Biro privacy policy

Biro, by AgentMaker LLC · Effective [DATE] · Version 2.1

Biro and your data: the short version

Written for you, not for lawyers. About a 4-minute read. The full version is below.

Who we are. Biro is made by AgentMaker LLC, a small company in the US. We're responsible for your data. Questions? Email support@birogcse.com.

What we know about you

Your account: your email and your password if you use one (stored by our sign-in provider, never by us). If you sign in with Apple or Google, they tell our sign-in provider your email (Apple can give a private relay address instead) and, for Google, your name and picture. Biro itself doesn't ask for or store your real name.
Your handle: Biro starts you with a handle, and you can choose your own, within Biro's rules. Other students see it, so keep your real name out of it. After you change handle or delete your account, the old one can't be used by anyone for 90 days, or a year if we removed it. We keep only a simplified version of it, with no link to you. It's the only name other students ever see. They never see your real name or email.
Your study stuff: your year group, subjects, exam boards, grades and target grades, exam dates, answers, marks, XP, streaks and cards. And, only if you choose to answer, how you feel about exams.
Photos of your work, if you choose to snap an answer. They're marked, then deleted. We don't keep them.
Your chats with Biro, if you turn chat on. Kept for 180 days.
Friends, classes, leagues and messages, if you use them. Messages to friends are kept for 90 days. If someone you've messaged deletes their account, what they sent you stays for 30 days so you can read and report it, shown as "Deleted account". Your replies stay with it, unseen, in case a moderator needs them. The same applies to what you send if you delete yours.
Safety records: reports, blocks, and messages our safety checks flag. If your account is banned or paused, we keep a scrambled code of your email, never the address, for as long as the sanction lasts and at most 12 months. It stays if you delete your account, and the sanction comes back if that email signs up again. If you delete an account that has sent messages or has a report open, we keep that code for 30 days so a moderator can act on a report. A report still open can keep it longer, up to 12 months.
The IP address you sign in from, kept for 90 days, only so we can help the police if someone is putting a child at risk.
Your plan: Free, Pro or the Exam Pass. Apple takes the payment. We never see your card.

What we don't collect: your location, your date of birth, your phone number, or your contacts list. We don't use any advertising, analytics or tracking tools, and we never sell your data.

What the AI does

When Biro marks an answer or chats with you, your words (or photo), and in chats your study profile, go through a service called OpenRouter to OpenAI's GPT-4.1 mini, run by Microsoft Azure.
We don't add your name or email. But if your name is in a photo or in what you write, it goes too, so leave it out.
Neither of them keeps it or trains AI on it, with one exception: OpenRouter screens what it carries for child sexual abuse material, and may keep what that flags where the law requires. We only use providers that promise this.
Biro's marks are AI estimates, not real exam marks.
Chat is optional. You turn it on yourself, and turning it off deletes your chats and what Biro remembered from them. Marking keeps working either way.
Voice: your iPhone turns what you say into text (sometimes using Apple's speech service). Only the text is sent. No audio is kept.
Memory: only if you say yes. Turning chat on doesn't turn this on. The first time Biro could remember a study fact you told it, like an exam date, it asks. Until you say yes it keeps nothing and sends nothing from memory to the AI. See it, delete any of it or turn it off in Settings → Privacy and AI → What Biro knows. It's in Download my data too.

If you tell Biro something worrying (like you're not safe or you're thinking of hurting yourself), Biro points you to people who can help, like Childline (0800 1111). An adult safeguarding lead is alerted, and they're the only person at Biro who can read what you said, so they can decide what to do. They may not be able to reach you directly, so please tell an adult you trust too.

Who can see you

Other students only ever see your handle, never your name or email.
Only friends you've both accepted can message you. No photos, files or links in chat.
Nobody can find you from their contacts unless you turn that on. The Community league is off unless you join it.
You can report or block anyone. See our safety page.

How long we keep it

Your account and study data: until you delete your account.
Chats with Biro: 180 days. Messages to friends: 90 days. Sign-in IP: 90 days.
Delete your account in Settings. Your email and handle go straight away and the rest within 30 days, apart from a few safety records we keep for a while, such as a scrambled code of your email (details).

Your rights

Get a copy: Settings → Download my data.
Delete your account: Settings → Delete account.
Turn off chat, and delete what Biro remembered: Settings → Privacy and AI.
Anything else (fix something, see the safety records the download leaves out, object to something): email support@birogcse.com.

You don't need a parent's permission to do any of this. A parent or carer can contact us for you if you'd like them to.

Not happy? Email us and we'll reply within 30 days. You can also complain to the ICO, the UK's data regulator: ico.org.uk/make-a-complaint or 0303 123 1113.

1. Who we are

Biro (the "app") is provided by AgentMaker LLC, a limited liability company registered in [STATE], USA (registration no. [NUMBER]), at [REGISTERED ADDRESS] ("we", "us"). We are the controller of the personal data described here.

Privacy contact: support@birogcse.com
General support: support@birogcse.com
UK representative (UK GDPR Art 27): [UK REPRESENTATIVE NAME, ADDRESS, EMAIL]. You or the ICO can contact our representative about anything to do with your data.
Data protection officer: we aren't required to appoint one. Our privacy lead is [NAME / ROLE], reachable at support@birogcse.com.

2. Who Biro is for

Biro is a GCSE and IGCSE revision app for students in the United Kingdom, usually in Years 10 and 11 (aged 14 to 16). It isn't for anyone under 13: when you make an account, you confirm you're 13 or over. We don't ask for your age or date of birth. Instead, Biro treats every account as a child's: everyone gets the same protective settings, whatever their age. If we learn that someone under 13 has an account, we delete it.

We've designed Biro to follow the ICO's Age Appropriate Design Code (the Children's Code) and to take account of the extra protection children's data gets under UK data protection law. See section 15.

3. What we collect and why

Data	Where it comes from	Why we use it	Lawful basis (UK GDPR Art 6)
Account: email address, a password and any second sign-in factor you add (held by Clerk, never by us), or your Apple or Google sign-in instead of a password, and sign-in sessions. With Apple you can use a private relay address. Google also gives Clerk your name and picture, which Clerk holds for your sign-in. Biro doesn't ask for your real name or copy it into your Biro account	You, Clerk, and Apple or Google if you sign in with them	Creating and securing your account, and contacting you about it	Contract (Art 6(1)(b))
Profile: handle (made by Biro, or one you choose within Biro's rules), cosmetics you've earned, time zone, invite code, privacy settings, notification choices	You, and the app	Running your profile and showing friends who you are, by handle only	Contract
Onboarding and study data: year group, subjects, exam boards, tiers, current and target grades, exam dates, study times, topics you're doing in class, answers, marks, feedback, mocks, papers, XP, streaks, mastery, cards	You, and the app as you use it	Running Biro: your plan, practice sets, papers, progress and grade estimates	Contract
How you feel about exams (optional onboarding questions, each with Skip)	You	Tuning Biro's tone and your plan. Never shown to other students	Contract. You can skip them
AI marking: your typed answer, or a photo of your handwritten answer, with the question and mark scheme where Biro has them (a photographed exam board paper is sent with no question or mark scheme: only its subject, exam board, tier and qualification, and the names of the skills it could test). A photo goes as you took it, so anything in it goes too. For a board paper, you crop each page on your phone and only the part you keep is sent	You	Getting an AI estimate of your mark and feedback	Contract: marking is the service. Before your first mark we tell you what's sent and where. That's information, not consent
Mark reports ("My answer was marked wrong"): the answer and your note	You	A person reviews it to fix how Biro marks. It doesn't change your mark. If we agree the mark was wrong, we keep the answer without your account details to improve marking	Contract, then legitimate interests (better marking)
Chats with Biro and the section tutor: your messages (typed, or the text of what you said) and Biro's replies	You	Answering your study questions	Consent (Art 6(1)(a)), which you can withdraw in Settings → Privacy and AI
Biro's memory: study facts you tell Biro (like "mocks start 12 Jan")	You	Personalising help. This is profiling (section 8)	Consent, separate from chat: Biro asks once, with yes and no side by side. Nothing is remembered, or sent to the AI from memory, unless you said yes. Withdraw any time in What Biro knows
Friends and classes: friend list and requests, how you connected (invite code, QR, contacts or class), blocks, classes you own or join	You, and other students	Running the social features you choose to use	Contract
Leagues: your league, weekly XP and rank	The app	Weekly leagues with friends, your class, and (only if you join) the Community league	Contract
Messages to friends: text, time sent and read, and whether a safety tip was shown	You, and your friends	Delivering messages between friends	Contract
Contacts matching (only if you use it): one-way codes ("hashes") made on your phone from the emails and numbers of the contacts you pick. If you turn on "Let contacts find me by email", a code made from your own verified email	You	Showing which of your contacts already use Biro. The codes from your contacts are checked and thrown away, never stored. Your contacts list never leaves your phone	Consent (you choose to use it, and for the contacts check the iPhone asks permission)
Safety: reports you make or that are made about you (with a copy of the reported message and the 9 before it), blocks, safety flags on chats and answers (category and a short extract, up to 300 characters), reviewer notes, sanctions, appeals and legal holds	You, other students, and our safety checks (section 7)	Keeping students safe, enforcing Biro's rules, and meeting our Online Safety Act duties	Legitimate interests (keeping children safe) and legal obligation (Art 6(1)(c)). In an emergency, vital interests (Art 6(1)(d))
Banned, paused and deleted accounts: in the cases in section 11, a scrambled code made from the account's email with a secret key, never the address itself	The account	Putting a ban or pause back if the same email signs up again, and letting a moderator act on a report about a deleted account	Legitimate interests (keeping children safe)
Sign-in IP address and time	Clerk, each time you sign in	Helping the police or the National Crime Agency find someone who is putting a child at risk	Legal obligation (Online Safety Act reporting) and legitimate interests (keeping children safe)
Subscriptions: plan, trial and Exam Pass status, expiry, the product bought, and purchase events. We never receive card details	Apple, via RevenueCat	Giving you what you've paid for	Contract. Records: legal obligation (tax and consumer law)
Usage limits: how many marks and messages you've used this month	The app	Applying your plan's limits and preventing misuse	Contract, and legitimate interests (preventing misuse)
Notifications: your phone's push token and your notification choices	Your device	Sending the notifications you've turned on. Message notifications are off until you turn them on, never show what was said, and don't arrive between 9:30pm and 7am	Contract
AI consent records: what you agreed to, which version, the AI provider named, and when	The app	Proving what you agreed to	Legal obligation (Art 7(1))
Support, privacy requests and complaints: your emails to us	You	Answering you	Legal obligation, and legitimate interests
Technical logs: server logs and errors kept briefly by our hosting provider	Automatic	Keeping Biro working and secure	Legitimate interests

Before you make an account. The onboarding questions you answer before "Save your plan" stay on your phone. Nothing is sent to us, and nothing goes to the AI, until you make an account. If you don't, Biro deletes them from your phone once they're 7 days old, the next time it's open.

Special category data. We don't ask for health, religion, sexuality or other special category data, and Biro's memory is built to keep study facts only, though no check catches everything: you can see and delete what it kept in What Biro knows. If you tell Biro something like this in a chat, it's used only to reply to you and, if it raises a safety concern, to help keep you safe (section 7).

What we don't do:

no advertising, and no advertising or attribution tools
no analytics or crash-reporting tools from other companies. The stats we use to run Biro (like XP and how many cards are earned) stay in our own database. If you've chosen on your iPhone to share analytics with app developers, Apple may show us crash reports, which don't tell us who you are. If we ever add an analytics or crash-reporting tool, we'll update this policy first
no tracking across other companies' apps or websites
no location
no selling or "sharing" of personal data
no training AI on your data, and our AI providers don't either

4. Your phone's camera, mic and other permissions

Biro uses these only for the parts of the app that need them, and your iPhone asks your permission first wherever it requires it. You can turn them off in iPhone Settings → Biro.

Camera: to photograph an answer for marking, and to scan a friend's invite QR code.
Photos: to pick a photo of a handwritten answer for marking.
Photos of your work aren't kept. They're sent for marking, read, and then gone. We don't keep the picture. For a past paper marked on paper, we keep only the label and the marks.
Microphone and speech recognition: to talk to Biro and to play Splatter. Your iPhone turns your voice into text, on the phone itself when it can, and otherwise using Apple's speech service under Apple's privacy policy. Only the text reaches us. No audio is recorded or kept.
Contacts: only if you choose to find friends from your contacts (section 3). Your contacts are never stored.
Motion: to tilt some of Biro's scenes a little as you move your phone. Nothing is recorded.
Clipboard: read only when you tap to paste an invite code.
Notifications: only the ones you turn on.

In the UK, if you're 13 or over you can give your own consent to online services (UK GDPR Art 8, Data Protection Act 2018 s9). We ask for consent only for chat with Biro (including voice and the section tutor), Biro remembering study facts from chats, and contacts matching. Each is asked separately: chat and the contacts check with the same-sized Yes and No, and "Let contacts find me by email" with a switch that's off until you turn it on. You can withdraw at any time in Settings: Privacy and AI for chat, Friends and privacy for "Let contacts find me by email". Turning chat off deletes your chats and anything Biro remembered from them, and the rest of Biro keeps working.

6. How the AI works

Route: AI requests go from our servers (Convex) to OpenRouter, Inc. (US), which sends them only to OpenAI's GPT-4.1 mini, hosted by Microsoft Azure. Biro has no AI key in the app, and our servers refuse any other model. If we change the model or host, we'll update this policy and ask for your chat consent again.
What's sent: the question and mark scheme where Biro has them (for a photographed exam board paper, instead: its subject, exam board, tier and qualification, and the names of the skills it could test), your answer or photo, and for chat your recent messages, your study profile (such as your subjects, exam boards, tiers, target and estimated grades, goals, exam dates, mock marks, questions you got wrong recently, what you're doing in class, and your streak and sets this week) and the study facts Biro remembers. Biro doesn't add your name, email or account ID. They only go if they're in what you send: a name written on a photographed page, or typed in an answer or a chat. So crop them out or leave them out. Each request carries a one-way, scrambled ID so misuse can be traced without identifying you.
No keeping, no training: every request tells OpenRouter not to store it and to use only zero-data-retention providers. OpenRouter and Microsoft Azure don't keep the content of Biro's requests or use it to train AI, with one exception: since 27 October 2026 OpenRouter screens all requests for child sexual abuse material, and what that flags may be kept for human review and reporting where the law requires.
Accuracy: AI marks are estimates. They aren't official exam board marks and can be wrong. On a practice question, use Report question and choose "My answer was marked wrong": a person reviews it to fix how Biro marks, though it doesn't change your mark. For a photo mark, or to ask about a mark, email us.
Biro is an AI, not a person. It's told to stick to studying, and to point you to help if you seem at risk.

7. Safety checks

Because Biro is used by children, we check for signs that someone may be at risk or breaking Biro's rules:

Messages to friends, handles and class names go through an automatic word and pattern filter before they're sent. It stops most personal details, links, sexual content and abuse, hides swearing, and can show the person you're talking to a safety tip. Friends' messages aren't sent to the AI. If it recognises you saying you're being hurt, bullied or thinking of hurting yourself, that message goes through, without any personal details, and Biro shows you where to get help. If a message has words the filter stops and it can't tell what you mean, it isn't sent, but our adult safeguarding lead can read it, and you're shown where to get help.
Chats with Biro and your written answers are checked by a phrase list and by the same AI, through the same no-keeping route, for signs of self-harm, abuse, sexual content or violence. The answer text used for this check is deleted once it's been checked, and always within 2 days. A scrambled fingerprint of it, which stops the same answer being checked twice, goes after 2 days too.
If it suggests someone may be at risk (like self-harm, abuse or a threat), Biro shows support (like Childline) and an adult safeguarding lead at Biro is alerted. A sexual flag alerts the lead too. The alert email contains no message content. Only the lead can read what a student said in a flag, a report or an appeal, and only the lead decides them. Anyone else on our team sees how many are waiting and whether any are overdue, and nothing else. They can decide a report about a bad handle with nothing but the handle to read, in our secure admin tool.
Reports. When you report someone you've messaged, we save the last 10 messages between you (or the one you reported and the 9 before it), and any others in the chat our checks are worried by, so a person can see what happened. If you report a handle from a profile, we save only those. Biro's own checks read every report and the chat behind it. What they're worried by, and anything we're not sure about, alerts the safeguarding lead straight away. They can't recognise every way of saying something, so a person looks at the rest, within 48 hours. The lead can see how often someone has reported, only as information.
Checking in. If the safeguarding lead is worried about a student, they can have Biro show a short, fixed check-in with where to get help. It can't carry a message or take a reply, and it goes once a week at most. We keep a record that it was sent.
Automated checks, the AI included, never ban anyone on their own. If several people report someone, their social features can pause automatically for 48 hours while a person checks. A later report doesn't restart it, and the team is alerted when it starts and again before it ends. A person makes every other decision, and you can appeal (safety page).
Where the law requires it, we report child sexual exploitation and abuse to the UK's National Crime Agency, and we tell the police or children's services if a child may be at risk of serious harm.

8. Profiling and automated decisions

Biro builds a study profile of you (your estimated grades, weak topics, exam dates and, if you agree, memory facts) so it can choose practice questions, plan your weeks and tailor help. This is profiling. It's the point of a revision app, so it's on, but it's limited to study information. You can see it in Settings → Privacy and AI → What Biro knows and in Download my data. Memory facts come only from chat, and only if you said yes: delete one, delete them all or turn memory off in What Biro knows. Turning chat off deletes what it remembered from your chats and turns memory off too.

We don't make decisions based solely on automated processing that have legal or similarly significant effects on you. AI marks and grade estimates are practice feedback. They don't affect your real exam results or your school record. Safety filters can hold a message, and several reports can pause someone's social features for 48 hours while a person checks. A person makes every other decision about your account. You can ask a person to look at a mark by emailing support@birogcse.com.

We don't sell your data. We share it only with these service providers ("processors"), who act on our instructions under data processing terms:

Provider	What they do	Data	Location
Clerk, Inc.	Sign-in and accounts	Email, password, sign-in sessions and IP address, and for Google sign-in your name and picture	US
Convex, Inc.	Database and backend	Everything in section 3	US
OpenRouter, Inc.	AI routing	AI request content (section 6), not kept	US
Microsoft Corporation (Azure)	Runs the AI model	AI request content, not kept	US and other countries where Azure runs
RevenueCat, Inc.	Subscriptions	Your Biro account ID, purchases and subscription status	US
Expo (650 Industries, Inc.)	Delivering notifications	Push token and the notification text	US
Resend, Inc.	Sending safety alert emails to our safeguarding lead	An alert that something needs checking, or how many. No message content	US

Apple handles payments, refunds and your App Store account as an independent controller under its own privacy policy, and so does its speech service when your iPhone uses it. We receive only subscription status, through RevenueCat.

Apple and Google sign-in. If you choose to sign in with Apple or Google, each handles your account with them as an independent controller under its own privacy policy, and passes your sign-in to Clerk. If you signed in with Apple and delete your Biro account, we ask Apple to remove Biro's access. If that doesn't work, the app tells you how to do it yourself.

We may also disclose data:

where the law requires it, including reports to the National Crime Agency under the Online Safety Act
to the police or children's services where we believe a child is at risk of serious harm
to a buyer of our business, under the same protections, with notice to you

Other students see only your handle, your cards and cosmetics, your league rank and weekly XP, and the messages you send them. They never see your real name or email. Students in a league or class who aren't your friends see a smaller card and can't message you. If you turn on "Let contacts find me by email", classmates can send you a friend request too.

10. International transfers

AgentMaker LLC and our providers are in the United States, so your data is processed there. Where a provider is certified under the UK Extension to the EU–US Data Privacy Framework (the "UK–US data bridge"), we rely on that. Otherwise we use the ICO's International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. Email support@birogcse.com for a copy of the relevant safeguard.

11. How long we keep data

Data	Kept for
Account, profile, study data, cards	Until you delete your account
Chats with Biro and the section tutor	180 days after the last message, or until you turn chat off
Biro memory facts	Until you delete them in What Biro knows, turn chat off, or delete your account, and for 12 months at most
Messages to friends	90 days after they're sent, unless they're part of an open report or a legal hold, or someone in the chat has deleted their account (next rows)
After a block, an unfriending or a pause	A sender can't take a message away from you. After a block, each of you can still read what you received for 30 days, read-only, so you can report it. If you're no longer friends or they're paused, you can read, read-only, what they sent you in the last 30 days
Messages from someone who deletes their account	30 days from the deletion. The person who received them can read them, read-only, and report them, shown as "Deleted account". Their replies stay with them, unseen, in case a moderator needs them. Then all of it's deleted, unless it's part of a report or a legal hold
Sign-in IP addresses	90 days, unless a hold keeps them (for example, for a report to the police or the NCA)
Answer text held for a safety check	Until it's been checked, and always under 2 days. Its scrambled fingerprint goes after 2 days
Reports, with the saved messages and reviewer notes	12 months after the report is closed, whether or not the accounts still exist. Longer only under a hold, or while an appeal is waiting (up to 30 days from the appeal). If you delete your account, a report you made stays without anything that links it to your email or handle
How a report was sorted: the result and a short reason	With the report, and no more than 13 months
A record that the safeguarding lead sent a check-in	12 months, unless a hold keeps it
Safety flags and alerts	12 months after they're reviewed. A flag not yet reviewed stays until it is
Appeals	Until you delete your account. Then we keep only the decision and dates, with no note and no account ID, for our safety numbers
Legal holds	When we report to the National Crime Agency or the police, the flagged words, safety alerts, sign-in IPs and any report (with its saved messages) are kept for 1 year from the report, even if the account is deleted. Your email and handle still go if you delete your account. While the account is open, a hold also keeps chats with Biro past 180 days. The reference, the category and the dates (not the words) are kept for 5 years. A hold overrides the other times in this table for the records it covers
Deleted accounts with an unreviewed safety flag	The flag, its alerts and the sign-in IPs are kept for 30 days so the safeguarding lead can check it, then deleted unless a hold applies
Scrambled code of your email, if your account is banned or paused	As long as the sanction lasts, and no more than 12 months. It stays if you delete your account, and goes if the sanction is lifted. A ban has no end date: if a banned account is deleted after those 12 months, a new code is kept for up to 12 months from the deletion
Scrambled code of a deleted account's email, with no ban or pause	Only if the account had sent messages or had a report open: 30 days, and no more than 12 months while a report stays open. If a moderator bans or pauses the account in that time, the row above applies. Otherwise we don't keep one
Marked answers kept to improve marking	Only from mark reports we agree with, with no account details, so they're no longer about you
AI consent records, subscription records	Until you delete your account. Apple keeps its own purchase records
Support, rights requests and complaints	2 years after they're closed
Invite codes	Replaced after 30 days, the next time you open Friends
An old handle, after you change it or delete your account	Only a simplified version (lower case, lookalike letters merged), with no link to you, so nobody can pose as you: 90 days, or a year after a moderator's reset. A report that led to that keeps the old handle as its record
The code behind "Let contacts find me by email"	Until you turn it off or delete your account
Blocks	Until either account is deleted
Onboarding answers before you make an account	On your phone only. Biro deletes them once they're 7 days old (counted from your first answer), the next time it's open
Your last AI replies, held so a retry isn't charged twice	Up to 2 days, even if you turn chat off in that time
Hosting backups	Up to [30] days
AI providers	Nothing kept, with one exception for child sexual abuse material (section 6)

Deleting your account (Settings → Delete account, then confirm) removes your email, handle and invite code from your Biro account straight away. The rest of your data is then deleted from our database, and your sign-in account at Clerk and your RevenueCat record are deleted, within 30 days. Backups expire within [30] days. We keep only what the table above says, such as open safety reports. What you sent stays for 30 days so the people you messaged can read and report it, read-only, shown as "Deleted account". Their replies stay with it, unseen, in case a moderator needs them. Then those messages are deleted, unless they're part of a report or a legal hold. If your account is banned or paused, the scrambled code of your email stays, and the sanction comes back if that email signs up again. If you delete an account that has sent messages or has a report open, we keep that code for 30 days so a moderator can act on a report. A report still open can keep it longer, up to 12 months. If you signed in with Apple, we ask Apple to remove Biro's access. Deleting your account doesn't cancel an Apple subscription: cancel that in iPhone Settings → your name → Subscriptions.

12. Your rights

You have the right to:

access your data (Art 15)
rectification (Art 16)
erasure (Art 17)
restriction (Art 18)
data portability (Art 20)
object (Art 21), including to processing based on legitimate interests
withdraw consent at any time (Art 7(3))
rights around automated decision-making (section 8)

How to use them:

In the app: Settings → Download my data (a file with your account, study data, what Biro remembered, friends, chats, classes, and the reports and appeals you made), Delete account, and Privacy and AI (turning chat off, which also deletes what Biro remembered).
By email (a "subject access request"): support@birogcse.com. Use this for anything the app doesn't do, including safety records about you that the download leaves out. We'll ask you to confirm it's your account, usually by replying from your Biro email. We may hold back parts of safety records if sharing them would identify another student or put a child at risk; if we do, we'll tell you.

We reply within one month (we can extend this by two months for complex requests, and we'll tell you if so). It's free. You can use these rights yourself whatever your age. A parent or carer can act for you with your agreement.

13. Complaints

Tell us first at support@birogcse.com with "Privacy complaint" in the subject. Under the Data Protection Act 2018 (s164A), we'll:

acknowledge your complaint within 30 days
look into it without undue delay
tell you the outcome

You can complain to the Information Commissioner's Office at any time: ico.org.uk/make-a-complaint · 0303 123 1113 · Wycliffe House, Water Lane, Wilmslow SK9 5AF.

Complaints about content or safety on Biro (not about your data) follow our safety page.

14. Security

Data is encrypted in transit (TLS) and at rest by our hosting providers.
Server-side rules mean you can only read your own data and what other students show you on Biro.
Only named people can see safety records: our safeguarding lead sees all of them. The Biro team member who checks bad-handle reports sees the handle and no one's words.
No secret keys are shipped in the app.

If a breach puts your rights at risk, we'll tell the ICO within 72 hours and tell you without undue delay.

15. Our assessment

We carried out a Data Protection Impact Assessment before any student used Biro, and updated it for this version. It covers AI marking, chat, voice, memory and profiling, friends, classes, leagues, contacts matching, safety checks and IP logging. A summary is available on request at support@birogcse.com.

16. Changes

We'll update the date at the top. For important changes, we'll tell you in the app before they take effect, and ask for consent again where needed.