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LEGAL

Privacy Policy

Last updated: January 2025

Habbly ("we", "us", "our") provides a language-learning app used by students in class. This policy explains what data we handle, why, and the choices teachers and parents have. We’ve written it in plain English on purpose.

Habbly is operated by Habbly Ltd (company number 16242486), United Kingdom.
Questions or requests: hello@habbly.org

Our approach: collect as little as possible

Habbly is designed to be privacy-light. Students do not create a normal account and do not enter any personal details themselves. A student signs in with only a class code and a 4-digit PIN, nothing else.

Each pupil is shown a display name, but this is set by the teacher in their dashboard and linked to the PIN. The teacher chooses what to use, a first name, initials, or a username, so whether a pupil is identifiable at all is the teacher’s decision, not information the app collects from the child. There is no email, no surname, no date of birth, and no home address.

What we collect

Sign-in information

  • Class code and PIN, entered by the student to log in
  • First name, initials or username, entered by the teacher in the dashboard and linked to the PIN, so the teacher can recognise their pupils
  • A device identifier, used to keep the student signed in on their device

Learning activity

  • Answers to homework questions, scores, and time spent per question, this is what produces the progress reports teachers see in their dashboard

Spoken and written answers (for specific exercise types)

  • For pronunciation exercises, the microphone records the student’s spoken answer (see "Voice and microphone" below)
  • For writing exercises, the student’s typed answer is sent for automated marking (see "Third parties" below)

What we deliberately do NOT collect

  • Email addresses or surnames
  • Dates of birth
  • Location / GPS data

How we use this data

  • To run the app and deliver homework
  • To mark answers and give feedback
  • To show teachers their class’s progress
  • To keep the app working and secure

We do not sell personal data, and we do not use student data for advertising or to train our own models.

Legal basis and roles (UK GDPR)

The teacher creates the account and decides what homework to set and what display name to give each pupil, so the teacher determines how the app is used with their class. Habbly processes the limited data described above only to provide the Service. Because students sign in with only a class code and PIN, Habbly holds no directly identifying details about a child. If you have any questions, contact hello@habbly.org.

Third parties we share data with (sub-processors)

We use a small number of trusted services to make features work. We share the minimum needed and never more than required for the task.

PROVIDER
WHAT THEY RECEIVE
WHY
OpenAI
The student’s typed answer (for writing exercises)
Automated marking and feedback
Apple (iOS Speech Recognition)
The student’s recorded voice (for pronunciation exercises)
Converting speech to text to score pronunciation
ElevenLabs (United States)
Question text we author; no student data
Generating spoken audio for questions (text-to-speech)
Expo / push notifications
A device push token (if notifications are enabled)
Sending app notifications
AWS (Amazon Web Services)
Stored learning data
Secure backend hosting (United States, encrypted at rest)

These providers process data under their own terms; under our API agreements they do not use student answers to train their models. Where a provider operates outside the UK (e.g. in the United States), we rely on appropriate safeguards such as Standard Contractual Clauses / the UK International Data Transfer Addendum.

Voice and microphone

Pronunciation exercises ask the student to speak. When they do, the microphone captures their voice and it is transcribed using Apple’s speech recognition. The resulting text may then be marked as described above. The microphone is only used during these exercises, never in the background.

Data retention

We keep student learning data for as long as the teacher’s account is active. We will delete it within 30 days of a request from the teacher or a parent. Teachers can ask us to delete a class’s data at any time.

Security

Data is transmitted over encrypted connections (HTTPS) and stored encrypted at rest. Sign-in tokens are held in the device’s secure store (iOS Keychain / Android Keystore), and students can optionally enable biometric unlock. We restrict internal access to student data.

Children’s privacy

Habbly is built for use by children in an educational setting. We follow the UK GDPR and the ICO’s Age Appropriate Design Code (the "Children’s Code"): we minimise data, avoid profiling, show no ads, and turn off any non-essential data collection by default.

Your rights and how to exercise them

Students, parents and teachers can ask us to access, correct or delete a student’s data. Because pupils sign in with only a class code and PIN, and the only link to a real child is the display name held by the teacher, please route requests through the teacher, who holds the class records needed to identify the right pupil. Contact hello@habbly.org and we will respond within one month.

Changes to this policy

If we change how we handle data, we’ll update this page and the "Last updated" date above.

Contact

Habbly Ltd
Company No. 16242486
United Kingdom
hello@habbly.org
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