1. Who is responsible
Cognito Coding (Eris Taylor) is the data controller for Arcadia. Contact for anything on this page, including exercising your rights:
ErisTaylor@cognitocoding.com
[to confirm: business postal address, and ICO registration number if registered]
Arcadia runs on a server Cognito Coding rents and administers directly. It is not a commercial platform and there is no company behind it other than Cognito Coding.
2. What we hold about your child
| What | Detail | Where it lives |
|---|---|---|
| First name and surname initial | Used to know who an account belongs to. We do not need or keep full surnames. | Club login system |
| Club username and password | The password is stored as a one-way hash, not as text. A memorable colour-and-animal phrase is used so it can be remembered without writing it down. | Club login system |
| A club login in email format | Something like name@arcadia.cognitocoding.com. This is an identifier, not a real mailbox — no email can be sent to or from it. | Club login system |
| Two-factor secret | Only if 2FA is set up on the account. | Club login system |
| Age band | Which band your child is in — under 13, 13–15, or 16–17 — so that the right default settings are applied. We do not hold a date of birth. | Club records |
| Minecraft username and account ID | Needed to put your child on a world's whitelist. Comes from their Minecraft account, not from us. | Minecraft world files |
| What they make | Minecraft builds, Scratch projects, Python programs, pixel art, 3D models. | The relevant tool's storage on the server |
| Chat messages | Text posted in club channels. Kept, so that a reported incident can be checked. | Club chat database |
| Live voice | Passes through the server so members can talk. Not recorded and not stored. | Nowhere — it is not retained |
| Technical logs | IP address, times of connection, Minecraft joins and commands. Used for security and to fix faults. | Server logs |
| Consent record | Who gave consent, when, and which optional features they agreed to. | Club records |
| Parent or carer contact details | A name, email and phone number so we can reach you during a session. Held off the Arcadia server, in an encrypted file on Eris's own device. | Not on the club server |
What we deliberately do not hold
- No date of birth — an age band only.
- No home address and no child's phone number.
- No real personal email address for the child.
- No payment or bank details on the server.
- No SEND, EHCP, medical, diagnosis or dietary information on the server. Where an adjustment needs to be recorded at all, it is held off the server, encrypted, and reduced to what is needed to run the session — see section 6.
- No analytics, tracking, advertising, profiling or behavioural data. There are no cookies for tracking, no advertising networks, and nothing that builds a picture of your child.
- No photographs of your child, and no recordings of sessions.
3. Why we hold it, and our lawful basis
| Purpose | Lawful basis (UK GDPR Article 6) |
|---|---|
| Running the club — accounts, worlds, tools, saving your child's work | Contract where there is a paid tuition arrangement with you; otherwise legitimate interests in providing a club place your child has asked for. Parental authorisation is recorded in every case. |
| Applying the right safety defaults (age band) | Legal obligation — data protection law requires us to consider the age of our users. |
| Keeping children safe, including looking into an incident and referring a concern on | Legal obligation. Where a safeguarding record contains health or similar sensitive information, the additional condition is DPA 2018 Schedule 1, Part 2, paragraph 18 — safeguarding of children. |
| Security, logs, backups, keeping the server running | Legitimate interests in protecting the service and the children using it. |
| Optional extras — voice for an under-13, screen sharing, showing your child's work publicly | Consent, given by you and withdrawable at any time with no effect on the rest of their membership. |
Because most members are under 13, we do not rely on a child's own consent as the basis for their membership. A person with parental responsibility authorises the account.
4. Who else can see it
We do not sell, rent or share your child's data for marketing. Nobody gets it for their own purposes. These are the only third parties involved, and each acts only on our instructions:
| Who | What they do | Where |
|---|---|---|
| netcup GmbH | Rents us the physical server Arcadia runs on. They do not use the data. | Nuremberg, Germany (EU) |
| Scaleway SAS | Stores our nightly off-site backup. The backup is encrypted on our server before it is sent, filenames included — Scaleway holds unreadable data and no key. | Paris, France (EU) |
| Cloudflare | Answers "what is the address of arcadia.cognitocoding.com". DNS only — traffic does not pass through them and they see none of the content. | — |
| Microsoft / Mojang | Checks that a Minecraft account is genuine when your child joins a world. This is part of owning Minecraft, not something we add. Your child's Microsoft account is governed by Microsoft's own privacy terms. | — |
| Google Fonts | Our public web pages load two typefaces from Google's font service, which means Google sees the visitor's IP address when a page loads. This affects the public website only — not the club chat, worlds or tools. [to confirm: we intend to self-host these fonts and remove this] | — |
All storage of your child's data is inside the EU or the UK. There is no transfer to the United States or anywhere else requiring extra safeguards.
We will also share information without your consent where we have to in order to protect a child — with children's social care, the police, or a school's designated safeguarding lead. That is set out in the Safeguarding Policy, and it is the one situation where safeguarding takes priority over your preferences.
5. How long we keep it
| What | Kept for |
|---|---|
| Account and login details | While your child is a member, then 12 months in a deactivated state in case they come back, then deleted |
| Their creative work | While a member, then 12 months. Exported and given to you when they leave, on request |
| Minecraft world files | While a member, then archived for 12 months, then deleted |
| Chat messages | 12 months, rolling |
| Minecraft server logs (player names, in-game chat, IP addresses) | 30 days, deleted automatically every night |
| Web server and application logs (including IP addresses) | Capped at 10 MB per service and overwritten as they fill. On a quiet service an entry can persist longer than 30 days, so we say that rather than claim a fixed period |
| Live voice | Not kept at all |
| Backups (on the server) | 14 nights |
| Backups (off-site, encrypted) | 30 nights |
| Consent records | While a member, plus 3 years, as evidence that consent was given |
| Behaviour records | 12 months after leaving |
| Safeguarding records | Until the child's 25th birthday, then securely destroyed. Held off the club server |
Deleting an account does not instantly remove it from backups. It disappears from the on-server backups within 14 nights and from the off-site copies within 30, and cannot be restored after that.
6. SEND information, and why we keep it off the server
Information about a child's disability, diagnosis or health is "special category" data and needs stronger protection. Arcadia's answer is to keep almost none of it, and to keep what little is needed away from the club systems entirely.
- The club server holds no SEND, EHCP, diagnosis, medical or accessibility records. Accounts carry no hidden fields.
- Where knowing something is genuinely necessary to run a session well — for example that a child needs written instructions rather than spoken ones — it is recorded as a practical adjustment, off the server, in an encrypted file only Eris can open, and kept to the minimum.
- We do not ask for or want a copy of an EHCP.
- Membership of Arcadia does not indicate anything about your child's needs, because the club is not exclusively for SEND children.
7. Your rights, and your child's
You can ask us to:
- Show you everything we hold about your child (a subject access request).
- Correct anything wrong.
- Delete it. Children have a particularly strong right to erasure. We will do it unless we are legally required to keep something — realistically only a safeguarding record.
- Stop or limit a particular use, or object to it.
- Hand over their work in a usable form — their Scratch and Python files, and their Minecraft world.
- Withdraw a consent you gave, such as for voice chat or for showing their work.
Requests are free and answered within one month. Ask by emailing ErisTaylor@cognitocoding.com.
The rights belong to the child. Older children can exercise them themselves, and we will judge case by case whether a child understands what they are asking; usually we act on a parent's request, and we will not use a child's request as a way around a parent, or a parent's as a way around a child where doing so would harm them.
There is no automated decision-making and no profiling at Arcadia. Nothing about your child is decided by software.
8. If something goes wrong
If personal data is lost or exposed and there is a risk to anyone, we assess it immediately, tell the ICO within 72 hours where required, and tell you directly and in plain terms where the risk to your child is high. We do not wait to be asked.
9. Complaining
Tell Eris first — ErisTaylor@cognitocoding.com — or use the Complaints Procedure. You also have the right to go straight to the regulator:
Information Commissioner's Office · 0303 123 1113 · ico.org.uk/make-a-complaint
10. Changes
If we change this notice in a way that matters, we will tell parents and carers directly rather than quietly updating the page. The version and date at the top always show what is current.