Privacy Policy

Last updated: 22 March 2026

8gent Jr is an AAC (Augmentative and Alternative Communication) app for children. We handle sensitive data, and we take that seriously. This policy explains exactly what we collect, why, and what control you have. No legal fog.

1. Who is responsible for your data

The data controller is 8gent, operated by James Spalding, based in Ireland.

Company8gent
Contactprivacy@8gent.app
JurisdictionIreland (EU/EEA)
Supervisory authorityIrish Data Protection Commission (DPC)

2. What data we collect

We only collect data that is necessary for the app to work and improve. Here is the complete list:

Communication data

  • Which AAC cards your child taps and in what order
  • Sentences built from card sequences
  • Frequency of card usage (to surface favourites)
  • Custom cards or symbols you create

Voice preferences

  • Selected voice type and speed
  • Volume and pitch settings
  • Language / locale preferences

Personalisation profile

  • Display name and avatar choice
  • Board layout and colour preferences
  • Accessibility settings (e.g. switch access, dwell time)
  • Favourite categories and recently used cards

Game and activity data

  • Scores and progress in learning games
  • Time spent in different activities
  • Skill level progression

Device and technical data

  • Device type and screen size (for layout)
  • Browser or OS version
  • Crash reports and error logs
  • Session timestamps
We do not collect: real names (unless you choose to enter one), photos, location data, contacts, microphone recordings, or any biometric data.

3. Why we collect it

To make AAC communication work

Card usage data powers the prediction engine that suggests the next likely card, reducing the number of taps your child needs to communicate.

To personalise the experience

Favourite cards, layout preferences, and voice settings are stored so the app feels familiar every time your child opens it.

To track learning progress

Game scores and activity data help you (the parent) and any therapists see how your child is progressing.

To fix bugs and improve the app

Crash reports and session data help us find and fix problems. We use aggregated, anonymised data to improve features.

4. Legal basis under GDPR

Under Irish and EU law, we need a legal reason to process personal data. Here are ours:

Parental consent (Article 6(1)(a) + Article 8)

All data relating to your child. In Ireland, the digital age of consent is 16, so we require verifiable parental or guardian consent before any child under 16 can use the app.

Explicit consent for special category data (Article 9(2)(a))

Health and disability-related data. See Section 5 below.

Legitimate interest (Article 6(1)(f))

Crash reports and anonymised usage analytics, where needed to keep the app stable and secure. We have conducted a Legitimate Interest Assessment (LIA) and concluded that these interests do not override the rights of the child.

Legal obligation (Article 6(1)(c))

We retain consent records for 7 years as required for regulatory compliance.

5. Health and disability data (Article 9)

Because 8gent Jr is an AAC app designed for children with communication disabilities (including autism, apraxia, and other conditions), some of the data we process qualifies as special category data under Article 9 of the GDPR. This includes:

  • The fact that your child uses an AAC app (which implies a communication disability)
  • Accessibility settings that indicate specific needs (e.g. switch access for motor difficulties)
  • Communication patterns that may relate to specific conditions
We process this data only with your explicit consent, given during the parental consent flow when you set up the app. You can withdraw this consent at any time (see Section 9).

6. Who has access to the data

You (parent/guardian)Full access. You can view, export, and delete all data at any time.
Your childUses the app. Cannot access raw data or admin settings.
8gent teamAccess only for technical support, bug fixing, or legal obligation. Access is logged.
Third-party advertisersNone. Zero. We do not sell, share, or trade data with advertisers.
Third-party analyticsNone. We do not use Google Analytics, Facebook Pixel, or any third-party tracking.
Sub-processorsHosting infrastructure only (Vercel for web hosting, Convex for database). Both are GDPR-compliant with DPAs in place.

We will never sell your child's data. We will never use it for advertising. We will never share it with anyone who does not strictly need it to keep the app running.

7. How long we keep it

Data typeRetention periodWhy
Session data (timestamps, device info)90 daysBug fixing and stability monitoring
Communication patternsUntil you request deletionPowers the prediction engine your child relies on
Personalisation profileUntil you request deletionKeeps the app familiar for your child
Game progressUntil you request deletionTracks learning over time
Consent records7 years after consent givenLegal/regulatory requirement
Crash reports30 daysDebugging only

When you delete your account, all data except consent records is permanently deleted within 30 days. Consent records are retained for the legally required period, then deleted.

8. Your rights (and your child's rights)

Under GDPR, you and your child have the following rights. As parent or guardian, you exercise these rights on your child's behalf until they reach 16:

Right of access— Request a copy of all data we hold about your child.
Right to rectification— Correct any inaccurate data.
Right to erasure— Request we delete all data. We will do so within 30 days.
Right to data portability— Receive your child's data in a standard, machine-readable format.
Right to restrict processing— Ask us to stop processing while a complaint is being resolved.
Right to object— Object to processing based on legitimate interest.
Right to withdraw consent— Withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, email privacy@8gent.app or use the Parent Admin panel in the app. We will respond within 30 days.

9. How to delete data

You have two options:

Option A: In the app

Open the Parent Admin panel (requires your parental PIN) and select "Delete all data". This is immediate and irreversible.

Option B: Email us

Send a request to privacy@8gent.app. We will verify your identity and delete data within 30 days.

10. How to withdraw consent

You can withdraw consent at any time. This will not affect the lawfulness of any processing that happened before you withdrew.

To withdraw consent, use the Parent Admin panel in the app, or email privacy@8gent.app. When you withdraw consent for special category data (health / disability data), we will stop processing that data immediately and delete it within 30 days.

Note: withdrawing consent may mean some personalisation features stop working, as they rely on the data you consented to us processing.

11. Cookies

We use only essential cookies. These are required for the app to function (e.g. keeping you logged in, remembering your parental session). We do not use:

  • Advertising cookies
  • Third-party tracking cookies
  • Analytics cookies
  • Social media cookies

Because we only use strictly necessary cookies, no cookie consent banner is required under the ePrivacy Directive. However, we list them here for transparency.

12. Changes to this policy

If we make material changes to this policy, we will notify you via the app and email (if you have provided one) at least 30 days before the changes take effect. We will ask for fresh consent if any changes affect how we process your child's data.

13. How to complain

If you are unhappy with how we handle your child's data, please contact us first at privacy@8gent.app. We will do our best to resolve the issue.

If you are not satisfied with our response, you have the right to lodge a complaint with the Irish Data Protection Commission:

NameData Protection Commission (DPC)
AddressData Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Phone+353 (0)1 765 0100 / 1800 437 737
Emailinfo@dataprotection.ie
Websitehttps://www.dataprotection.ie