PRIVACY POLICY

Last updated: June 2026

Who we are

Empathia is a product of Elygra Ltd, a company registered in England and Wales.

Company registration number: 04640811 Registered address: Elygra Marketing Services Units 11-13 The Quad, Sovereign Way, Sealand Rd, Chester CH1 4QP. Contact: [email protected]

Elygra Ltd is the data controller for all personal data collected through the Empathia platform.

What this policy covers

This policy explains what personal data we collect when you use the Empathia platform at portal.elygra-empathia.org, how we use it, who we share it with, and what your rights are.

We are committed to handling personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and — where children are involved — the ICO's Age-Appropriate Design Code (Children's Code).

What data we collect and why

When you register for an account We collect your name and email address. We use this to create and manage your account and to send you essential platform communications. Our legal basis is contract — this data is necessary to provide you with access to the platform.

When you use the platform We collect usage data — which content you access, when, and for how long. We use this to improve the platform and to provide schools with evidence of staff engagement with development content. Our legal basis is legitimate interests.

When you contact us We collect the information you choose to share with us. We use this to respond to your enquiry. Our legal basis is legitimate interests.

We do not collect sensitive personal data. We do not build individual profiles of children. We do not use personal data for advertising or marketing to third parties.

Children's data

Empathia's children's stories are designed to be watched by children, but children do not register for accounts or submit personal data directly through the platform. Access is managed by schools, teachers, or parents.

Where schools use Empathia content with individual children — for example, in a personalised social story — any personally identifying information (such as a child's name or safe person) is added locally by the school and is not transmitted to or stored by Elygra Ltd.

We have designed the platform in accordance with the ICO's Age-Appropriate Design Code and apply its fifteen standards to all aspects of our service that may be accessed by or relate to children under 18.

Who we share data with

We use the following third-party processors to operate the platform:

Go High Level — our platform and membership system provider. Your account data is stored and managed through Go High Level.

We do not sell personal data. We do not share personal data with third parties for marketing purposes.

We may disclose personal data if required to do so by law, or to protect the rights, property, or safety of Elygra Ltd, our users, or others.

Data retention

We retain account data for as long as your account is active. If you close your account, we will delete your personal data within 7 days, except where we are required to retain it for legal or regulatory reasons.

Usage data is retained for 3 months and then anonymised.

Your rights

Under UK GDPR you have the right to:

• Access the personal data we hold about you

• Correct inaccurate data

• Request deletion of your data

• Object to processing based on legitimate interests

• Request restriction of processing

• Data portability

• Withdraw consent where processing is based on consent

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

If you are not satisfied with our response, you have the right to complain to the Information Commissioner's Office at ico.org.uk.

Cookies

The Empathia platform uses essential cookies to manage your login session. We do not use advertising cookies or third-party tracking cookies.

Changes to this policy

We may update this policy from time to time. We will notify registered users of significant changes by email. The current version will always be available at this address.

Contact

For any questions about this privacy policy or how we handle your data: [email protected]

Every child,

understood

Bring Empathia to your school

Elygra Empathia 2026