Privacy policy

Last Updated: 1st March 2026

SpellingandVocab.com is operated by Komodo Learning Ltd.

Komodo Learning Ltd is registered with the UK Information Commissioner’s Office (ICO) under registration number ZB589020.

1. Our Role

We act as a data controller for teacher accounts and subscription data.

We act as a data processor when processing student data on behalf of schools.

2. Information We Collect

Teachers

  • Name
  • Email address
  • Login credentials
  • Uploaded lesson content
  • Student performance data
  • Subscription information

Payments are processed by Stripe. We do not store full card numbers.

Students

  • First name or display name
  • Login credentials
  • Writing submissions
  • Pronunciation recordings
  • Lesson results

We collect only data necessary for educational functionality.

SSO Data (Google/Microsoft)

  • Name
  • Email address
  • Basic profile information

Used solely for authentication and account management.

We do not sell or use SSO data for advertising.

Automatically Collected

  • IP address
  • Device information
  • Usage logs

Used for security and improvement.

3. How We Use Data

We use data to:

  • Provide the Service
  • Process subscriptions
  • Deliver AI feedback
  • Improve functionality
  • Maintain security
  • Comply with legal obligations

We do not sell personal data.

We do not use student data for behavioural advertising.

4. AI Processing

Student writing and pronunciation may be processed by third-party AI providers solely to generate feedback.

We require providers to process data securely and in accordance with applicable data protection laws.

5. Legal Bases (UK)

We process data based on:

  • Contract performance
  • Legitimate interests
  • Legal obligations
  • Consent (where required)

Schools determine lawful basis for student data.

6. U.S. Student Privacy

When used in U.S. schools:

  • Schools are responsible for obtaining parental consent under COPPA where required.
  • We act as a service provider under FERPA.
  • Student data is not sold or used for advertising.
  • Parents should contact their school first regarding student data.

7. Data Sharing

We may share data with:

  • Stripe
  • Cloud hosting providers
  • AI providers
  • Analytics providers
  • Professional advisers

We share only what is necessary to operate the Service.

8. Data Retention

We retain data only as long as necessary to provide the Service and meet legal obligations.

If an account is deleted:

  • Data is removed from active systems within a reasonable period.
  • Some data may remain in secure backups temporarily.

9. Your Rights

UK Users

You have rights to access, correct, delete, restrict, object, and request portability.

Contact: team@spellingandvocab.com

You may lodge a complaint with the UK ICO.

U.S. Users

  • You may request access or deletion.
  • Teachers may request deletion directly.
  • Students and parents should contact their school first.

10. Security

We implement reasonable technical and organisational safeguards including encryption in transit and access controls.

11. International Transfers

Data may be processed outside the UK. We use appropriate safeguards where required.

12. Changes

We may update this Policy from time to time.

13. Contact

team@spellingandvocab.com

Komodo Learning Ltd
109–113 Royal Avenue
Belfast BT1 1FF, UK