Privacy & Safety
ThinkOtter is an online tutoring service for children, operated by Codelogy Labs Pte Ltd. Because it is built for children, privacy is part of the product, not an afterthought. This policy explains what we collect, why, who we share it with, how long we keep it, and the choices you have as a parent. It covers the ThinkOtter service, both the app where your child learns and our website at www.thinkotter.sg.
Effective date: 29 June 2026 · Version 1.0 · Controller: Codelogy Labs Pte Ltd (UEN 202618954W), Singapore · Governed by Singapore's PDPA.
The short version
- Who operates ThinkOtter?Codelogy Labs Pte Ltd, a company incorporated in Singapore. We are the organisation responsible for your and your child's personal data under Singapore's PDPA.
- Do we sell or rent your child's data?No. Never.
- Do you use my child's answers to train AI?No. We use AI to mark answers and give hints. Your child's answers are used only to support your child's lessons and reports. ThinkOtter does not use your child's answers to train AI models.
- Are there ads or outside links in the learning space?No ads, and no external links inside the lesson.
- Who is in control?You, the parent. You create and own the account, and the reports are written for you.
Who this policy is for, and the parent's role
ThinkOtter accounts are created and owned by a parent or legal guardian. A child does not sign up on their own. By creating an account and letting your child use ThinkOtter, you confirm you are the parent or guardian, you are at least 18, and you consent to us handling your child's personal data as described here. You can withdraw that consent at any time (see section 11).
What personal data we collect
- Account details you give us when you register: the parent's email address, and your child's first name or display name.
- Learning activity your child creates while practising: answers typed, hints received, questions attempted, Pebbles earned, streaks, progress, and the session reports we generate.
- Basic technical information: device and browser type, and sign-in activity, used to run the service and keep the account secure.
We deliberately keep this minimal. We do not ask for your child's full name, school, NRIC/FIN, address, photographs, or location, and we ask you not to enter sensitive personal information into answer fields.
How we use your child's data, and our legal basis
We use the data above only to:
- run each tutoring session and give guiding hints;
- mark answers and build the report you see after every session;
- track Pebbles, streaks and progress on your dashboard;
- keep the account secure and let you sign back in; and
- respond to your requests and contact you about your account.
Our legal basis under the PDPA is your consent as the parent, given when you register and continue to use the service. Where the PDPA allows, we may also rely on deemed consent or a relevant consent exception (for example, to secure the account or comply with the law). We do not use your child's data for advertising, and we do not make decisions producing legal or similarly significant effects about your child by automated means.
Will my child see ads, or be sold anything?
No. There are no third-party ads in the learning space, no purchase prompts shown to your child, and we do not sell or rent personal data to anyone. ThinkOtter is not an open chatbot. The tutor only discusses the passage and the question in front of your child.
How ThinkOtter uses AI (and the training question)
ThinkOtter uses an AI model to mark answers and generate hints and tutoring responses. To do this, the text your child types may be sent to a trusted AI service provider to generate the marking, hint or tutoring response for that session. We take reasonable steps to require our service providers to process personal data only for the purposes we engage them for, and under confidentiality, security and data-protection safeguards. ThinkOtter does not use your child's answers to train AI models.
AI can occasionally produce an answer that is wrong or imperfect. The session reports and model answers are guidance to support learning, not a guarantee of correctness, and are not professional educational advice. A human (you, the parent) reviews progress through the reports.
Who we share data with
We may share personal data with trusted service providers who help us operate ThinkOtter. These include providers for cloud hosting and data storage, AI-assisted marking and hints, payment processing, website and security services, communications, and support or administration. We take reasonable steps to require them to process personal data only for the purposes we engage them for, and to protect it under confidentiality, security and data-protection safeguards. We do not sell or rent personal data.
We may also disclose personal data where required by law, to protect the safety or rights of a child or other person, or in connection with a business transfer, in each case as permitted by the PDPA.
Where your data is stored, and overseas transfers
ThinkOtter's core account and learning records are hosted in Singapore. Some service providers may process or access personal data from outside Singapore, for example to provide AI processing, payment, security, technical support or website services. Where personal data is transferred outside Singapore, we take reasonable steps required under the PDPA to ensure that it receives a standard of protection comparable to the protection under Singapore law.
How long we keep it
We keep personal data only for as long as we need it to provide ThinkOtter and for the purposes set out in this policy, or for as long as the law requires. If your account is closed, or if you ask us to delete personal data and we no longer need it for legal, security, billing or dispute-resolution reasons, we will delete or anonymise it within a reasonable period. We keep basic security logs only for as long as needed to keep the service secure.
How we protect it
We use reasonable security measures appropriate to the sensitivity of children's data, including access controls, encryption in transit, and hosting with reputable providers. No system is perfectly secure, but we work to protect your child's information and we restrict access to those who need it to run the service.
Your rights and choices
As the parent, you may at any time:
- ask to see the personal data we hold about you and your child (access);
- ask us to correct it (correction);
- withdraw your consent and stop further use; and
- ask us to delete your child's information or close the account.
To make a request or ask a privacy question, email our privacy contact at pdpa@thinkotter.sg. We will respond within the timeframe required by the PDPA. Withdrawing consent or deleting data may mean we can no longer provide the service.
Cookies and similar technologies
We use only the cookies and local storage strictly necessary to sign you in, keep your session secure, and remember your preferences. We do not use advertising or third-party tracking cookies. Our website does not currently run analytics.
Data breaches
If a data breach occurs that is likely to result in significant harm to affected individuals, or meets the notification threshold under the PDPA, we will notify the Personal Data Protection Commission (PDPC) and affected individuals as required by law, and take steps to contain and remedy it.
Children's data
ThinkOtter is designed for children and treated with extra care. Accounts are parent-created and parent-owned; we collect only the minimal data in section 3; we show no ads and no purchase prompts to children; and we do not knowingly let a child create an account without a parent. If you believe a child has provided us data without parental consent, contact pdpa@thinkotter.sg and we will take reasonable steps to delete it.
Changes to this policy
If we make material changes, we will update this page, change the version and effective date, and where appropriate notify you by email or in the app.
Governing law and how to reach us
This policy is governed by the laws of Singapore.
- Privacy questions and requests: pdpa@thinkotter.sg
- General enquiries: hello@thinkotter.sg
If you are not satisfied with our response, you may contact the Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.
Operated by Codelogy Labs Pte Ltd (UEN 202618954W), registered office 60 Paya Lebar Road, #06-28, Paya Lebar Square, Singapore 409051.