Privacy Policy

Learn Phonics · Last updated: 21 October 2026 · Applies to version 1.0 and later

This policy is between you and Mohibur Rahman, trading as Humble Code, the developer of Learn Phonics, wherever you live. It is written in plain language for parents, carers and teachers, so you can see what information is involved when your child uses the app, why, and the choices you have.

In short

Everything your child does in the app — sounds met, practised and checked, words built and read, lessons finished — stays on your device. It is never uploaded, and we cannot see it.
We run no servers, no accounts and no analytics. The app contains no code that connects to the internet.
There are no adverts of any kind, and no advertising or tracking software in the app.
Nothing about your child leaves the device unless you, the grown-up, press Share.
The one-time “Unlock everything” purchase is handled by Apple; we never see your payment details.
You can delete one child’s progress, or everything, in the grown-up area. Deleting the app deletes all of its data.
The App Store privacy label for this app is “Data Not Collected”.

Who we are

Data processing in connection with the app is the responsibility of:

Mohibur Rahman, Humble Code, the developer of Learn Phonics (“Humble Code”, “we” or “us”). You can contact us about this policy or anything else to do with data protection at info@humble-code.com.

Where this policy applies

This policy applies to the Learn Phonics app for iPhone and iPad, a phonics app for children in Reception and Year 1 (ages 4 to 6), which we call the “app” or the “service”. Where we say “we”, that means the controller named above. We follow the UK Data Protection Act 2018, the UK GDPR and the EU GDPR, and the app is designed to the UK’s Age Appropriate Design Code (the Children’s Code).

Information stored on your device only

So that your child can carry on where they left off, the app keeps the following on your device, and nowhere else. For each child:

their progress: which sounds they have met, practised and been checked on, the words they have built and read, and the lessons they have finished;
what you told the app: the sounds you ticked as already met at school, this week’s focus sounds, and what you heard your child say on the “Listen to your child” card;
a profile: an avatar (a drawn animal or shape) and a colour, and a nickname only if you chose to add one. The nickname is for you: the app never says it aloud and never shares it unless you switch it on for the teacher card.

And for the device:

your settings from the grown-up area, such as the session length, the pace, the grown-up tips and the accent switch;
a cached copy of whether “Unlock everything” has been bought, so the app works offline.

None of this is uploaded. We cannot see it, and deleting the app deletes it.

Where it is kept

In the app’s own private storage on your device, which other apps cannot read, protected by your device’s passcode encryption. If your device is backed up to iCloud or to a computer, the app’s progress and settings are included in that backup like any other app’s data, so progress is not lost if you replace the device. That backup belongs to you and is covered by your agreement with Apple; we cannot see it.

What we do not do

We do not ask you or your child to create an account. We do not use analytics, advertising or crash-reporting services. We do not collect your child’s real name, date of birth, photograph, voice, school or email address, and there is nowhere in the app to enter them. The app does not use the microphone, camera, location, contacts or photos, and never asks for permission to. It sends no notifications. We do not sell personal information.

When you press Share

The grown-up area can make a card for your child’s teacher: one page listing the sounds met, the ones checked in the app and what you have heard, with the last two weeks. It carries no name unless you have typed a nickname and switch it on for that card. The card is made on your device and leaves it only if you press “Share the card” and choose where to send it, using your device’s normal share sheet (for example AirDrop, Mail or Print). Once shared, it is handled by the app or person you chose, not by us. The app never shares anything by itself.

The “Unlock everything” purchase

“Unlock everything” is a one-time, non-consumable in-app purchase processed by Apple. The purchase and “Restore purchases” sit in the grown-up area, behind a question for grown-ups. Payment happens entirely within Apple’s App Store systems under Apple’s privacy policy. We do not receive or store your name, payment details or Apple Account. Your purchase is tied to your Apple Account, so you can restore it on any of your devices, and if you use Family Sharing, Apple can share it with your family’s devices. The app keeps only a local yes/no record of whether “Unlock everything” has been bought.

Children

Learn Phonics is made for young children, and is listed in the App Store’s Kids category. We do not collect personal information from children, or from anyone else, through the app; all learning progress stays on the device. In line with the Children’s Code and Apple’s rules for Kids apps:

every setting starts at the most private option;
no personal data is collected, profiled, shared or sold, and there is no advertising of any kind;
your child is never asked for information about themselves, and nothing in the app nudges them to give any;
there are no links to websites, no purchases and no settings on your child’s screens. They all sit in the grown-up area, behind a question for grown-ups;
no streaks, timers, scores or reminders pull your child back into the app.

Testing versions of the app

While the app is being made, the developer installs test versions on devices used in testing sessions. Only those test versions keep a log of taps, sounds and pauses with their times, and only they have a “Family testing” panel in the grown-up area. The version on the App Store keeps no such log and has no such panel.

In a test version, the panel’s “Share session notes” button opens the normal share sheet. If a grown-up chooses to share, the notes contain the short session code (a letter and one or two digits, never a name), every screen, spoken line, tap and pause with clock times, the sounds met, the app version, whether the device is an iPhone or an iPad, the system version and the text size. They never contain a name, a nickname, a recording or anything typed by a child. The log is not included in device backups.

If your family helps us test the app

Consent first. A parent or carer reads and signs a consent form before a session begins, and may withdraw at any time, during or after the session, by contacting us. Anything we hold about that session is then deleted.
Codes, not names. Each child is given a short code. The code is what appears in the app and in our notes. No list linking codes to names is kept with the notes, and no name is ever typed into the app.
Notes only. We write notes about what the child does on screen. We do not record audio or video, and we do not photograph the child.
Where it is kept, and for how long. The signed consent form, our written notes and any session notes a parent chose to share are kept in a private folder on the developer’s own encrypted computer, never in a shared or public place. Notes and session logs are deleted when the app is first released on the App Store. Consent forms are deleted twelve months after that, so that we can answer any question about what was held.
What we use it for. Only to improve the app. It is never published, shared or sold.

If you contact us

If you email us, we use what you send only to answer you, and we keep it only for as long as needed to help you.

Downloading the app

Apple collects information when you download or update the app from the App Store, such as your Apple Account details and the time of download. We have no influence over that and do not receive it. If you have chosen, in your device’s Settings, to share analytics with app developers, Apple may also pass us crash reports and usage totals for this app; Apple collects these under its own policy, and they do not tell us who you or your child are. Both are governed by Apple’s privacy policy: www.apple.com/legal/privacy.

Why we use information

to provide the app to you and keep it working reliably;
to improve the app through the family-testing sessions described above, only with a parent’s consent;
to respond to you if you contact us;
to comply with the law and to establish, exercise or defend legal rights.

Legal bases (Article 6 UK GDPR / GDPR)

Consent — for the family-testing sessions, given by a parent or carer on the consent form. You can withdraw consent at any time as described above. Processing carried out before withdrawal remains lawful.
Contract — where processing is necessary to deliver something you have asked for, such as the “Unlock everything” purchase, which Apple processes.
Legitimate interests — to answer your emails and to keep the app working.

How information is shared

We do not sell or share any information about you or your child. The only things that ever leave the app are what you choose to send with the share sheet. We may disclose the little we do hold, such as an email you sent us, if reasonably necessary to comply with a legal process, to assist in the prevention or detection of crime, or to protect the safety of any person.

International transfers

We transfer no data anywhere, because the app sends us none. Anything Apple processes in connection with the App Store or the purchase is governed by Apple’s privacy policy.

How long information is kept

On your device, until you delete it or delete the app. The app does not delete progress by itself, because a child coming back after a long break should find their sounds where they left them. We keep nothing beyond any correspondence you send us, which we delete once your query is resolved, and the family-testing records, kept only for the periods set out above.

Deleting your child’s data

Open the grown-up area (the grown-up button on the Home screen, then answer the sum written in words).

Delete one child’s progress: Privacy, then “Delete [child]’s progress”, and confirm once. This removes everything recorded about that child’s learning; their avatar and nickname stay so they can still find themselves on Home.
Remove a child altogether: Settings, then Delete beside that child under Children, and confirm once.
Delete everything: Privacy, then “Delete everything”, and type the word “delete” to confirm. This removes every child, all their progress and every setting on this device.
Delete the app: deleting the app from your device deletes all of its data.

Copies in an iCloud or computer backup made before you deleted are replaced as new backups are made, or you can delete the backup yourself. There is nothing to delete on our side, because nothing is held on our side.

Your rights

Under Articles 15 to 22 of the UK GDPR and GDPR you have the right to access, rectify and erase your personal data, to restrict or object to its processing, and to data portability. Because the app sends us nothing, most requests about the app will be answered by confirming exactly that; for the family-testing records and any email you sent us, we will act on your request. We aim to reply within a week.

You also have the right to lodge a complaint with a data protection supervisory authority. For us that is the Information Commissioner’s Office (ICO): ico.org.uk/make-a-complaint, helpline 0303 123 1113, or by post to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would appreciate the chance to resolve any concern first, so please contact us before approaching the ICO.

Security

Because your child’s data never leaves your device, it is protected by your device’s own security: your passcode, Face ID or Touch ID, and Apple’s encryption. The grown-up area, with the share sheet, the purchase and the link to this page, sits behind a question for grown-ups.

Uninstalling

Uninstalling the app in the usual way deletes everything it has stored on your device.

Automated decision-making

The app chooses which sounds to revisit from your child’s answers, on the device only. Nobody else sees these answers and they are not used for anything else. We do not use automated decision-making or profiling that produces legal or similarly significant effects concerning you or your child.

Changes to this policy

We will update this policy whenever a change to the app makes it necessary, and we will show the new date at the top and say what changed. The app will never start collecting data without a new version of this policy and a change to its App Store privacy label.

Questions and complaints

Please direct any questions or comments about this policy to info@humble-code.com. If you believe we have acted otherwise than as described here, please tell us.