Our Commitment to Safeguarding and Privacy

Effective date: 10/10/2025

This Privacy and Safeguarding Policy applies to the Pebble mobile application and all associated services, platforms, and features (together, “Pebble”).

Pebble is an educational and wellbeing application designed to help secondary-school students better understand how they learn and to receive personalised, evidence-informed learning support. We take privacy, safeguarding, and data protection seriously, particularly when working with children and individuals who may be vulnerable.

This policy explains how personal data is collected, used, stored, and protected, and how Pebble is designed to support safeguarding and responsible use within schools and educational settings.

1. Who We Are

Pebble is operated by Schologists Magna Ltd, a company registered in England and Wales.

  • Company registration number: 14716296

  • Registered office: 20-22 Wenlock Road, London, N1 7GU, UK

Schologists Magna Ltd acts as a Data Controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

For privacy, safeguarding, or data-protection enquiries, please contact our Data Protection Lead at:
privacy@schologists.co.uk

2. Who Pebble Is For

Pebble is designed for students aged 11 to 18 and is typically accessed through a school, college, or authorised educational organisation.

Pebble may be used by students who experience learning difficulties, special educational needs, or wellbeing challenges. Accordingly, Pebble treats all users as potentially vulnerable by default and applies enhanced safeguarding-level protections across the platform.

Pebble is not a medical device and does not provide medical diagnoses, clinical treatment, or therapeutic interventions.

3. Lawful Basis for Processing Personal Data

Pebble processes personal data only where there is a lawful basis under UK GDPR, including:

  • Public task or legitimate interests, where Pebble is used by schools or educational organisations to support learning, wellbeing, and safeguarding responsibilities

  • Consent, including parental or guardian consent where required for under-18s

  • Research purposes, where data is anonymised or where explicit consent has been obtained

Different categories of personal data may be processed under different lawful bases depending on context and use.

Schools and educational organisations deploying Pebble are responsible for ensuring that appropriate permissions and consents are in place in accordance with their own policies and legal obligations.

4. Personal Data We Collect

Pebble is designed according to strict data-minimisation principles. We collect only the data necessary for the platform to function safely and effectively.

This may include:

  • School-issued user identifiers, year group, and assigned usernames

  • Cognitive assessment responses and task-performance data

  • Learning and interaction data generated within the application

  • Generated feedback, summaries, and reports

  • Technical and operational data such as device type, operating system, and app usage logs

Pebble does not require or request students’ real names, photographs, personal contact details, precise location data, or social-media information.

5. Special Category and Sensitive Data

Pebble may process data relating to learning profiles, cognitive functioning, or wellbeing. Such data is treated as sensitive and subject to enhanced safeguards.

Safeguards include:

  • Data minimisation and purpose limitation

  • Encryption of data in transit and at rest

  • Strict role-based internal access controls

  • Separation of identifying data from assessment or performance data where feasible

Pebble does not collect clinical diagnoses, medical records, therapy notes, or health-service data.

6. How We Use Personal Data

Personal data is used solely for the following purposes:

  • Providing students with age-appropriate, supportive cognitive feedback

  • Generating reports and insights for authorised educators

  • Improving the accuracy, reliability, and quality of Pebble’s assessments and educational features

  • Supporting safeguarding, risk awareness, and responsible platform use

Student data is never used for advertising, behavioural profiling, or commercial marketing purposes.

Pebble does not use tracking technologies for cross-app or cross-service tracking and does not participate in third-party advertising networks.

7. Research and Evaluation Use

Pebble may be used in educational or psychological research contexts.

Where research is conducted:

  • Data is anonymised or pseudonymised wherever possible

  • Ethical approval is obtained where required

  • Participation is voluntary and consent-based

Research data is never used to identify individual students.

8. Data Sharing

Pebble does not sell personal data.

Personal data may be shared only with:

  • The student’s school or authorised educational staff

  • Approved technical and hosting service providers operating under GDPR-compliant data-processing agreements

  • Academic or research partners, where explicit consent and appropriate ethical approval exist

All third-party partners are subject to contractual confidentiality and data-protection obligations.

9. Data Storage and Security

Personal data is stored on secure servers using industry-standard security measures, including:

  • Encryption

  • Secure authentication systems

  • Role-based access controls

  • Regular security reviews and updates

Data is stored within the United Kingdom or in jurisdictions that provide an equivalent level of data protection. Where data is transferred internationally, appropriate safeguards such as adequacy decisions or standard contractual clauses are applied.

10. Data Retention

Personal data is retained only for as long as necessary for its intended purpose.

Typically:

  • Student data is retained while an account remains active through a school or educational organisation

  • Data is deleted or anonymised following the end of a school agreement or on request

  • Fully anonymised research data may be retained for academic or statistical purposes

Schools may request deletion of student data at any time.

11. Rights of Students and Parents

Under UK GDPR, students and their parents or guardians have the right to:

  • Access personal data

  • Request correction of inaccurate data

  • Request deletion

  • Restrict processing

  • Object to certain uses of data

Where a student is deemed capable of exercising their own data-protection rights, requests may be handled directly with the student in accordance with UK GDPR and applicable school policies.

Requests may be made via the school or by contacting privacy@schologists.co.uk.

Individuals also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).

12. Safeguarding by Design

Safeguarding is a core design principle of Pebble.

Safeguarding features include:

  • No open user-to-user messaging or chat

  • No public profiles or social-networking functionality

  • Controlled access via schools or authorised organisations

  • Clear separation between student and staff views

Pebble supports safeguarding practices but does not replace safeguarding responsibilities held by schools or local authorities.

13. Safeguarding Concerns and Escalation

Pebble does not provide real-time monitoring or emergency intervention.

Where patterns of use or generated content may indicate a potential safeguarding concern, relevant indicators may be made available to authorised school staff in line with the school’s safeguarding policies.

All safeguarding decisions and actions remain the responsibility of the school or responsible authority.

14. Children’s Privacy

Pebble complies with UK GDPR, the ICO Children’s Code, and relevant app-store requirements.

We do not knowingly collect personal data from children outside a school-authorised or parent-consented framework. If data is collected in error, it will be deleted promptly.

15. Changes to This Policy

This policy may be updated to reflect changes in law, guidance, or platform functionality.

Material changes will be communicated to schools and reflected within the application.

16. Contact Us

For questions or concerns about privacy or safeguarding, contact:

privacy@schologists.co.uk.

Schologists Magna Ltd
20-22 Wenlock Road, London, N1 7GU.
United Kingdom