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Quire / Operator documents / English

Age and Children’s Data Policy

Adult-only public waitlist and demo use, and the required institutional authorisation and deployment safeguards before children can use a customer service.

Effective 3 October 2026 · Contact legal@quirelms.com

On this page

  1. Current public service is for adults
  2. Institutional learning is a separate service
  3. Under-13 prerequisites
  4. Jurisdiction-specific responsibilities
  5. Data minimisation, sensitive information and oversight
  6. Parent, guardian and learner requests

Effective date: 3 October 2026.

Current public service is for adults#

Nuits, the Finnish sole proprietorship operated by Bapusaheb Patil, operates Quire. The public waitlist and browser-local demo are intended for people aged 18 or older. Do not sign up a child for the waitlist or put a child's real personal information in the demo. The fictional learners shown there do not demonstrate that any live child onboarding has been approved.

If you are under 18, do not submit your information through these public services; ask an appropriate adult or your institution about an authorised institutional service instead. If we learn that a child's information was supplied to the public waitlist, we will stop using it for waitlist communications and arrange removal, subject only to any legally necessary restricted evidence. A parent, guardian or other person may report it to legal@quirelms.com.

Institutional learning is a separate service#

A future school, employer or other institutional customer is normally the controller of its learner records. It must establish the lawful authority for enrolment, required and optional processing, age information, communications and sharing. Quire's technical capabilities do not verify that authority or replace a child's or guardian's rights. An age threshold is not the sole question: the purpose, country, lawful basis and type of processing all matter.

The product supports tenant-controlled age collection and consent workflows, but age gating is not universally enabled by default. An entered age, guardian email, identity-provider assertion or officer-reviewed evidence is not a guarantee that independent identity verification has occurred. Before any child deployment, the institution and operator must establish the real onboarding, authorisation, settings, privacy notice and handling responsibilities. This page does not represent those prerequisites as already completed for every installation.

Under-13 prerequisites#

Children under 13 may use a customer deployment only after approved institutional onboarding. Before access is enabled, the applicable deployment must have:

  • Verified school or parent/guardian authority appropriate to the jurisdiction and the actual educational purpose.
  • A signed child-data agreement allocating instructions, access, retention, rights handling, security and incident responsibilities without removing statutory operator duties.
  • An institution-specific notice identifying the controller, data categories, uses, recipients and how a parent or learner can exercise rights.
  • No advertising, learner advertising profiles or unrelated commercial use of children's data.
  • AI and third-party sharing disabled until separately assessed and approved for that deployment, with any required parental or institutional authorisation and provider terms.
  • Tested deployment-specific controls for age, optional analytics/communications purposes, integrations and staff access. A settings-screen restriction alone must not be assumed to protect every other consent or access path.

These are conditions of admitting under-13 learners, not evidence that an automated age or parental-consent system currently enforces them across all deployments. If the prerequisites cannot be met, the deployment must not admit those learners.

Jurisdiction-specific responsibilities#

Where US COPPA applies, a school's authorisation on a parent's behalf can be relied on only within the legally permitted educational context, not for unrelated commercial purposes. The operator retains its own COPPA responsibilities; a school agreement does not waive them or create general permission for every integration. Parents must be given applicable notice, access and deletion opportunities, and an appropriate alternative authorisation process where school authority is insufficient. See the FTC's COPPA guidance.

FERPA applicability and school-official disclosures depend on the institution, relationship and permitted purpose. We do not claim FERPA certification or blanket FERPA compliance for the software. The relevant institution must determine its obligations, permitted disclosures and required contractual controls.

Under European data-protection law, national digital-consent thresholds differ, and consent is not the legal basis for every school's educational task. The institution must choose and explain a valid basis and obtain guardian authorisation where required. A universal “13 is old enough” rule is not appropriate. The Finnish Data Protection Ombudsman's children's guidance explains relevant protections. Other local protections and mandatory rights continue to apply.

Data minimisation, sensitive information and oversight#

Collect only age or authorisation evidence necessary for the purpose; do not request full identity documents or sensitive family information by ordinary email without a justified need and suitable channel. Highly sensitive health or biometric data is outside the standard offering unless separately agreed with safeguards. Institutions should explain who can see accessibility preferences or supporting information and avoid recording unnecessary diagnoses.

Teachers and authorised administrators may see learner activity and relevant communications under institutional access rules. Any AI-assisted educational decision requires meaningful human review, and AI use must meet the separate AI Use Disclosure and child deployment approval. Educational risk indicators are not permission to make an unreviewed consequential decision about a child.

Parent, guardian and learner requests#

For the public waitlist or operator correspondence, contact legal@quirelms.com to ask what information we hold, request correction or deletion, withdraw consent where relevant, or raise a concern about a child's use. Identify the interaction and your relationship without sending unnecessary documents; proportionate verification may be required.

For institutional learning records, contact the institution's privacy officer or administrator. We assist the controller under the applicable agreement and do not decide custody, parental access disputes or statutory educational retention ourselves. Consent withdrawal or an erasure request may affect participation where there is no other lawful basis, and necessary academic evidence may be retained where law permits or requires. The institution must explain that outcome rather than promise instant deletion of every shared record. The Privacy Policy explains rights and complaint channels.

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