Your data, in plain English.

If you're a student

• We keep your first name, the first letter of your surname, your username, your class, your answers, your marks and your streak. That's so you can see your progress and your teacher can help you. We don't ask for your email address.
• Your teacher approves everyone who joins their class, so only the right people are in it.
• If something you write suggests you might be at risk, a safeguarding lead at your college may be told, so they can help.
• When you talk your answer, your phone turns it into words. We never record or keep your voice. Only the words are sent.
• We don't show you adverts and we don't track you around the internet.
• Your teacher can see your answers and marks. Other students can't, and we never compare you with them.
• Please don't put things in your answers that you want to keep private, like your address or phone number.
• You can download everything you've done from the Me screen, and you can ask your teacher or college to delete your data.

The detail

Who's responsible

When a college or school uses Foothold, the college is the data controller and Foothold is the processor, working under a data processing agreement. For parents who subscribe directly, Foothold is the controller.

What we collect

• Students: first name, surname initial, username, class, and an exam date if entered. No email address, date of birth or phone number. Teachers and safeguarding leads: name and college email.
• Learning data: answers, marks, feedback, breakout plays, streaks, settings such as font and text size.
• Technical data needed to keep the service running and safe.

Where it goes

• Stored with our database provider in a London data centre.
• Answer text and practice text are sent to an AI provider to produce feedback. We don't send names or contact details, and we never send audio. We are confirming the provider's retention and no-training terms before any pilot.
• Analytics, if used, are privacy-friendly and don't use advertising trackers.

Your rights

You can ask to see, correct, export or delete your data. For students in a college, ask the college first. Teachers can export or delete a student's data themselves, and we'll help the college respond to any request.

Keeping it for how long

• Student learning data (answers, marks, feedback, progress and the student's account) is deleted automatically at the end of the academic year plus 30 days, which is 30 September unless the college asks us to keep it longer or delete it sooner. Teachers see a warning 30 days and 7 days before, with a download of the data.
• Join requests that nobody approves are removed after 14 days.
• The content of a safeguarding flag is cleared 90 days after the college closes it. Only the date, category, status and who handled it remain. The history of who viewed or changed a flag is kept for 2 years and holds no student content.
• Teacher accounts are removed after 12 months without use. Register-interest enquiries are removed after 12 months.
• We keep anonymous totals (for example the number of answers and an average) only for groups of 10 or more students. They contain no names, usernames or answers.
• Database backups roll over every 7 days, so deleted data can remain in a backup for up to 7 days.

Examples on this site use only made-up data. These periods are our defaults and are confirmed in each college's data processing agreement.

Children's Code

Foothold is designed with the ICO Children's Code in mind: high-privacy settings by default, no marketing trackers and no nudges to share more data.