Privacy Policy

1. Introduction

This Privacy Policy explains how Challenger (Financial Literacy) Limited (“we”, “us”, or “our”) collects, uses, and protects your personal information when you use our financial literacy quiz web application (the “Service”). We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

By using our Service, you agree to the collection and use of information in accordance with this policy.

2. Data Controller

The data controller responsible for your personal information is:

3. Information We Collect

We collect the following types of information:

3.1 Information You Provide

• Account Information: Name, email address, and password when you create an account
• Quiz Responses: Your answers to financial literacy quiz questions
• User-Generated Content: Any custom quiz questions or content you create using our Service
• Communications: Information you provide when contacting our support team

3.2 Automatically Collected Information

• Usage Data: Quiz performance metrics, completion rates, scores, and learning progress
• Device Information: IP address, browser type, operating system, and device identifiers
• Log Data: Access times, pages viewed, and referring URLs
• Cookies and Similar Technologies: Data collected through cookies and similar tracking technologies (see Section 9)

4. How We Use Your Information

We process your personal information for the following purposes under the legal bases specified:

4.1 Service Provision (Legal Basis: Contract Performance)

• Creating and managing your account
• Generating personalised financial literacy quizzes using OpenAI technology
• Tracking your progress and providing learning recommendations
• Storing your quiz history and performance data

4.2 Service Improvement (Legal Basis: Legitimate Interests)

• Analysing usage patterns to improve quiz quality and user experience
• Developing new features and educational content
• Conducting research and analytics on learning effectiveness

4.3 Communication (Legal Basis: Contract Performance & Legitimate Interests)

• Sending service-related notifications and updates
• Responding to your enquiries and support requests
• Sending educational content and tips (with your consent where required)

4.4 Legal Compliance (Legal Basis: Legal Obligation)

• Complying with applicable laws and regulations
• Responding to legal requests and preventing fraud

5. Third-Party Service Providers

5.1 OpenAI Integration

Our Service uses OpenAI’s application programming interface (API) to generate quiz questions and educational content. When you use our quiz features, certain information may be processed by OpenAI:

• Quiz topics and parameters you select
• Content you provide when creating custom quizzes
• Technical data required for API functionality

Important: We do not share your personal identification information (such as name or email address) or your quiz performance data with OpenAI. OpenAI processes only the information necessary to generate quiz content. OpenAI’s data processing practices are governed by their Business Terms of Use and Privacy Policy, available at https://openai.com/policies.

5.2 Other Service Providers

We may share your information with other trusted third-party service providers who assist us in operating our Service:

• Hosting Providers: To store and maintain our application and databases
• Analytics Services: To understand how users interact with our Service
• Email Service Providers: To send service communications
• Payment Processors: To handle subscription payments (if applicable)

All service providers are contractually obligated to protect your data and use it only for the purposes we specify.

6. International Data Transfers

Some of our service providers, including OpenAI, are located outside the United Kingdom and European Economic Area (EEA). When we transfer your personal data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the UK Information Commissioner’s Office (ICO)
• Adequacy decisions recognising equivalent data protection standards
• Other legally approved transfer mechanisms

OpenAI is based in the United States. Data processed by OpenAI is subject to appropriate safeguards under their data protection agreements and compliance frameworks.

7. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy:

• Account Information: Retained whilst your account is active and for 12 months after account closure
• Quiz Data and Performance: Retained whilst your account is active and for 12 months after account closure
• Usage and Analytics Data: Typically retained for 24 months in anonymised form
• Legal and Compliance Records: Retained as required by applicable law

After the retention period, we securely delete or anonymise your personal information.

8. Your Data Protection Rights

Under UK GDPR, you have the following rights regarding your personal information:

• Right of Access: Request a copy of the personal information we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete information
• Right to Erasure: Request deletion of your personal information in certain circumstances
• Right to Restrict Processing: Request limitation of how we use your information
• Right to Data Portability: Receive your data in a structured, commonly used format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent for processing based on consent at any time

To exercise any of these rights, please contact us at:

We will respond to your request within one month. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe we have not handled your data appropriately. Visit www.ico.org.uk for more information.

9. Cookies and Tracking Technologies

Our Service uses cookies and similar tracking technologies to enhance your experience:

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Service to function (e.g., authentication, security)
• Performance Cookies: Help us understand how users interact with our Service
• Functional Cookies: Remember your preferences and settings
• Analytics Cookies: Collect information about Service usage and performance

9.2 Managing Cookies

You can control cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our Service. For more information about managing cookies, visit www.aboutcookies.org.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal information, including:

• Encryption of data in transit and at rest using industry-standard protocols
• Regular security assessments and vulnerability testing
• Access controls limiting data access to authorised personnel only
• Secure authentication mechanisms including password protection
• Regular backups and disaster recovery procedures

Whilst we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.

11. Children’s Privacy

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately, and we will take steps to remove that information.

For users aged 13-16, we recommend parental or guardian supervision when using our Service.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by:

• Posting the updated policy on our Service with a new “Last Updated” date
• Sending an email notification to your registered email address (for significant changes)

Your continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

14. Regulatory Information

Information Commissioner’s Office (ICO)

ICO Registration Number: ZC028212

You have the right to lodge a complaint with the ICO if you are unhappy with how we handle your data. Visit www.ico.org.uk or call 0303 123 1113.

Acceptance of This Policy

By using our Service, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.

Last Updated: