Last updated: July 2026

1. Who We Are

Locus Thrive is a digital child development platform operated by Newbee Hub. We are the Data Controller for all personal data collected through locusthrive.com.

We are committed to protecting your privacy and handling all personal data — especially data relating to children — with care, transparency, and in full compliance with the General Data Protection Regulation (GDPR) as applied under Irish law, and the Digital Personal Data Protection Act 2023 (DPDPA) for users in India.

2. What Data We Collect

2.1 Parent or Guardian Data

• Full name and email address (required for account registration)
• WhatsApp number (optional, required only for the WhatsApp reminder add-on)
• Payment information (processed by our payment provider; we do not store card details)
• IP address and device/browser information (collected automatically for security and platform improvement)

2.2 Child Data

• Child's name and date of birth
• Developmental screening responses entered by the parent or guardian
• Screening results and programme progress data

We do not collect any data directly from children. All child-related data is entered by a parent or legal guardian.

2.3 Usage Data

• Pages visited, actions taken within the platform, session duration
• Screening completions and programme activity logs

3. Legal Basis for Processing

We process your data on the following legal bases under GDPR Article 6:

• Contract: processing necessary to provide the services you have purchased or registered for
• Consent: for optional features such as WhatsApp reminders and marketing communications
• Legitimate Interests: for platform security, fraud prevention, and service improvement
• Legal Obligation: where required by Irish, EU, or Indian law

For data relating to children, we rely on parental consent provided at account registration. You confirm when registering that you are the parent or legal guardian and have authority to consent on their behalf.

4. Children's Data and GDPR Article 8

Locus Thrive is used by parents to enter data about their children. We treat all child-related data with the highest level of care.

• Accounts may only be created by adults aged 18 and above
• Children do not interact directly with this platform
• Child data is never used for marketing purposes
• Child data is never shared with third parties without explicit parental consent, except as required by law
• Parents may request deletion of all data relating to their child at any time

We are mindful of our obligations under GDPR Article 8, the Irish Data Protection Act 2018, and the DPDPA 2023 (India), including the Data Protection Commission's guidance on children's data.

5. How We Use Your Data

• To create and manage your account
• To deliver screening services and generate your child's results report
• To process payments and manage subscriptions
• To send service-related communications: booking confirmations, session reminders, weekly summaries
• To send WhatsApp reminders where you have opted in
• To share your child's results with a consultant when you actively book a session and give consent
• To improve the platform using anonymised and aggregated usage data

6. Data Sharing

We do not sell your personal data. We share data only in the following circumstances:

• With consultants when you book a session and give explicit consent for your child's results to be shared
• With our payment processor to complete transactions
• With WhatsApp/Meta to deliver automated reminders where you have opted in
• With law enforcement or regulatory bodies where required by law

7. Data Retention

We retain your personal data for as long as your account is active. If you close your account, we will delete your personal data within 30 days, except where legally required to retain records longer (e.g. payment records retained for up to 7 years for tax compliance).

You may request deletion of specific data at any time without closing your account by emailing contact@locusthrive.com.

8. Your Rights Under GDPR

• Right of Access: request a copy of the personal data we hold about you and your child
• Right to Rectification: correct any inaccurate data through your account settings or by contacting us
• Right to Erasure: request deletion of your personal data and your child's data
• Right to Restriction of Processing: ask us to limit how we use your data in certain circumstances
• Right to Data Portability: request your data in a structured, machine-readable format
• Right to Object: object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: withdraw consent at any time without affecting prior processing

To exercise any of these rights, email contact@locusthrive.com. We will respond within 30 days.

9. Cookies

Locus Thrive uses cookies to maintain your session, remember your preferences, and analyse usage.

• Essential cookies: required for the platform to function (login sessions, security)
• Analytics cookies: to understand how the platform is used (anonymised data only)

You can manage cookie preferences through the Cookie Settings option in the platform footer.

10. Data Security

Locus Thrive uses industry-standard security measures including encrypted data transmission (HTTPS), secure data storage, and access controls restricting who can view personal data.

In the event of a personal data breach, we will notify you and the relevant Data Protection Authority within 72 hours as required by GDPR Article 33.

11. International Data Transfers

Your data is stored and processed within the European Economic Area (EEA). If any transfer outside the EEA becomes necessary, we will ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or via a notice on the platform. Continued use of Locus Thrive after changes are published constitutes your acceptance of the updated policy.

13. Complaints

If you have a concern about how we handle your personal data, please contact us first at contact@locusthrive.com and we will do our best to resolve it.

If you are not satisfied with our response, you have the right to lodge a complaint with:

Ireland — Data Protection Commission (DPC):
Website: dataprotection.ie  |  Phone: +353 57 868 4800
Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

India — Data Protection Board of India (DPBI):
As established under the Digital Personal Data Protection Act 2023.