Privacy Policy — Optimum

1. Who we are

Optimum and Optimum US (together, "Optimum," "we," "us") are university pathway planning tools. This policy applies to both products, whether accessed via optimum-generic.vercel.app or optimum-us.vercel.app, and to any related mobile or PWA installation.

[Insert incorporated company name, registered address, and company number once incorporation is complete.] is the data controller for the personal data described in this policy — meaning we decide how and why your data is processed, rather than acting only on someone else's instructions.

Questions or requests about your data should go to our dedicated privacy contact: privacy@optimumpathway.co.uk, rather than our general enquiries address.

2. Information we collect

We collect information you provide directly, and some information generated automatically as you use the product.

Category	Examples
Account information	Email address, password (encrypted), account creation date.
Academic profile data	Qualification type (IGCSE, A Level, IBDP, US Diploma), subjects, predicted or current grades, GPA (weighted/unweighted, Optimum US only), super-curricular and co-curricular activities.
Nationality (optional)	Provided only if the student chooses to share it. Used solely to flag likely UK undergraduate fee status (Home vs International) and English-language test requirements (e.g. IELTS) that may apply to specific universities named in a pathway plan. Not required to use the product.
Planning data	Target courses and universities, generated pathway plans, saved "Me Now vs Future Me" comparisons, PDF exports.
Technical data	Device type (mobile or desktop), general usage timestamps, and standard web log data (IP address, browser type).
Payment data	If you subscribe, your payment is processed by Stripe. We do not receive or store your full card details — only a subscription status and a Stripe customer reference.

3. Children and student users

Optimum is designed for use by secondary school students, many of whom are under 18, and some of whom may be under 13. We take the following approach:

We collect the minimum academic data needed to generate a pathway plan, and do not require a student's full name, date of birth, or home address to use the product.
How we determine age: during sign-up, we ask the user to confirm their age band (under 13 / 13–17 / 18 or over) or, for school-provisioned accounts, we rely on the school's own records. We do not run independent age verification (such as ID checks) — the accuracy of this self-declared information is relied upon in good faith, in line with common practice for services of this kind.
How parental consent is obtained: where a student signs up directly and declares themselves under the age required for consent in their country (13 in the US under COPPA; 13 in the UK under UK GDPR, though we recommend parental involvement up to 16), sign-up is blocked until a parent or guardian creates and verifies the account instead, using the parent's own email address. The parent's email receives a consent confirmation link before the child's account becomes active.
Parental access and deletion: a parent or guardian who created or verified a child's account can request a copy of, or the deletion of, that child's data at any time by contacting privacy@optimumpathway.co.uk from the email address used to set up the account. We will verify the requester is the account's registered parent/guardian before acting on the request.
Role of schools: where a school or counsellor sets up accounts on behalf of students (rather than the student or family signing up directly), that school acts as the party responsible for obtaining any parental consent required under local law before student data is entered, and for managing requests from parents about that data in the first instance. Optimum processes that data on the school's instructions in this scenario.
We do not use student academic data for targeted advertising, and do not sell student data to third parties, under any circumstance.

[This section in particular should be finalised with a solicitor, including whether the self-declared age-gate described above meets the bar for "verifiable" parental consent required in your target markets, or whether a stronger verification step is needed before launch.]

4. How we use your information

To generate Forward Planner, Reverse Planner, Dimensions Analysis, and Venn comparison outputs.
To save and retrieve your pathways, Venns, and PDF exports when you choose to save them.
To process payments and manage subscriptions, where applicable.
To maintain and improve the reliability and security of the product.
To respond to support requests.

5. Our legal basis for processing

Where UK/EU data protection law applies, the legal basis we rely on depends on what we're doing with your data:

Processing activity	Legal basis
Creating and running your account, generating pathway plans	Performance of a contract — this is the core service you signed up for.
Processing subscription payments	Performance of a contract, and compliance with legal obligations (e.g. accounting and tax records).
Maintaining security, preventing fraud or misuse, fixing bugs	Legitimate interests — we have a legitimate interest in keeping the product secure and working, balanced against your rights.
Sending optional marketing or product update emails	Consent — you can opt out at any time.
Processing a child's academic data where direct sign-up is used	Consent from a parent or guardian, in addition to performance of a contract.

6. Who we share data with

We share data only with the following categories of third party, each acting as a processor on our behalf:

Supabase — hosts our database and handles authentication and storage of academic profile and pathway data.
Anthropic — processes profile and planning data via API to generate pathway text and "More information" search results. Anthropic processes this data solely to generate your response; under Anthropic's standard commercial API terms, this data is not used to train Anthropic's models. We recommend not entering sensitive information beyond what's needed for a pathway plan (e.g. avoid including health conditions, religious or political views, or similar special-category data in free-text fields) since it isn't necessary for the product to function.
Vercel — hosts the application itself.
Stripe — processes payments, where you choose to subscribe. See Stripe's own privacy policy for how they handle payment data.

We do not sell personal data to any third party, do not share academic data with advertisers, and do not use personal data for cross-context behavioural advertising. This applies regardless of where you are located, including under US state privacy laws (such as the California Consumer Privacy Act) that give residents specific rights around the sale and sharing of personal information.

Legal disclosures: we may disclose personal data where required to do so — for example in response to a valid court order or regulatory request, to establish or defend legal claims, to investigate suspected fraud or misuse of the product, or as part of a merger, acquisition, or sale of some or all of our business (in which case the recipient would be bound by commitments no less protective than this policy).

AI-generated recommendations are advisory only. Pathway plans, Dimensions Analysis outputs, and university recommendations generated by Optimum are intended to support your own research and decision-making. They are not a fully automated decision with legal or similarly significant effect, and should not be treated as a substitute for guidance from a school counsellor, teacher, or official university admissions information.

7. International data transfers

Optimum's database is hosted in Australia (ap-southeast-2). Optimum US's database is hosted in the United States (us-east-1). Anthropic and Stripe may also process data in the United States. If you are located outside these regions — for example, a UK or EU user of Optimum US — your data will be transferred internationally to be stored and processed.

Where we transfer personal data out of the UK or EEA, we rely on recognised safeguards, primarily the UK International Data Transfer Agreement (IDTA) or the EU Standard Contractual Clauses (SCCs) as incorporated into our agreements with Supabase, Anthropic, Vercel, and Stripe, together with an assessment of the data protection standards in the receiving country. A copy of the relevant safeguard can be requested from privacy@optimumpathway.co.uk.

8. How long we keep data

We keep account and academic profile data for as long as your account remains active. If you delete your account, we will delete your personal data within 30 days, except for the categories below, which we retain for longer for legal, accounting, or operational reasons:

Data type	Retention period
Invoices and billing records	6 years, to meet UK tax and accounting obligations.
Standard web server logs	Up to 90 days, then automatically deleted.
Support emails and correspondence	Up to 2 years from the last message, to handle follow-up queries.
Database backups	Rolling backups retained for up to 35 days; deleted account data still present in a backup ages out naturally within this window.

9. Your rights

Depending on where you live, you may have the right to:

Access the personal data we hold about you.
Correct inaccurate data.
Request deletion of your data.
Export your data in a portable format.
Object to or restrict certain processing.
Withdraw consent, where processing is based on consent.

To exercise any of these rights, contact us using the details in Section 13.

If you're in the UK and you're unhappy with how we've handled your personal data, you also have the right to complain to the UK's independent data protection regulator, the Information Commissioner's Office (ICO), at ico.org.uk/make-a-complaint or by calling 0303 123 1113. We'd appreciate the chance to resolve your concern directly first, but you're not required to contact us before raising it with the ICO.

10. Cookies

Optimum uses only the essential cookies and local/session storage needed to run the product. We do not currently use advertising or third-party tracking cookies.

Name / type	Purpose	Duration
Supabase auth session token	Keeps you signed in between visits.	Until sign-out or expiry (typically up to 1 week).
Local storage — in-progress plan data	Remembers unsaved Forward/Reverse Planner inputs if you navigate away mid-session.	Until cleared or overwritten.
Vercel/CDN functional cookie	Basic routing and load-balancing for the hosting platform.	Session.

Because these are strictly necessary to provide the service you've asked for, they don't currently require a cookie consent banner under UK PECR — but if we introduce analytics or marketing cookies in future, we'll add a consent mechanism and update this section first.

11. Security

We use industry-standard measures to protect your data, including encrypted connections (HTTPS), row-level security on our database tables, and encrypted password storage. No system is completely secure, and we encourage you to use a strong, unique password.

12. Changes to this policy

We may update this policy from time to time. If we make material changes, we will notify active users by email or in-product notice before the changes take effect.

13. Contact us

For any questions about this policy, or to exercise any of the rights described above, contact our dedicated privacy address: privacy@optimumpathway.co.uk. For general enquiries unrelated to privacy, use contact@optimumpathway.co.uk.