Policies
Age Appropriate Design Code compliance
A standard-by-standard summary of how BoomReader and BoomWriter meet the 15 standards of the ICO Age Appropriate Design Code.
Last updated: October 2025
This document outlines how BoomReader (operated by BoomApps/Squirrel Learning Ltd) and BoomWriter comply with the 15 Standards of the ICO's Age Appropriate Design Code (AADC), based on the publicly available Privacy Policy (last updated October 10th, 2025), and details the actions needed for full compliance.
| AADC Standard | Compliance Status | Evidence from Updated Policy |
|---|---|---|
| 1. Best Interests of the Child | Compliant | The stated purpose is purely educational, and BoomApps commits to putting children's best interests first. |
| 2. Data Protection Impact Assessments (DPIA) | Compliant | DPIA commitment remains via assistance to the School and internal compliance requirements. |
| 3. Age Appropriate Application | Compliant | Compliance is ensured through the School-as-Controller gating model; children cannot create accounts directly. |
| 4. Transparency | Compliant | Achieved by providing two notices: a detailed formal policy and a separate, accessible Child-Friendly Privacy Notice. |
| 5. Detrimental Use of Data | Compliant | The policies commit not to use data detrimentally, commercially, or for direct marketing to children. |
| 6. Policies and Community Standards | Compliant | Public policies (Privacy, T&Cs, Cookies) are in place. |
| 7. Default Settings | Compliant | Policy explicitly confirms: "We adhere to high privacy settings for all children's accounts by default". |
| 8. Data Minimisation | Compliant | Explicit adherence to Data Minimisation, collecting only the "least amount of personal data" required for function. |
| 9. Data Sharing | Compliant | Strong commitment: "We do not routinely share any data we collect". |
| 10. Geolocation | Compliant | Policy states: IP data is gathered only from the website (not the product) and "We do not collect the geographical location of children". |
| 11. Parental Controls | Compliant | Policy confirms: "There is no live parental monitoring". Parents only view logged data shared by the School, removing the need for an in-app monitoring notification. |
| 12. Profiling | Compliant | Policy explicitly states: "We do not link Facebook technologies to children’s accounts and do not use them to target children". This resolves the most significant compliance conflict. |
| 13. Nudge Techniques | Compliant | Policy confirms the reward system (Gems) "do not improperly influence children to compromise their privacy" and are limited to customizing avatars. |
| 14. Connected Toys and Devices | Compliant | Not applicable; the service is a website/app. |
| 15. Online Tools | Compliant | Policy confirms an in-app 'Help' button is available to all users to contact the support desk, fulfilling the requirement for prominent and accessible tools. |