Privacy Policy

Last updated: 18 May 2026.

1. Introduction

Qwixl ("we", "us") is committed to protecting your privacy. This policy explains what personal data we collect, how we use it, and your rights. We operate with data minimisation: we only collect what we need to provide the service and to comply with the law.

2. Data controller

The data controller for Qwixl and the Milo Chrome extension is Luke Chapman, sole trader, of Old Furnace Cottage, Greendale, Oakamoor, Stoke-On-Trent, ST10 3AP, United Kingdom. For the purposes of UK GDPR, the controller determines the purposes and means of processing your personal data. Contact: support@qwixl.com.

3. Lawful basis

We process personal data where necessary for the performance of our contract with you (e.g. to provide the Service), where necessary for our legitimate interests (e.g. security, improvement of the Service) where not overridden by your rights, and where required by law (e.g. tax, safeguarding). Where we rely on consent (e.g. marketing communications), you may withdraw it at any time.

4. What we collect

We store: name (first and last), email address, role (e.g. teacher, student, parent), and account and usage data necessary to run the Service. We do not store school name or school address. For students we store date of birth so we can tell when they turn 13 and no longer require parental consent, without them having to create a new account. Payment card details are not stored by us; payment is handled by Stripe in accordance with their privacy policy.

5. How we use your data

We use your data to: create and manage your account; provide marking, feedback, and related features; run typing-based insight features; send service-related communications (e.g. consent requests, password reset); process payments via our payment provider; comply with legal obligations; and improve the Service (e.g. security, performance). We do not sell your personal data.

Subscription communications: If you have a paid subscription, we (or our payment provider) will send you renewal reminders before your subscription renews and confirmations when a payment is taken, so you have clear information about charges. This is in line with good practice for UK subscription services.

6. Typing telemetry

When students type answers within Qwixl we collect typing behaviour (e.g. timing, corrections) only within our answer fields. We do not track activity outside the Service. This data is used to provide early insight into learners who may need extra support and to support writing replay and integrity features. We do not use the content of what is typed for purposes beyond providing the Service to you.

7. Milo extension — Google user data and Limited Use

Milo is our Chrome extension for SEN-aware writing support in Google Docs. This section is the disclosure required by Google's API Services User Data Policy and explains exactly what Milo does with Google user data.

7.1 OAuth scopes Milo requests, and what each is used for

When you sign in to Milo with Google, Milo requests the following OAuth scopes. We request the minimum scopes needed to provide the features described in the Chrome Web Store listing.

• openid — required by Google's OpenID Connect protocol so Milo can verify that the sign-in came from a real Google account. We do not store the underlying ID token after sign-in.

• email — Milo reads your Google account email address so we can create your Milo account, link your extension session to that account, and send you service emails (e.g. subscription receipts). We store the email in our milo_users table.

• profile — Milo reads your basic Google profile (first name, last name, locale) so we can personalise the in-doc UI and address you correctly in emails. We store name and locale in our milo_users table.

• https://www.googleapis.com/auth/documents.readonly — Milo reads the content of the Google Doc you are currently editing, on demand, so it can produce writing-quality metrics, structure/expand/assess guides, and (optionally) an in-doc assistant grounded in your draft. Milo only reads the active document, only while the extension is open, and only after you sign in.

7.2 What we do with the document text

Document text obtained via the documents.readonly scope is fetched on demand, used transiently for the request you have just made, and is not persisted to our servers. We do not store the document text in our database, our logs, or any third-party storage we control.

7.3 What we do store against your Milo profile

From the document text we derive small, structured writing-quality metrics and store those against your Milo profile. These derived metrics are what powers the SEN-aware insights shown in the Milo side panel; they are not a copy of your document. Examples of derived metrics we store:

• Word, sentence and paragraph counts.

• Spelling-issue count and grammar-issue count (returned by LanguageTool — see 7.4).

• Sentence-structure indicators (e.g. average sentence length, sentence-type distribution).

• Typing pattern indicators (e.g. timing, pauses, correction frequency) captured while you type, as described in section 6.

• The document identifier (Google Docs file ID) so Milo can group metrics by document over time. We do not store the document title or content.

7.4 Third-party processor — LanguageTool

Milo's grammar and spelling analysis is performed by LanguageTool, via the public LanguageTool API at api.languagetool.org. To produce the grammar/spelling counts described in 7.3, Milo sends the text of the active Google Doc to LanguageTool's API and receives a list of issues in return. The text is sent transiently for that single request; we do not retain LanguageTool's per-request input or output beyond computing the derived counts we store against your profile.

LanguageTool acts as a data processor for us under contract. Their privacy policy is available at https://languagetool.org/legal/privacy. If you do not want your document text sent to LanguageTool, do not use Milo's writing-analysis features; the extension will fall back to local typing-pattern indicators only.

7.5 Retention and deletion (Milo-specific)

Derived Milo metrics are retained while your Milo account is active. If you delete your Milo account, derived metrics are deleted within 30 days. You can request deletion at any time by emailing support@qwixl.com from the Google account you used to sign in to Milo, or by removing the extension and emailing the same address asking us to purge derived metrics for your account. Because we do not persist document text, there is no document text to delete on request — the text only exists in transit during the request that processes it.

7.6 What we do not do

• We do not sell, transfer, or use Google user data for advertising.

• We do not use Google user data to train or improve generalised AI/ML models. (Derived metrics from your own account are used to improve your Milo insights only.)

• We do not allow humans at Qwixl to read your Google Doc content, except (a) where you have given affirmative consent for support, (b) for security investigations after we have notified you, (c) where required by law, or (d) where the data has been aggregated and anonymised so individuals cannot be identified.

7.7 Limited Use compliance statement

Milo's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

8. SEN screening data (Special Category Data)

Qwixl analyses typing patterns and written content to generate screening indicators for potential special educational needs (SEN), such as literacy and learning difficulties, attention and focus patterns, and writing and motor skill indicators. Under UK GDPR Article 9, this data is classified as Special Category Data (health-related) and is subject to additional protections:

• SEN screening data is processed on the lawful basis of legitimate interests for safeguarding and educational support, as permitted under the SEND Code of Practice 2015.

• Access to SEN data is restricted, by the student, to the student's teacher(s), linked SENCO, parent/guardian, and the student themselves. All access is logged for audit purposes.

• SEN screening indicators are not diagnoses. They are screening flags intended to support professional review. This is made clear throughout the Service.

• Schools using Qwixl should ensure that their own Data Protection Impact Assessment (DPIA) covers the processing of SEN-related data. A Data Processing Agreement (DPA) template is available on request.

9. Sharing and sub-processors

We share data only with sub-processors that help us run the Service. Each is bound by a contract that requires them to protect your data and use it only as we instruct.

• Supabase (database and authentication hosting) — stores Qwixl and Milo account data, telemetry, and derived metrics. Hosted in the EU.

• Vercel (web hosting and edge delivery) — serves the qwixl.com website and the Qwixl web application.

• Stripe (payments) — processes subscription payments. Stores card details on our behalf; we never see or store card numbers.

• Google (sign-in and Google Docs API for Milo) — see section 7.

• LanguageTool (grammar and spelling analysis for Milo) — see section 7.4.

• Resend (transactional email) — sends consent requests, password resets, subscription receipts and renewal reminders. Receives recipient email addresses and the email body.

We may disclose data where required by law or to protect our rights, users, or safety.

10. International transfers

Your data may be processed in the UK and/or the European Economic Area. Some sub-processors (e.g. Stripe, Google) operate in the United States; where we transfer data outside the UK/EEA we ensure appropriate safeguards (e.g. adequacy decisions, standard contractual clauses) are in place. Details are available on request.

11. Data retention

Qwixl (schools): account data is retained for as long as your account is active and for a limited period after closure for legal and operational purposes. Submission and telemetry data are retained for the duration of use and typically until the end of the academic year plus one year, unless you request earlier deletion or we are required to retain longer by law.

Milo (Chrome extension): account record (email, name, preferences) and derived writing-quality metrics are retained while your Milo account is active. If you delete your account, this data is deleted within 30 days. Raw Google Doc text is never persisted, so has no retention period (see section 7.2).

12. Safeguarding children and under-13 consent

We take the following measures to safeguard children:

• Minimum age to create an account: Children aged 9 and below cannot create a student account.

• Date of birth: We store students' date of birth so we can apply age-based rules and know when a student turns 13. We use it only for these safeguarding and consent purposes.

• Parental consent for under-13s: Students under 13 must provide a parent or guardian email at sign-up; we send that adult a link to approve the account before the student can access the Service.

• Year 7, 8 and 9 (UK) and equivalent year groups: For classes in these year groups, only students with approved parental consent can access the class. We require consent for all students in these year groups (not only those under 13), because in the UK school year (1 September–31 August) some pupils turn 13 during the year and some after; requiring consent for everyone in the year group keeps the rule clear and consistent, and also restricts these classes to children with parental consent so older learners cannot access the content.

• Restriction on senior and Higher Education classes: Students under 13 cannot join classes designated as Higher Education or senior-only (e.g. Year 12/13), so that younger children do not access content intended for older students.

Consent is collected and stored as described when you use the consent flow. Our full safeguarding position is set out in the Terms of Service.

13. Your rights (UK GDPR)

You have the right to:

• Access — request a copy of your personal data;

• Rectification — have inaccurate data corrected;

• Erasure — request deletion in certain circumstances;

• Restrict processing — limit how we use your data in certain cases;

• Data portability — receive your data in a structured, machine-readable format;

• Object — object to processing based on legitimate interests or for direct marketing;

• Withdraw consent — where we rely on consent;

• Lodge a complaint — with the ICO (ico.org.uk) or another supervisory authority.

To exercise these rights, email support@qwixl.com from the email address registered against your account. We will respond within one month unless the request is complex or numerous.

14. Changes

We may update this policy from time to time. We will post the updated version on our website and update the "last updated" date at the top of the Full Policy. For material changes, we will notify you by email or in-app notice where appropriate.

15. Contact

For privacy questions, data subject requests, or any concern about how Qwixl or Milo handles your data, email support@qwixl.com. Postal contact: Luke Chapman, Old Furnace Cottage, Greendale, Oakamoor, Stoke-On-Trent, ST10 3AP, United Kingdom.