Privacy Policy

1. Introduction

Walnut Learning Assistant provides AI-powered personalised learning for young learners. Protecting the privacy of parents/guardians and students is central to how we operate.

This Privacy Policy explains how we collect, use, and safeguard information. We will always act reasonably, collect only what is necessary, and handle all data securely.

2. Information We Collect

We may collect different types of information to provide and improve the Service. The categories below are examples and not a complete list:

• Parent/Guardian Information: such as name, contact details, payment information, and account preferences.
• Student Profile Information: such as first name, age or grade, subject choices, and learning progress.
• Learning Data: such as quiz results, AI interactions, progress history, and preferences.
• Technical Data: such as device type, operating system, browser, IP address, and usage logs.
• Marketing Data: such as communication preferences, responses to offers, and feedback provided by parents/guardians.

Every student account is created and managed by a parent or carer from their own Walnut account. Students cannot sign up on their own, whatever their age.

On our website, we use Google Analytics 4 and Microsoft Clarity only if you opt in through our cookie controls. Google Analytics collects aggregated information about how pages are used (such as approximate location and device type). Microsoft Clarity additionally records how pages are interacted with (mouse movements, clicks, scrolling, and replays of the screens visited) to help us understand and improve the experience. Passwords and payment details are always masked by the tool and never appear in recordings. You can withdraw that consent at any time via Cookie preferences on the site; see our Cookie Policy for details.

3. How We Use Data

We use the information we collect for purposes such as:

• Providing, personalising, and improving the Service.
• Tracking learning progress and providing reports to parents/guardians.
• Training and improving our AI models (using anonymised or aggregated data where possible, and always respecting the right to withdraw consent).
• Supporting safety through content moderation and parental controls.
• Processing payments and managing subscriptions.
• Sending service updates, relevant offers, and communications to parents/guardians.
• Conducting analytics and research to enhance the user experience.
• Meeting legal, regulatory, or compliance requirements.

You can withdraw consent for your or your student's data to be used for AI training at any time by contacting us. This will not affect the provision of core tutoring services.

4. Advertising and Marketing

We may use anonymised or aggregated data for marketing insights. We may also use limited data (such as cookies or device identifiers) to re-advertise Walnut's services to parents/guardians. Students are never served targeted advertising.

5. Sharing of Data

We may share information in limited ways, such as with:

• Service providers who help us operate the Service (for example, hosting, analytics, or payment processing).
• Schools or organisations (if your subscription is arranged through them, and only with appropriate agreements in place).
• Legal or regulatory authorities where disclosure is required by law.
• Business partners or successors in the event of a company merger, acquisition, or restructuring.

We do not sell personal data. Any sharing will be limited, secure, and consistent with the purposes set out in this Policy.

6. Data Retention

• Student learning data is retained for the duration of the subscription plus 12 months, unless deleted earlier by the parent.
• Account and transaction data is retained as long as legally required for tax and compliance.

We will not keep personal data for longer than necessary.

7. Your Rights (UK & EU GDPR)

Parents and carers, and students themselves, have rights under data protection law, including the right to:

• Access, correct, or delete personal data.
• Withdraw consent for processing or marketing.
• Withdraw consent for data to be used in AI model training.
• Request data portability.
• Restrict or object to certain types of processing.
• Lodge a complaint with the Information Commissioner's Office (ICO).

To exercise these rights, please contact info@walnutlearn.com.

8. Students' Privacy

Walnut is designed with safeguarding in mind.

• Student accounts can only be created by a parent or carer, from their own Walnut account. Students cannot register themselves, whatever their age.
• Parents and carers can read their child's conversations with the tutor from the parent dashboard.
• We do not knowingly collect personal information from a child without a parent or carer's involvement.

9. Security

We use measures such as encryption, secure storage, and access controls to protect data. While no system is 100% secure, we continuously review and improve our safeguards.

10. International Data Transfers

Walnut's database and uploaded files are stored in the UK, with Amazon Web Services in London. To write the tutor's replies and to check every message for safety, the content of lessons is processed by named providers in the United States: Anthropic (the tutor) and OpenAI (safety checks, image checks and the optional read-aloud and voice features). Sign-in (account email addresses and passwords) is handled by Google Firebase, which may process it in the United States or the European Union. Each provider works under a data processing agreement with UK transfer safeguards.

Data may therefore be stored or processed outside the UK/EEA. Where this occurs, appropriate safeguards (such as Standard Contractual Clauses or the UK International Data Transfer Agreement) will be in place. The full list of providers, what each receives and where, is on our Sub-processors page.

11. Updates

We may update this Privacy Policy from time to time. Parents/guardians will be notified of material changes, and the "Effective Date" at the top will be revised.