Privacy and Cookies Policy
What personal information we collect, why, how we protect it, and your rights, including how we use cookies.
1. Who we are
SchoolJewel.com is owned and operated by Vladimir Keves, a sole trader trading as LD Pro ("we", "us", "our"), of 6 Coldhams North, Huntingdon, England, PE29 1UB. ICO registration number: ZB688986. You can contact us at info@schooljewel.com.
This policy explains what personal information we collect, why, how we protect it, who we share it with, how long we keep it, your rights, and how we use cookies. It is written to be read by school leaders, teachers, parents and carers. A short, child-friendly summary for pupils is available in our School and Trust Compliance Centre.
2. Our role: controller or processor?
Who is responsible for personal information depends on what it is.
| Information | Our role | Who decides how it is used |
|---|---|---|
| Pupil information and everything the School enters or records through the Service (names, classes, Houses, points, prizes, messages) | Processor: we act on the school's instructions | The School is the controller |
| Staff account information that the School creates for its Teachers | Processor (for the School) | The School |
| School Leader account, billing, support, security and website information | Controller | We do |
If you are a pupil, parent or carer and want to know how your or your child's information is used, please speak to the school first, as it makes the decisions and is responsible for your privacy notice. We will help the school to respond. Our Data Processing Agreement sets out our duties as processor.
3. Information we collect
3.1 Pupils (processed for the School)
A teacher creates each pupil account. We process:
- A name, exactly as the teacher enters it. Schools do not need to use full names. We strongly recommend only a first name and the initial of the surname (for example "Alex M."), or a class-based identifier. Some schools choose to use full names; that is the school's decision and responsibility.
- a generated username and password (printed on the pupil's login card, which may include a QR code);
- the class, school and (if used) House the pupil belongs to, and the class year group set by the teacher;
- points awarded or removed (category: Hero, Sage or Guardian; amount; date and time; and the teacher who made the change);
- Prize Shop activity: prizes chosen, points spent, status, and the classmate chosen if a pupil shares a prize with a friend;
- thank-you messages a pupil sends to a teacher (chosen from a fixed list of kind messages; the pupil never types anything); and
- Personal Best and celebration records: figures calculated from the pupil's own points, and whether they have seen certain celebrations or announcements.
What we do not collect about pupils: email addresses, dates of birth, home addresses, phone numbers, photographs, voice or video, location, health or special educational needs information, ethnicity, religion, free school meal or pupil premium status, behaviour incident reports or safeguarding information. Pupils cannot type free text, upload files or message anyone. Schools must not enter such information (see our Terms).
3.2 School Leaders and Teachers
- School Leaders (who register the School): name, email address, username and password, school name, membership level, and the classes, Houses and prizes they set up.
- Teachers (whose accounts a School Leader creates): the name the School Leader enters, a generated username and password, class link, and an automatically generated placeholder email address that does not receive email. If a Teacher chooses to receive thank-you messages, the professional name they enter (for example "Mrs Smith"), their choice, the messages they receive, and which ones they keep or clear.
- records of actions taken, such as awards given.
3.3 Payments
Where a School Leader buys a paid membership, payment is handled by our payment provider, Stripe. We receive confirmation that payment has been made, the membership level, billing name and email address, and the last four digits of the card used. We do not store full card numbers. We keep invoices and payment records for accounting purposes. Free memberships need no payment details.
3.4 Support and communications
If you contact us (for example at info@schooljewel.com) we keep your message, your contact details and our replies. We send service emails (for example about your account, renewals, new features and important changes) to School Leaders. We do not send marketing emails unless a School Leader has opted in, and you can unsubscribe at any time.
3.5 Technical and website visit information
When you visit the Website, our servers and security tools record technical information such as your IP address, browser and device type, pages requested, dates and times, and error and login records. We use this to keep the Website working and secure, to prevent misuse, and to investigate problems.
We also use Google Analytics in a minimal form to count visits and see which pages are used and for how long. It records basic information such as the pages viewed, the type of device and browser, and the approximate area a visit comes from. It does not receive names, pupil information or anything you enter into the platform, and we do not use it for advertising or to build profiles about people.
3.6 What we do not do
We do not show adverts, sell personal information, use pupil information for marketing, build advertising profiles, use social media tracking, or use pupil information to train artificial intelligence. The Service has no chat, comments, user-uploaded content or in-service purchases.
4. How and why we use information (and our lawful bases)
4.1 Where we are the processor (pupil and Teacher information entered by the School), we use information only to provide the Service to the School and on the School's instructions. The School is responsible for its lawful basis. For maintained schools and academies this is usually public task (Article 6(1)(e)); independent schools commonly rely on legitimate interests (Article 6(1)(f)). We do not rely on pupil consent.
4.2 Where we are the controller, we rely on:
| What we do | Lawful basis (UK GDPR Article 6) |
|---|---|
| Create and manage accounts; provide the Service; take payment; send service messages | Performance of a contract (6(1)(b)) |
| Provide support; keep the Website and Service secure; prevent fraud and misuse; understand and improve the Service using anonymous statistics | Legitimate interests (6(1)(f)): running a safe, reliable service for schools. We have considered the impact on individuals and that children use the Service, and use the minimum information needed |
| Count visits and see which pages are used, so we can keep the Website useful and working well | Legitimate interests (6(1)(f)). The cookies involved are used only for website statistics, which UK law allows without consent where we tell you about them and you can opt out freely |
| Keep accounting and tax records; respond to lawful requests from authorities | Legal obligation (6(1)(c)) |
| Send optional newsletters or updates | Consent (6(1)(a)), which you can withdraw at any time |
4.3 Automatic calculations (no automated decision-making). The Service automatically adds up points, balances, House scores and Personal Best figures. This is routine calculation that helps teachers and pupils celebrate effort and growth. It is not used to make decisions that have a legal or similarly significant effect on anyone. Pupils are never ranked against one another, and points must not be used by schools for assessment, grading or behaviour sanctions. If we ever introduce anything that does make such decisions, we will tell you first and give you the safeguards required by law.
5. Children's information
Children need particular protection. SchoolJewel is designed around the ICO's Age Appropriate Design Code (the Children's Code): pupil accounts are created only by a school; we collect the least information we can; pupils have no direct contact with each other or with us; there is no advertising, tracking for advertising, nudge techniques that encourage spending, or in-service purchases; points cannot be bought; and high-privacy settings are the only settings. Pupil information is never made public. See also our Safeguarding page.
The Service is offered through schools, not directly to children. We do not ask children for consent. Parents and carers with questions should contact the school.
6. Who sees pupil information
- The pupil sees only their own points, prizes and messages. If a pupil shares a prize with a classmate, the classmate's name appears as a first name and initial.
- The pupil's Teacher can see the pupils in their own class.
- The School Leader can see their whole school, including class totals, House totals and thank-you messages sent to staff.
- A Teacher who is thanked can read the messages sent to them.
- Nobody outside the school sees pupil information, other than our small team (who access it only to provide support or maintain the Service) and the service providers listed below.
7. Who we share information with
We do not sell personal information. We share it only where necessary:
| Recipient | Why | Information |
|---|---|---|
| Websupport s. r. o. (EU) | Hosts the Website, database and email accounts, and sends service emails, under a contract that meets Article 28 | All information |
| Amazon Web Services (AWS), S3 storage in the EU | Stores our backups. Backups are encrypted on our server before they are sent, so AWS cannot read them | Encrypted backups of the database |
| Google (Google Analytics) | Provides our basic website visit statistics (pages viewed, visit length, device type). No pupil names or platform information | Basic visit data |
| Stripe | Takes card payments as an independent controller | Billing details of School Leaders |
| Professional advisers (accountants, lawyers, insurers) | Professional advice, audit and insurance | Only what is necessary and lawful |
| Police, regulators, courts or others | Where the law requires, or to protect a child or prevent crime | Only what is necessary and lawful |
| A buyer or successor to our business | If the business changes hands, on the same protections | All information, with notice to you |
The software that powers memberships (Paid Memberships Pro) and points (GamiPress) runs on our own hosting. Our "Listen" button uses the text-to-speech voices built into the pupil's own device and browser; depending on the device, those voices may be provided by the device manufacturer or browser developer, which we do not control.
8. Where information is stored
Information is stored in the European Union. Our hosting provider is based in the European Union, and all of our servers are located within the European Union. Encrypted backups are held with AWS S3 in the European Union. We do not transfer pupil information outside the UK or the European Economic Area, and the UK treats the EEA as providing adequate protection for personal information.
Our basic website statistics (Google Analytics) contain no pupil information. Google may process that visit data in other countries under its own international transfer safeguards.
If we ever need to transfer information to a country that is not covered by UK adequacy regulations, we will first put in place the safeguards required by law (such as the ICO's International Data Transfer Agreement or Addendum) and tell schools in advance. Payment data is handled by Stripe under its own arrangements.
9. How long we keep information
| Information | How long we keep it |
|---|---|
| Pupil accounts, points, prize and message records | For as long as the school keeps the pupil in the Service. Deleting a pupil removes their account and linked records. Schools are encouraged to remove pupils who have left at the end of each school year |
| A class (including its Teacher and pupil accounts) | Until the school deletes the class |
| A whole school, after a request to leave | Deleted from our live systems within 30 days of the request |
| After a paid membership ends without renewal | 90 days, then deleted or anonymised |
| Free accounts inactive for 12 months | Deleted after we have emailed a reminder to the School Leader |
| House competition totals and announcements | These contain no pupil identities. Announcements are deleted after 90 days; yearly totals after two school years |
| Backups | Encrypted, and overwritten on a rolling cycle. Kept for up to 90 days from the date each backup was created, so deleted information disappears from backups within that time |
| Invoices and payment records | 6 years, as required for tax and accounting |
| Support emails | 24 months after the matter is closed |
| Server and security logs | Up to 90 days |
| Website visit statistics (Google Analytics) | 14 months, as set in our analytics account |
We may keep information for longer where the law requires it, or where it is needed to deal with a legal claim.
10. How we keep information safe
We use HTTPS encryption; role-based access so that pupils, teachers and school leaders only see what they should; checks on every request; randomly generated passwords; a block on the usual WordPress password-reset route for teachers and pupils; limited staff access; regular updates; and encrypted backups stored in the EU. Teacher passwords are stored securely hashed and shown only once. Pupil login details are generated by the Service and held so that teachers can reprint login cards; they unlock only that pupil's own points, prizes and messages, which contain no sensitive information. Schools should keep login cards secure and issue a new password if one is lost.
If there is a personal data breach that affects your information, we will tell the school (or you, where we are the controller) and the Information Commissioner's Office when the law requires.
11. Your rights
Under UK data protection law, you can ask:
- to be told how your information is used (this policy);
- for access to a copy of your information;
- for corrections to inaccurate information;
- for information to be deleted in certain circumstances;
- to restrict or object to some uses of your information;
- for portability of information you gave us under contract; and
- to withdraw consent where we rely on it.
To exercise these rights over information we hold as controller (for example School Leader accounts and billing), email info@schooljewel.com. We will respond within one month (which may be extended by up to two further months for complex requests, and the clock may be paused while we ask you to confirm your identity or clarify your request). We will make reasonable and proportionate searches. There is normally no charge.
For pupil information, please contact the school. If you contact us directly, we will pass your request to the school without delay and support it, because we cannot decide such requests ourselves.
12. Complaints
We would like the chance to put things right first. You can complain to us at info@schooljewel.com, marking your email "Data protection complaint". We aim to acknowledge it within 5 working days, and will in any case acknowledge it within 30 days, respond without undue delay, and keep you informed of progress and outcome.
You also have the right to complain to the Information Commissioner's Office: ico.org.uk, telephone 0303 123 1113, or Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. You may do so at any time, though we hope you will contact us first.
13. Cookies and similar technologies
13.1 What they are
Cookies are small text files stored on your device by a website. "Similar technologies" include browser storage that works in a comparable way. They are used to make a website work, remember choices and sometimes measure use.
13.2 Our approach
SchoolJewel uses only a small number of cookies: those needed to make the Website work and keep it secure, and two basic cookies that help us count visits. We do not use advertising, social-media or cross-site tracking cookies. We use Google Analytics in a minimal form to count visits and see which pages are used. It is used only for website statistics, never for advertising, and it does not receive pupil names or anything entered into the platform.
UK law (the Privacy and Electronic Communications Regulations 2003, as amended by the Data (Use and Access) Act 2025) allows cookies that are strictly necessary, and cookies used only to collect statistics to improve a website, without asking for consent, as long as we tell you about them and you can object easily and for free. A notice on the Website points you to this policy. You can opt out of our visit statistics at any time by installing Google's Analytics opt-out browser add-on or by blocking cookies in your browser settings. If we ever add a cookie that does need consent, we will ask for it first.
13.3 The cookies and storage we use
| Name | Purpose | Type | Duration |
|---|---|---|---|
| wordpress_logged_in_*, wordpress_sec_* | Keep you logged in securely | Strictly necessary | Session, or up to 14 days if "Remember me" is chosen |
| wordpress_test_cookie | Checks that your browser accepts cookies | Strictly necessary | Session |
| wfwaf-authcookie-* | Used by our security firewall to recognise logged-in users and protect the Website | Strictly necessary (security) | Up to 1 day |
| ucp_tabs | Remembers which tab you were last looking at | Functionality | 1 year |
| __utma, __utmz | Basic visit statistics (Google Analytics): count visits and show which pages are used and how people arrive | Statistics | About 13 months / 6 months |
| __stripe_mid, __stripe_sid (payment pages only) | Set by Stripe to prevent fraud | Strictly necessary (security) | 1 year / 30 minutes |
| Browser session storage (e.g. scm_tab_*, scm_flash) | Remembers which tab you were on and shows a confirmation after you save | Functionality; not a cookie, cleared when you close the tab | Session |
13.4 Controlling cookies
You can delete or block cookies through your browser settings (see aboutcookies.org). If you block strictly necessary cookies, you will not be able to log in. Schools may also manage browsers on school devices.
14. Links to other websites
The Website may link to other websites, which have their own privacy policies. We are not responsible for them.
15. Changes to this policy
We may update this policy from time to time. The date at the top shows when it was last changed. We will give School Leaders reasonable notice of material changes by email.
16. Contact us
Vladimir Keves, a sole trader trading as LD Pro, 6 Coldhams North, Huntingdon, England, PE29 1UB. Email: info@schooljewel.com.
