The short version
- Your explorers' names, ages and avatars, the pictures they take, their badges and their progress stay on your phone. We never receive them.
- Your location is used on your phone to move the story along. It is not sent to us.
- There are no adverts, no tracking or analytics tools, and we never sell personal data or build profiles of children.
- The app sends us anonymous counts, such as "a story was started on this trail today", so the parks that host trails know they're being enjoyed.
- If you choose to sign in, write a review, join the waitlist or get in touch, we keep what you give us for the reasons and periods set out below.
Who we are
Clever Cookie Studios is run by [Company legal name] (company number [Company number]), registered at [Registered address]. We are the controller of the personal data described in this notice, which means we decide how it is used and are responsible for looking after it. We are registered with the Information Commissioner's Office (ICO) under registration number [ICO registration number].
Trails are hosted by partner organisations, such as parks, estates and visitor attractions. They are separate organisations with their own privacy notices for things like parking, tickets and CCTV at their sites. This notice only covers Clever Cookie Studios.
For anything about privacy, email hello@clevercookiestudios.com.
Families using the app
What stays on your phone
Most of what makes Clever Cookie Studios personal is stored only on your device. We can't see it, and we can't recover it for you if it's deleted.
- Explorer profiles: the name or nickname, age and avatar you choose for each child.
- Pictures taken in the scrapbook game, and the badges, progress and finished adventures that go with them.
- Saved and walked trails, settings and the story you're part way through.
- Your first name and email address, if you sign in, so the app can greet you.
- Location readings, sound levels from noise games, and motion readings from tilt and shake games. These are used in the moment to run the story and are never sent to us.
Grown-ups can remove all of this with "Delete all explorers, stickers and pictures" in grown-ups' settings, or by deleting the app.
What the app sends to us
- Requests for stories, trails, pictures and narration. Like any internet request, these reveal your IP address and device type to our hosting provider. We don't store them in our database or use them to identify you.
- Anonymous play events: what happened (for example a story started, a stop unlocked or a plaque scanned), on which story, trail and stop, how it was unlocked (walking, GPS, NFC tag, QR code or by hand), the plaque's code, how many explorers were playing (a number, never who) and when. We add these straight into daily totals for each trail and don't keep the individual events or link them to a person or device.
- The code on a trail plaque when you tap or scan it, so we can open the right trail.
Reviews (optional)
After a walk, the app asks the grown-up "How was it?". If you choose to answer, we receive your star rating, any comment you write, the name you choose to sign it with (for example "Sarah, mum of two"), the ages you choose to share, the trail or story and the date. The app also sends a random code created when it was installed. We scramble (hash) it before storing it, and use it only to make sure each phone leaves one review per trail, so a second review replaces the first.
Every review is checked before it appears, by us or by the partner organisation that runs the trail. Published reviews are public: they appear in the app and on our website with the name and ages you chose, and the partner may reply publicly. Please don't include children's full names or anything that could identify someone.
Signing in (optional)
You can use Clever Cookie Studios without an account by choosing to look around first. If you sign in with Google, Google shares your name, email address and profile picture link with us. We store these with a record of your sign-in sessions, including the IP address and a description of the device or browser used, so we can keep you signed in and keep accounts secure. We don't use your account for marketing. Google's own privacy policy covers what Google does.
Maps
The app's map loads map pictures from OpenFreeMap. Like any website, it sees your IP address and which part of the map is on screen. Your exact location is shown on your phone but isn't sent to it or to us.
Permissions the app asks for
Your phone asks before Clever Cookie Studios can use any of these, and you can change your answer at any time in your phone's settings.
- Location: to tell how far you've walked and when you've reached the next stop. If you allow it, the story keeps going while the phone is in your pocket. Location is only used during a story and on the map, and never leaves your phone.
- Camera: to take scrapbook pictures, which stay on your phone, and to scan the QR code on trail plaques.
- Microphone: to measure how loudly explorers roar in noise games. Sound is measured on the phone and never sent to us.
- Motion: for tilt and shake games.
- NFC: to read the tag in a trail plaque.
- Face ID, Touch ID or your phone's passcode: for the grown-up check. This is handled entirely by your phone and we never receive it.
Children's privacy
Clever Cookie Studios is made for families with children of around 2 to 10, and we've designed it with the ICO's Age Appropriate Design Code (the Children's Code) in mind.
- Children don't give us personal data. Explorer profiles, pictures and progress are kept on the phone.
- A grown-up check (Face ID, Touch ID, the phone's passcode, or a sum young children can't answer) is needed before leaving a story or opening grown-ups' settings.
- Signing in, reviews and our website forms are for grown-ups only.
- Privacy is high by default: no adverts, no chat or social features, no third-party analytics or tracking, no profiling, and location stays on the phone.
- We never sell children's data or share it for marketing.
If you think a child has sent us personal information, for example in a review, email hello@clevercookiestudios.com and we'll delete it.
Visiting our website
- We don't use analytics, advertising or tracking cookies, and there are no third-party trackers on our pages. Our fonts are served from our own site.
- Trails you save are kept in your browser's local storage, on your device. They're never sent to us, and you can clear them in your browser settings.
- Our hosting provider, Cloudflare, keeps short-lived technical logs (such as the page requested, the time, your IP address and browser type) to keep the site secure and help us fix problems.
- If a page shows an interactive map, the map pictures come from our map provider, which sees your IP address.
Joining the waitlist or getting in touch
Launch waitlist
When you join the waitlist, we keep your email address, your name and area if you give them, the page you signed up on, and the fact that you agreed to hear from us. We'll email you when Clever Cookie Studios launches and, if you shared your area, when a trail opens near you. You can unsubscribe at any time by replying to any email or writing to us.
Partner enquiries
If you ask about bringing Clever Cookie Studios to your site, we keep your name, work email, phone number if given, organisation, role, the details you share about the site and your message. We use them to reply and talk about working together, and our team is notified by email. We'll only send you occasional news if you tick the box to ask for it, and you can stop it at any time.
Keeping forms free of spam
To stop the forms being misused, we store a scrambled (hashed) version of your IP address combined with the date, which lets us limit repeated submissions without keeping the address itself.
If you email us directly, we keep the email and our reply so we can help you.
Partner teams using Clever Trails Studio
Clever Trails Studio is where partner organisations create and run their trails. For people who use it, we keep:
- Your name, work email address, the organisations you belong to and your role in each, and who invited you.
- Sign-in details: your passkeys (we store only the public part; the private key never leaves your device), two-factor settings and backup codes if you turn them on, one-time sign-in links (which expire after 15 minutes), and your sign-in sessions, including IP address and browser.
- An activity log of changes made in Studio, recording who did what, when, and from which IP address, so teams can see what changed and we can investigate misuse.
- What you create: stories, trails, pictures, recordings, printed materials and replies to reviews. Replies appear publicly next to the review.
We use this to provide Studio under our agreement with your organisation, and to keep accounts secure. Studio's writing help and narration tools send the text you're working on to our AI providers, so please don't include personal information in story scripts or prompts.
Why we use personal data, and our lawful basis
UK data protection law asks us to explain the legal reason for each use.
- Providing the app, website and accounts you sign in to: to perform our agreement with you (our terms of use).
- Anonymous trail statistics, keeping services secure, preventing spam and fixing faults: our legitimate interests in running a safe, reliable service and helping partners understand how trails are used. Nothing in these uses identifies children.
- Reviews: your consent. You can ask us to remove your review at any time.
- Waitlist emails and partner news: your consent, which you can withdraw at any time.
- Replying to partner enquiries: our legitimate interests, and taking steps at your request before entering into an agreement.
- Studio accounts and the activity log: to perform our agreement with your organisation, and our legitimate interests in security and accountability.
- Keeping records we're required to keep, and responding to lawful requests: legal obligation.
Where data is stored
Some of our providers, including Cloudflare, Google, Anthropic and ElevenLabs, may process data outside the UK, for example in the United States or the European Union. When that happens we make sure it is protected, using UK adequacy regulations (including the UK-US data bridge) or the UK's approved contract terms for international transfers.
How long we keep it
- Data on your phone: until you delete it in the app or delete the app.
- Anonymous daily trail totals: these don't identify anyone, so we may keep them.
- Sign-in accounts: while your account is open. If an account hasn't been used for two years we'll delete it. Each sign-in session expires after 30 days.
- Reviews: while published. Reviews that aren't published, and published reviews when their trail is withdrawn, are deleted after 12 months. We'll remove yours sooner if you ask.
- Waitlist: until 12 months after Clever Cookie Studios launches in your area, or until you unsubscribe, whichever comes first.
- Partner enquiries and emails to us: two years after we last heard from you. If your organisation becomes a partner, we keep them for the length of the partnership and six years afterwards, as business records.
- Scrambled IP addresses used against spam: 30 days.
- Studio accounts: while you have access, and 12 months afterwards.
- Studio activity log: two years, with IP addresses removed after 12 months.
- Error reports and technical logs: error reports are kept for 90 days, and Cloudflare's technical logs for a few days.
Keeping it safe
All data is encrypted as it travels between your device and our servers. Studio uses passkeys and optional two-factor sign-in, access is limited to people who need it, and identifiers such as install codes and IP addresses are scrambled before they're stored wherever we can. No system is perfectly secure, but if something ever went wrong we would tell you and the ICO when the law requires it.
Your rights
Under UK data protection law you can ask us to:
- give you a copy of the personal data we hold about you;
- correct anything that's wrong;
- delete your data;
- restrict how we use it, or object to a use based on our legitimate interests;
- give you your data in a format you can take elsewhere;
- stop using data we hold with your consent (this doesn't affect what we did before).
Email hello@clevercookiestudios.com to make a request. It's free, and we'll reply within one month. We may need to check who you are first. Because we don't hold explorer profiles, pictures or progress, you can manage those directly in the app. For a review, tell us the trail, date and name you signed it with so we can find it.
Children have the same rights over their own data, and a parent or carer can make a request on their behalf. We don't make decisions about anyone by purely automated means that have legal or similarly significant effects. Reviews containing certain words are held back automatically until a person checks them.
Complaints
If you're unhappy with how we've handled your data, please tell us first at hello@clevercookiestudios.com so we can put it right. You can also complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or by calling 0303 123 1113.
Changes to this notice
We'll update this notice when Clever Cookie Studios changes, and change the date at the top. If a change affects how we use your data in an important way, we'll tell you in the app or by email before it takes effect.
Contact us
Email hello@clevercookiestudios.com, or write to [Company legal name], [Registered address].