No personal data collected
We never ask for your name, email, or any personal information.
✓ Privacy firstWorks fully offline
All content and progress is stored on your device. No server required.
✓ No internet neededCompletely ad-free
No advertisements of any kind — ever. No ad SDKs, no tracking.
✓ Zero adsSafe for children
Designed for ages 8–11. Compliant with UK GDPR and the ICO Children's Code.
✓ Child-safe1Introduction
BrightOwl 11+ ("the App", "we", "us", "our") is an educational mobile application designed to help children aged 8–11 prepare for the UK grammar school 11+ entrance examinations. The App covers:
This Privacy Policy explains clearly and honestly how the App handles information when you or your child uses it. We are committed to the highest standards of data privacy — especially given our audience of younger learners.
Data Controller
The data controller responsible for BrightOwl 11+ is an independent developer operating under the trading name BrightOwl 11+, based in the United Kingdom.
Contact: 0xsupports@gmail.com
As the App collects no personal data, no Data Protection Officer (DPO) appointment is required under UK GDPR Article 37.
2Information We Collect
We do not collect personal information. The App does not ask for, transmit, or store any of the following:
- Names, usernames, or profile information
- Email addresses or phone numbers
- Passwords or login credentials (there are no accounts)
- Location data (GPS or IP-based)
- Photos, camera, or microphone access
- Contacts or calendar data
- Device identifiers (IMEI, advertising ID, etc.)
- Behavioural tracking or analytics data
- Payment information of any kind
The only data that exists is local progress data, stored exclusively on your child's device:
- Words marked as learned, starred, or needing practice
- Per-word learning data (mastered words and practice history)
- Quiz scores, grammar, spelling, and comprehension results
- Daily challenge streaks (current and longest) and stars and coins earned
- Date of last activity and last daily challenge completion
- Badges, achievements, and passage scores unlocked
- Avatar selection and theme preference (e.g. light / dark mode)
This data never leaves your device. It is stored locally using your device's secure sandboxed app storage and is automatically deleted if you uninstall the App. We have no access to it whatsoever.
3How Data Is Used
Because we collect no personal information, there is nothing to use, share, or sell. Local progress data is used solely by the App itself — to display your child's learning history, achievements, and chosen avatar within the App on the same device.
We do not use any data for advertising, profiling, machine learning training, research, or any commercial purpose whatsoever.
Legal basis (UK GDPR Article 6(1)(f)): to the extent that locally stored progress data constitutes personal data, the legal basis for storing it is legitimate interests — specifically, to provide the core educational functionality of the App. The data is stored solely on the user's own device, is never transmitted, and remains under the user's complete control at all times.
4Children's Privacy
BrightOwl 11+ is specifically designed for children aged 8–11. We take their privacy with the utmost seriousness and comply fully with:
- UK General Data Protection Regulation (UK GDPR) — in particular Article 8, which requires parental consent for processing personal data of children under 13.
- ICO Children's Code (Age Appropriate Design Code) — the UK statutory code of practice requiring online services likely to be accessed by children to provide high privacy protections by default.
- Google Play Families Policy — the App does not use advertising of any kind, does not collect sensitive data, and any external links (such as to this Privacy Policy or our support contact) are clearly labelled and age-appropriate.
Because we collect zero personal information, no parental consent mechanism is required. There is nothing to consent to. Children can use the App safely without creating an account or providing any personal details whatsoever.
Parent/guardian note: If you believe your child has somehow provided personal data through the App, please contact us immediately using the details in Section 10. We will investigate and delete any such data without delay.
5Permissions
BrightOwl 11+ requests no runtime permissions from your device. The App does not ask for access to:
- Internet or network access
- Camera or microphone
- Location (GPS or network-based)
- Contacts, calendar, or files
- Phone state or call logs
- Notifications (no push notifications are sent)
The App works entirely offline. No internet connection is required to use any feature of BrightOwl 11+. All learning content, exercises, and rewards are bundled within the App itself — nothing is downloaded from external servers during use.
6Data Storage & Security
All progress data is stored in the App's sandboxed local storage, provided by the Android and iOS operating systems. This storage is:
- Isolated from all other apps on your device
- Accessible only to BrightOwl 11+
- Automatically encrypted on devices with a screen lock enabled (OS-level encryption)
- Automatically and permanently deleted when the App is uninstalled
Since no data is ever transmitted to external servers, there is no possibility of a server-side data breach affecting your child's information.
To clear all App data manually:
- Android: Settings → Apps → BrightOwl 11+ → Storage → Clear Data
- iOS: Uninstall and reinstall the App
- Within the App: Settings → Reset All Progress
There is no cloud backup of progress data. If the App is uninstalled or its data cleared, all progress is permanently deleted and cannot be recovered.
7Third-Party Services
BrightOwl 11+ does not integrate any third-party advertising networks, analytics tools, crash-reporting SDKs, or social media plugins. Specifically:
- No Google AdMob or any advertising network
- No Google Analytics, Firebase Analytics, or any analytics service
- No Facebook SDK or social login
- No crash-reporting services (e.g. Sentry, Crashlytics)
- No payment processing SDK (purchases handled by the platform store)
The App is built with the Flutter framework by Google. All fonts used by the App are bundled within the App itself — no font files are downloaded from external servers at runtime. No personal data is transmitted to any third party under any circumstances.
When you download BrightOwl 11+ from the Google Play Store or Apple App Store, those platforms have their own privacy policies governing the download transaction. We encourage you to review:
8In-App Purchases
BrightOwl 11+ is free to download and offers an optional one-time upgrade to BrightOwl Premium (price as displayed in the App and on the store listing at the time of purchase). The premium upgrade unlocks additional content including extended vocabulary, grammar and comprehension exercises, spelling and sentence-builder activities, unlimited quizzes, and exclusive avatar options and cosmetic themes.
Payment is handled entirely by the platform store (Google Play or Apple App Store). BrightOwl 11+ never sees, stores, or processes your payment card details or billing information. All financial transactions are governed by the relevant store's own terms and privacy policy.
- One-time purchase — no subscription and no auto-renewal
- No personal or payment data passes through our systems
- Purchase is tied to your store account (Google or Apple), not to BrightOwl
- No additional cost is ever required to continue using the free features
Parents or guardians should ensure that in-app purchases are suitably protected on the child's device — for example, by requiring a password or biometric confirmation for purchases in the device settings.
9Your Rights
Under the UK GDPR and other applicable data protection laws, you have the right to access, correct, and delete personal data held about you. Since we hold no personal data, these rights are satisfied by default — there is nothing for us to provide, correct, or delete.
If you have a concern or believe this is not the case, please contact us (see Section 10) and we will respond within 30 days.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) — the UK's independent data protection supervisory authority:
- Website: ico.org.uk
- Telephone: 0303 123 1113
10Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or the App's data practices, please get in touch:
BrightOwl 11+ — Privacy Contact
Email: 0xsupports@gmail.com
We aim to respond to all privacy enquiries within 5 business days.
Developer: Independent developer trading as BrightOwl 11+, United Kingdom
Please include "Privacy Policy" in your subject line.
11Changes to This Policy
We may update this Privacy Policy from time to time — for example, if we add new features or if legal requirements change. When we do:
- The "Effective date" at the top of this page will be updated
- The latest version is always available at the URL linked in the App's store listing
- For material changes — especially those affecting how data is handled — we will seek fresh consent where required by applicable law
If you do not agree with any changes, you may uninstall the App at any time.