Privacy Policy
Last updated: February 2026
Kite Phone exists because we believe children deserve communication without surveillance. This policy explains what data we collect, why, and how we protect it. We've written it in plain English because privacy shouldn't require a law degree to understand.
1. Who We Are
Data Controller:
Kite Inclusive CIC2b Bassein Park Road
Shepherds Bush
London W12 9RY
United Kingdom
Contact for data requests: info@kitestudios.org
ICO Registration Number: Registration pending
We are a Community Interest Company (CIC) registered in England. One of our services is providing VoIP landline telephone services for children aged 5-12.
2. What Data We Collect
| Data Type | Collected | Purpose | Legal Basis |
|---|---|---|---|
| Parent name | Yes | Account administration, billing | Contract performance |
| Parent email | Yes | Service communications, support | Contract performance |
| Parent phone number | Yes | Account verification, support | Contract performance |
| Billing address | Yes | Hardware delivery, invoicing | Contract performance |
| Bank account details | No* | *Processed by GoCardless, not stored by us | N/A |
| Child's name | Optional | Personalisation (e.g., voicemail greeting) | Consent |
| Child's voice | No | We do not record calls | N/A |
| Call logs | Yes** | Service delivery, troubleshooting | Legitimate interest |
| Website analytics | Yes | Service improvement | Legitimate interest |
*Direct Debit processing: Bank account details (sort code, account number) are handled entirely by GoCardless. We receive only confirmation of payment status, not your bank details. GoCardless is authorised by the Financial Conduct Authority (FCA) and payments are protected by the Direct Debit Guarantee.
**Call logs: Our VoIP provider retains call metadata (numbers dialled, call duration, timestamps) for service delivery and billing. Call content is never recorded or monitored.
3. What We Don't Collect
We do not collect:
- Call recordings or transcripts
- Location data (the phone is stationary; there's nothing to track)
- Browsing history (the phone cannot access the internet)
- Contacts or address books
- Photos, videos, or messages (the phone has no camera or messaging capability)
- Behavioural data, preferences, or profiles on children
- Biometric data of any kind
Why this matters:
Most "safe phone" products monitor children extensively. We took a different approach: build a device that doesn't generate surveillance data in the first place.
4. Children's Data & the Age Appropriate Design Code
Kite Phone is designed for use by children aged 5-12. We comply with the ICO's Age Appropriate Design Code (Children's Code) by:
Data minimisation by design
The phone cannot collect behavioural data, location, or browsing activity because it lacks those capabilities entirely.
No profiling
We do not build profiles on child users or use their data for marketing.
No nudge techniques
The phone has no apps, notifications, or features designed to extend usage.
Parental control without surveillance
Parents control who the child can call via short-dial codes. We don't provide call recording, message monitoring, or location tracking.
High privacy by default
No settings need to be changed to achieve maximum privacy. It's the only mode.
5. How We Use Your Data
Service delivery:
- Processing your order and delivering hardware
- Provisioning your VoIP phone line
- Collecting monthly payments via Direct Debit
- Providing technical support
- Sending service-related emails (outages, billing, contract renewals)
Service improvement:
- Analysing aggregate, anonymised usage patterns (e.g., average call volumes) to improve the service
- Website analytics to understand how visitors find us
We never:
- Sell personal data to third parties
- Share data with advertisers
- Use child data for marketing
- Make automated decisions affecting you or your child
7. Data Retention
| Data Type | Retention Period | Reason |
|---|---|---|
| Account data | Duration of contract + 6 years | Legal/tax obligations |
| Call metadata | 12 months rolling | Troubleshooting, billing queries |
| Payment records | 6 years from transaction | HMRC requirements |
| Direct Debit mandates | Duration of contract + 13 months | GoCardless/Bacs requirements |
| Support correspondence | 3 years from resolution | Service improvement |
| Website analytics | 12 months | Anonymised and aggregated |
After retention periods: Data is securely deleted or anonymised such that it cannot be linked to any individual.
8. Your Rights Under UK GDPR
You have the right to:
To exercise any right: Email privacy@kitestudios.org with your request. We will respond within 30 days.
Complaints: If you're unsatisfied with our response, you may complain to the Information Commissioner's Office (ICO):
- Website: ico.org.uk
- Helpline: 0303 123 1113
10. Security
We protect your data through:
- HTTPS encryption on all web traffic
- Encrypted database storage (Supabase with AES-256)
- Access controls limiting staff access to personal data
- Regular security reviews of third-party processors
- No storage of bank account details on our systems (handled by GoCardless)
VoIP security:
Calls are transmitted using encrypted SIP protocols. Call content is not recorded or stored.
Payment security:
GoCardless is PCI-DSS compliant and authorised by the FCA. Your bank details are encrypted and stored in their secure environment, never on our servers.
11. Direct Debit Guarantee
All Direct Debit payments are protected by the Direct Debit Guarantee, which provides:
- Immediate money-back entitlement from your bank if an error is made
- Advance notice of payment amounts and dates
- Right to cancel the Direct Debit at any time by contacting your bank
Full details: directdebit.co.uk/direct-debit-guarantee
12. Changes to This Policy
We may update this policy to reflect changes in law or our practices. Material changes will be communicated via email to active customers. The "Last Updated" date at the top indicates the most recent revision.
13. Contact Us
Email: info@kitestudios.org
Postal address:
Kite Inclusive CIC2b Bassein Park Road
Shepherds Bush
London W12 9RY