Privacy Policy

ActuallySpeak Kids · Effective date: 5 August 2026 · Last updated: 30 September 2026
The short version. ActuallySpeak Kids is built for children aged 4–9, used with a grown-up. Your child can play without any account — that progress stays on your device. A grown-up may optionally create a free account with their own email so progress is saved and follows the child across devices. We don't show ads, we don't sell personal data, and we don't use third-party advertising trackers. You can erase everything at any time.

Who we are

ActuallySpeak Kids ("the app") is operated by Matthew Fabling, a sole trader trading as “Smooth English” ("we", "us", "our"), who is the data controller for the app. “Smooth English” is a trading name of Matthew Fabling; it is not a registered company. Postal address: 4 Earlsburn Road, Lenzie, Glasgow, East Dunbartonshire, Scotland, G66 5PF, United Kingdom. For any privacy question, or to exercise a data right, contact us at actuallyspeak.help@gmail.com. This is also our contact point for data-protection matters.

Who this app is for & who holds the account

The app is intended for children aged 4–9 used together with a parent or guardian. Children are not asked to provide personal information to learn. Any account is created and held by an adult (18+) who is the child's parent or guardian: account creation is placed behind a grown-up step, and the only personal detail an account needs is the grown-up's email address. By creating an account or allowing a child to use the app, the parent/guardian agrees to this policy on the child's behalf and confirms they are 18 or older.

What we collect — and what we don't

1. Stored on the device only (not sent to us) — for everyone: the child's chosen first name or nickname and avatar, and their learning progress (lessons completed, words practised, stars, streaks, badges, jungle items) and grown-up settings. This lives in your browser/device storage.

2. If a grown-up creates an optional account: we collect the grown-up's email address and store a copy of the child's learning progress (the same game data as above — nickname, avatar, stars, streaks, words practised, lessons completed) in our secure database, linked to that account, so it can sync across devices. You can sign in with a password or a one-time email link. If you set a password it is stored securely (salted and hashed) by our authentication provider — never in plain text and never visible to us. We do not ask for the child's real full name, birthday, address, phone number, photos, contacts or precise location.

3. Microphone (optional): speaking practice uses the microphone only while the child is doing a speaking activity. Audio is sent to our own server to give friendly pronunciation feedback and is not used for advertising. Recordings are not kept unless a grown-up turns on "Keep recordings" in Settings. Speaking is always optional.

4. Free Talk — AI chat (optional, OFF until a grown-up turns it on): Free Talk lets a child have a short spoken chat with one of the app's cartoon characters, played by an AI assistant. It is switched off by default and cannot be used until a parent or guardian passes a grown-up check and gives consent inside the app. When it is on, what we send is: the words the child taps or says in that chat, their first name and age (so the character speaks at the right level), and a list of the English words they have already met in the app. If the child speaks, the audio is turned into text and the audio is discarded immediately. We do not store the conversation on our servers, we do not keep a transcript, and neither the conversation nor the child's voice is used to train any AI model. Anything the safety system flags for your attention is stored on your device only and shown to you in the grown-ups area. A grown-up can withdraw consent at any time in Grown-ups → Settings, which deletes the permission record and switches the feature off.

5. Leaderboard (optional, off unless a grown-up joins): if a grown-up opts in, we store only a jungle nickname, an emoji avatar and a star count — no real names, emails, birthdays or location.

We do not knowingly collect precise geolocation, contacts, photos, or persistent advertising identifiers, and we do not build advertising profiles of children.

How we use information, and our lawful basis

DataWhy we use itLawful basis (UK/EU)
Grown-up's email (account)To create the account, send the sign-in link, and save/sync the child's progress you asked us to keepPerformance of a contract / the service the parent requested
Child's learning progressShow progress, remember settings, run the learning gamePerformance of the service, at the parent's request
Microphone audioGive pronunciation feedback (processed then discarded unless you opt to keep it)Consent (you choose to use speaking / keep recordings)
Marketing emailsOnly if the grown-up ticks the optional box — occasional product newsConsent (opt-in; withdraw any time)

We do not use children's information for behavioural advertising or profiling. If you tick the optional "email me news" box, you can unsubscribe from any email or by contacting us; unsubscribing does not delete your account.

How the app talks to the internet (and where data goes)

To protect children and to work reliably worldwide (including mainland China), the child's browser only ever talks to our own domain. Features like Kiki's voice, word pictures, pronunciation feedback and account sync are relayed by our own servers on your behalf; your child's browser does not connect directly to third-party services. The service providers ("sub-processors") we rely on strictly to deliver the app are:

ProviderPurpose
SupabaseSecure database & account authentication (stores account email + synced progress)
NetlifyWebsite hosting and the server relay that keeps everything same-origin
Email delivery provider (e.g. Resend, via our Mailery system)Sending the sign-in link and, if opted in, product-news emails
Google Cloud Text-to-SpeechKiki's spoken voice
Microsoft Azure SpeechPronunciation feedback scoring
PexelsWord-picture image search
Anthropic (Claude)The AI that plays the character in Free Talk. Sent only the chat itself plus first name, age and known-word list. Conversations are not used to train models.
Groq (Whisper)Turning a child's spoken sentence into text during Free Talk. Audio is processed once and not retained.
StripeTaking payment when a grown-up buys a plan. Stripe receives the grown-up's email and handles the card, Alipay or WeChat Pay details directly — we never see or store them. We keep only the fact that the email has an active plan, which plan it is, when it ends, and Stripe's own reference for it, so access can be restored on a new device. No child's name or progress is ever sent to Stripe.

These providers process data only to perform their function for us, not for their own advertising. Some providers may process data outside your country; where required we rely on appropriate safeguards (such as standard contractual clauses).

Children's privacy (COPPA, UK Children's Code & GDPR-K)

We designed ActuallySpeak Kids to be data-minimising and parent-supervised. Children can learn without an account and without providing personal information. Where an account exists, it is created by a parent or guardian using the grown-up's own email, which serves as the point of parental consent and control. We do not knowingly collect personal information directly from a child under 13 (US) / under the applicable age of digital consent (UK/EU) without a parent or guardian. If you believe a child has provided us personal information without appropriate consent, contact us and we will delete it promptly.

Parental choices, access & deleting data

A grown-up can, at any time:

Depending on where you live, you may also have rights to access, correct, port, restrict or object to our use of your data, and to lodge a complaint with your local data-protection authority (in the UK, the ICO).

Data retention & security

On-device data remains until a grown-up erases it or clears their browser. Account data (email + synced progress) is kept while the account is active and deleted on request or after a prolonged period of inactivity. Access to the database is protected by row-level security so an account can only ever read or change its own data, and connections are encrypted in transit. No method of transmission or storage is 100% secure, but we use reasonable technical and organisational measures to protect information.

No sale of data & no ads

We do not sell or rent personal information, and we do not serve third-party advertising or use advertising trackers in the app.

Changes to this policy

We may update this policy; we will change the "Last updated" date above and, for significant changes, provide a clearer notice.

Contact

Questions or requests about privacy? Email actuallyspeak.help@gmail.com.

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