1. Introduction

This Privacy Policy explains how Urban Mechanics LTD (company number 10959925), trading as KidsHustle, collects, uses, stores, and shares your personal data when you use our Platform. Our registered address is 55 King William Street, London, EC4R 9AD. You can contact us at [email protected].

KidsHustle is specifically designed for young people aged 13 to 17 and their parents or guardians. We take the protection of children's personal data extremely seriously and have designed our systems with privacy and safety as core principles.

2. Personal Data We Collect

2.1 Information You Provide at Registration

When you create an account, we collect:

• Display name
• Email address
• Date of birth (to verify age eligibility)
• Password (stored in a securely hashed format; we never store plaintext passwords)
• Authentication provider details (Google ID or Apple ID, if applicable)
• User type (Teen or Parent)

2.2 Identity Verification (Parent Users Only)

Parent Users are required to verify their identity through our payment partner's identity verification service. This involves submitting a government-issued identity document. We do not store or have access to images of your identity document — our payment partner processes this and we receive only your verified legal name.

2.3 Payment and Financial Information

Payment processing is handled entirely by Stripe. We store only the identifiers necessary to manage your relationship with the payment system (such as customer and account reference numbers). We do not store card numbers, bank account numbers, or other financial credentials.

2.4 Family Data

When a Teen User joins a Family, we store the family identifier, parent user identifier, teen user identifiers, the Family Join Code, and job application records associated with the Family.

2.5 Location Data

When a Teen User begins an active job, we collect precise GPS real-time location data. This data is:

• Visible only to the Teen User's parent or guardian within their Family;
• Used to power a geofencing system that alerts the parent if the Teen leaves a defined radius around the job location;
• Retained for 21 days after the job is marked as complete; and
• Permanently deleted after the 21-day retention period.

No other users, including Job Owners, can access a Teen User's location data.

2.6 Content and Communications

We collect and store job listings, job applications, reviews and ratings, profile pictures, in-app chat messages between Teen Users and Job Owners, and reports and support communications.

2.7 Automated Data Collection

We use product analytics services for session recordings, event logging, and feature management. Session recordings are used exclusively for debugging and quality assurance. Sensitive text input and images are automatically redacted from session recordings.

3. How We Use Your Data

3.1 Core Platform Operations

We use your data to create and manage your account, verify your identity (Parent Users), facilitate jobs, process payments, enable messaging, provide real-time location tracking to parents, and display your profile to other users where appropriate.

3.2 Safety and Moderation

We use your data to moderate job listings using AI-powered content analysis, scan all uploaded images for inappropriate content, filter chat messages through automated moderation, investigate reports and complaints, resolve disputes, and detect and prevent fraud.

3.3 Analytics and Improvement

We use analytics to understand how users interact with the Platform, identify and fix bugs, manage feature rollouts, and improve the overall user experience. We do not sell, rent, or share analytical data with any third party for advertising or marketing purposes.

4. Lawful Basis for Processing

Contract (Article 6(1)(b))

Processing your account data, payment information, job data, and communications is necessary for the performance of our contract with you. For Teen Users, we additionally rely on legitimate interests given the limitations of contracting with minors.

Legitimate Interests (Article 6(1)(f))

We rely on legitimate interests for safety and moderation activities, analytics and product improvement, fraud prevention, and location tracking during jobs. We have conducted a Legitimate Interests Assessment for each of these purposes.

Legal Obligation (Article 6(1)(c))

We may process data where required by law, such as for tax reporting, fraud prevention, safeguarding obligations, or to respond to valid legal requests from authorities.

Consent

Where we rely on consent, we will ask for it separately and clearly. Consent can be withdrawn at any time by contacting [email protected].

5. Data Sharing and Third Parties

We share personal data with carefully selected third-party service providers who act as data processors on our behalf. These include payment processing and identity verification (Stripe), cloud infrastructure (EU-based), AI-powered content moderation, image moderation, messaging infrastructure, product analytics, transactional email delivery, and push notification services.

A full, up-to-date list of our sub-processors is maintained at kidshustle.app/sub-processors. We do not sell your personal data to any third party and do not share it with advertisers.

6. International Data Transfers

Our servers are located in the European Union. Where data is transferred outside the UK and EU, we ensure appropriate safeguards are in place, including the UK International Data Transfer Agreement (IDTA), Standard Contractual Clauses (SCCs), or approved certification mechanisms.

7. Data Retention

• Account data: Retained for the duration of your account, plus 30 days after deletion.
• Location data: Deleted 21 days after the associated job is marked as complete.
• Chat messages: Retained for the duration of the job and a reasonable period thereafter.
• Job records and payment history: Retained for 6 years after the end of the relevant tax year (HMRC requirements).
• Session recordings and analytics: Retained for up to 12 months.
• Identity verification records: Managed by our payment partner in accordance with their policy.

8. Your Rights Under UK GDPR

You have the right of access, rectification, erasure, restriction of processing, data portability, and to object to processing based on legitimate interests. You also have rights related to automated decision-making. To exercise any of these rights, contact us at [email protected]. We will respond within one month.

9. Children's Privacy

KidsHustle is specifically designed for users aged 13 and over. In accordance with the ICO's Age Appropriate Design Code, we have implemented: high privacy by default, data minimisation, parental oversight, no behavioural advertising, no nudge techniques, and clear age-appropriate language throughout.

10. Cookies and Similar Technologies

The Platform uses essential cookies and similar technologies necessary for operation, including authentication tokens and session management. We also use analytics services that may use similar technologies on the basis of our legitimate interest in maintaining and improving the Platform. We do not use advertising cookies or tracking technologies.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or in-app notification at least 14 days before the changes take effect.

12. Complaints

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO). We would, however, appreciate the opportunity to address your concerns first at [email protected].

13. Contact Us

1. Introduction and Acceptance

These Terms of Service ("Terms") govern your access to and use of the KidsHustle platform ("Platform"), operated by Urban Mechanics LTD, a company registered in England and Wales (company number 10959925), with a registered address at 55 King William Street, London, EC4R 9AD.

KidsHustle is a freelancing platform designed exclusively for young people aged 13 to 17 ("Teen Users") in the United Kingdom, connecting them with parents and guardians ("Parent Users") and local job opportunities.

By creating an account or using the Platform, you confirm that you have read, understood, and agree to be bound by these Terms. If you are a Teen User, your parent or guardian must also create an account and approve your use of the Platform. If you do not agree to these Terms, you must not use the Platform.

2. Definitions

• Platform: The KidsHustle mobile application, website, APIs, and all related services.
• Teen User: A registered user aged 13 to 17 who performs jobs posted on the Platform.
• Parent User: A registered user who is the parent or legal guardian of one or more Teen Users, or a Job Owner who posts jobs on the Platform.
• Family: A linked group consisting of one Parent User and one or more Teen Users, joined via a unique Family Join Code.
• Job: A task posted by a Parent User (Job Owner) for a Teen User to complete in person.
• Escrow: The system by which job payments are held by the Platform until job completion or resolution.
• Cooldown Period: The 14-day waiting period after funds are deposited before a Teen User can initiate a payout.
• Content: Any text, images, reviews, messages, profile information, or other material uploaded through the Platform.

3. Eligibility and Account Registration

3.1 Age Requirements

• Teen Users must be aged 13 to 17 at the time of registration.
• Parent Users must be aged 18 or over and must be the legal parent or guardian of any Teen User they add to their Family.
• Users outside the United Kingdom may not use the Platform.

3.2 Account Creation

To use the Platform, you must create an account with accurate and complete information. You may register via email, Google, or Apple. Parent Users are required to complete identity verification through our payment partner before they can post jobs or manage payments.

3.3 Family Structure

Teen Users must join a Family by entering a Family Join Code provided by their parent or guardian. By joining, the parent or guardian confirms they consent to the Teen User's use of the Platform, have read and agree to these Terms on behalf of the Teen User, accept responsibility for overseeing the Teen User's activity, and consent to the processing of the Teen User's personal data as described in our Privacy Policy.

3.4 Account Security

You are responsible for maintaining the confidentiality of your account credentials and for all activity that occurs under your account. Notify us immediately at [email protected] if you suspect unauthorised access.

4. How the Platform Works

4.1 Job Posting

Parent Users (Job Owners) may post in-person job opportunities on the Platform. All jobs must be for legitimate, lawful tasks suitable for young people aged 13 to 17 and must comply with UK child employment laws.

4.2 Job Application and Approval

When a Teen User wishes to apply for a job, the application is first sent to their parent or guardian for approval. If the parent approves, the application is submitted to the Job Owner, who may then accept or decline it.

4.3 Payments and Escrow

When a job is accepted, the Job Owner's payment method is charged the job amount plus a 12.5% platform service fee. The job amount is held in escrow by the Platform. Once released, funds are deposited to the Teen User's connected payment account. A 14-day cooldown period applies before the Teen User can initiate a payout to their linked bank account.

4.4 Messaging

In-app messaging between a Teen User and a Job Owner is available only in the context of an active job. The Teen User's parent or guardian has full visibility of all messages. Messaging is subject to automated moderation.

4.5 Location Tracking

When a Teen User starts an active job, real-time location tracking is enabled. Only the Teen User's parent or guardian within their Family can view this location. A geofencing system alerts the parent if the Teen leaves a defined radius around the job location.

4.6 Dispute Resolution

If a Job Owner declines the result of a completed job and the Teen User escalates the dispute, the matter is first reviewed by our automated dispute resolution system. If unsatisfied, either party may request human review.

5. User Conduct

5.1 General Obligations

All users agree to provide accurate and truthful information, use the Platform only for its intended purpose, treat all other users with respect and courtesy, comply with all applicable UK laws and regulations, and not attempt to circumvent any safety or security features.

5.2 Prohibited Conduct

The following conduct is strictly prohibited:

• Creating a false or misleading account, including misrepresenting your age, identity, or relationship to a Teen User;
• Posting jobs that are unlawful, unsafe, exploitative, or inappropriate for young people;
• Contacting or attempting to contact a Teen User outside the Platform;
• Sharing, requesting, or exchanging personal contact information through Platform messaging;
• Uploading or transmitting content that is sexually explicit, violent, hateful, discriminatory, defamatory, or otherwise harmful;
• Harassing, bullying, threatening, or intimidating any user;
• Attempting to arrange meetings with Teen Users outside the context of an accepted job;
• Using the Platform for any form of money laundering, fraud, or financial crime; and
• Interfering with or disrupting the Platform's infrastructure or security systems.

6. Content and Intellectual Property

6.1 User Content

You retain ownership of Content you upload. By uploading Content, you grant us a worldwide, non-exclusive, royalty-free licence to use, display, reproduce, and distribute it within the Platform to provide our service. All Content is subject to automated moderation.

6.2 Platform Intellectual Property

The KidsHustle name, logo, design, software, and all associated intellectual property are owned by Urban Mechanics LTD. Nothing in these Terms grants you any right to use our intellectual property.

7. Working Hours and Child Employment

• Jobs may only be posted for times between 7:00 AM and 7:00 PM;
• Teen Users aged 13 to 15 who are still of compulsory school age are subject to additional working hour restrictions under local authority bylaws;
• Teen Users aged 16 to 17 must not work more than 8 hours per day or 40 hours per week under the Working Time Regulations 1998;
• It is the responsibility of both the Job Owner and the Teen User's parent to ensure compliance with all applicable child employment laws; and
• The Platform does not constitute an employer of any Teen User.

8. Fees and Charges

The Platform charges a 12.5% service fee on top of the job amount, payable by the Job Owner. This fee is non-refundable once work has commenced. There are no fees charged to Teen Users or Parent Users for using the Platform as a family.

9. Limitation of Liability

To the fullest extent permitted by law, Urban Mechanics LTD is not liable for any indirect, incidental, special, consequential, or punitive damages arising from your use of the Platform; we do not guarantee the quality, safety, or legality of any job posted; we are not responsible for the conduct of any user; and we do not act as an employer, employment agency, or recruitment service.

Our total aggregate liability to you shall not exceed the total fees paid by you to the Platform in the 12 months preceding the claim. Nothing in these Terms excludes or limits liability for death or personal injury caused by negligence, fraud, or any other liability that cannot lawfully be excluded.

10. Account Suspension and Termination

We may suspend or terminate your account if you breach these Terms, if we reasonably believe your account poses a risk to the safety of other users, if you fail to complete identity verification (Parent Users), or if required by law. Account deletion requests are subject to a 30-day grace period.

11. Modifications to the Terms

We may update these Terms from time to time. We will notify you of material changes via email or in-app notification at least 14 days before the changes take effect.

12. Governing Law and Jurisdiction

These Terms are governed by and construed in accordance with the laws of England and Wales. Any disputes arising from these Terms shall be subject to the exclusive jurisdiction of the courts of England and Wales.

13. Contact Us

1. Our Commitment to Safety

The safety and wellbeing of the young people who use KidsHustle is our highest priority. This Safety Notice explains the measures we have in place to protect Teen Users aged 13 to 17, the responsibilities of all parties, and what to do if something goes wrong.

2. Built-In Safety Features

2.1 Parental Oversight

Every Teen User must be part of a Family on the Platform. This means a parent or guardian must approve every job application, can view all in-app messages, can see their Teen's real-time GPS location during active jobs, receives alerts if their Teen leaves a defined area (geofencing), has visibility over earnings and completed jobs, and can remove their Teen from the Platform at any time.

2.2 Identity Verification

All Parent Users must complete identity verification before they can interact with Teen Users or post jobs. This involves verifying a government-issued identity document through our payment partner's verification service.

2.3 Content Moderation

We employ multiple layers of automated content moderation:

• Job listings are scanned by AI-powered safety systems to detect inappropriate, exploitative, or unsafe content.
• All images uploaded to the Platform are scanned for nudity, violence, hate symbols, weapons, drugs, and other harmful content.
• Chat messages are filtered through automated moderation. Messages flagged as inappropriate are shadow-blocked (hidden from the recipient without notifying the sender).

2.4 Working Hours Protection

Jobs can only be posted for times between 7:00 AM and 7:00 PM, in line with UK child employment regulations.

2.5 Financial Safeguards

The escrow payment system ensures Teen Users are guaranteed payment for completed work, as funds are held in escrow before the job begins. A 14-day cooldown provides an additional window for dispute resolution. No party has direct access to the other's financial details.

2.6 Communication Controls

Chat is only available within the context of an active job, parents can see all messages, automated moderation filters are applied, and sharing personal contact information through the chat is prohibited.

3. Reporting and Escalation

3.1 How to Report a Concern

• Report a user, job listing, or review directly through the app;
• Contact our support team at [email protected]; or
• In an emergency, always call 999 or contact your local police.

3.2 How We Handle Reports

When a report is made, the reported content or user is flagged in our system. Reports accumulating multiple flags are escalated for human review. We may suspend or terminate accounts. Where appropriate and legally required, we will report concerns to relevant authorities. We will not inform the reported party of the identity of the person who made the report.

3.3 Safeguarding Referrals

If we become aware of any concern regarding the safety or welfare of a child, we may suspend the relevant accounts immediately, report the concern to the relevant local authority children's services, and cooperate fully with any investigation by authorities.

4. Responsibilities of Parent Users

5. Responsibilities of Teen Users

6. Responsibilities of Job Owners

7. In-Person Job Safety

All jobs on the Platform are in-person. We strongly recommend:

• Parents accompany younger teens (aged 13–14) to and from job locations, especially for first-time jobs or unfamiliar Job Owners.
• Jobs take place in safe, accessible, and where possible, public or semi-public locations.
• Teens carry a charged mobile phone at all times during a job.
• Parents use the in-app location tracking and geofencing features to monitor their child's safety.

8. Emergency Contacts and Resources

• Childline: 0800 1111 (free, available 24/7)
• NSPCC Helpline: 0808 800 5000
• Police non-emergency: 101
• KidsHustle Support: [email protected]

9. Contact Us

1. Introduction

This GDPR Compliance Statement describes how Urban Mechanics LTD (company number 10959925), trading as KidsHustle, meets its obligations under the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.

KidsHustle is an online service specifically designed for children aged 13 to 17. As such, we are subject to the ICO's Age Appropriate Design Code (Children's Code) and apply enhanced protections to children's personal data throughout our systems and processes.

2. Data Controller Information

• Controller: Urban Mechanics LTD
• Company Number: 10959925
• Registered Address: 55 King William Street, London, EC4R 9AD
• Contact Email: [email protected]

Urban Mechanics LTD does not currently have a designated Data Protection Officer (DPO). For all data protection enquiries, please contact [email protected].

3. Data Protection Principles

We adhere to the seven key principles of the UK GDPR:

Lawfulness, Fairness, and Transparency

We process personal data lawfully, fairly, and in a transparent manner. Our Privacy Policy clearly explains what data we collect, why we collect it, and how it is used. We communicate with Teen Users in plain, understandable language.

Purpose Limitation

We collect personal data only for specified, explicit, and legitimate purposes: operating the Platform, facilitating jobs, processing payments, ensuring safety, and improving the service. We do not use data for any other purpose, including advertising or profiling.

Data Minimisation

We collect only the personal data strictly necessary to operate the Platform and protect the safety of our users. We do not encourage Teen Users to provide unnecessary personal information.

Accuracy

We take reasonable steps to ensure that personal data is accurate and up to date. Users can update their information through the Platform at any time.

Storage Limitation

We retain personal data only for as long as necessary. Location data, for example, is deleted 21 days after job completion. Specific retention periods are set out in our Privacy Policy.

Integrity and Confidentiality (Security)

We implement appropriate technical and organisational measures, including:

• Passwords stored using industry-standard cryptographic hashing
• All data transmitted over HTTPS/TLS
• Server infrastructure hosted on EU-based cloud platforms
• PCI-DSS compliant payment processing
• Role-based access controls for internal data access
• Automated masking of sensitive data in analytics and session recordings

Accountability

We are responsible for, and able to demonstrate compliance with, the UK GDPR. This document, our Privacy Policy, and our internal records of processing activities form part of our accountability framework.

4. Lawful Bases for Processing

4.1 Contract (Article 6(1)(b))

Account management, job facilitation, payment processing, and communications are necessary for the performance of our contract with users. For Teen Users aged 13 to 17, we additionally rely on legitimate interests, noting that parental consent and oversight is required, we process only data strictly necessary for the service, enhanced safety and privacy protections are in place, and the Teen User's best interests are always the primary consideration.

4.2 Legitimate Interests (Article 6(1)(f))

We rely on legitimate interests for the following, having conducted a Legitimate Interests Assessment (LIA) for each:

• Safety and content moderation: Legitimate interest in maintaining a safe platform for minors.
• Analytics: Legitimate interest in maintaining a stable, functional platform. Sensitive data is automatically masked.
• Fraud prevention: Legitimate interest in protecting the Platform and its users from abuse.
• Location tracking during jobs: Legitimate interest in protecting the physical safety of Teen Users. Access is strictly limited to the Teen's parent or guardian.

4.3 Legal Obligation (Article 6(1)(c))

We process data where required by law, including financial record-keeping (HMRC requirements), responding to court orders, and safeguarding referrals.

5. Children's Data and the Age Appropriate Design Code

As an online service specifically designed for children, we conform to the ICO's Age Appropriate Design Code across all 15 standards:

Standard 1: Best Interests of the Child

The best interests of the child are a primary consideration in all our design decisions and data processing activities.

Standard 2: Data Protection Impact Assessment

We have undertaken a Data Protection Impact Assessment (DPIA) for our processing of children's personal data. This assessment is reviewed and updated periodically.

Standard 3: Age-Appropriate Application

We verify the age of users at registration through a date of birth picker. Users under 13 are not permitted to create accounts.

Standard 4: Transparency

Our Privacy Policy and Terms of Service are written in clear, accessible language. We provide an additional plain-language summary written specifically for Teen Users.

Standard 5: Detrimental Use of Data

We do not use children's data in any way that has been shown to be detrimental to their wellbeing. We do not build behavioural profiles, use nudge techniques, or serve advertising.

Standard 6–8: Policies, Default Settings, Data Minimisation

Our Terms set out standards of behaviour. All settings are high privacy by default — Teen Users' location is never shared beyond their parent or guardian. We collect only the minimum data necessary.

Standard 9: Data Sharing

We share data with third-party processors only where strictly necessary. A full list of sub-processors is maintained at kidshustle.app/sub-processors.

Standard 10: Geolocation

Geolocation tracking is active only during jobs and is visible only to the Teen's parent or guardian. Location data is deleted 21 days after job completion. No default "always-on" tracking exists.

Standard 11: Parental Controls

Parents have comprehensive controls: they approve job applications, view messages, monitor location, and can remove their child from the Platform at any time.

Standard 12: Profiling

We do not engage in profiling of children. Analytics data is used only in aggregate form for product improvement.

Standard 13–14: Nudge Techniques & Connected Devices

We do not use nudge techniques. The Platform does not interact with connected toys or devices.

Standard 15: Online Tools

We provide accessible tools for users to exercise their data rights, including account deletion and data access requests via [email protected].

6. Data Processing Records

In accordance with Article 30 of the UK GDPR, we maintain a Record of Processing Activities (ROPA) which documents all categories of processing, lawful bases, data recipients, retention periods, and security measures.

7. Data Breach Procedures

In the event of a personal data breach, we will:

• Assess the breach within 24 hours of becoming aware of it;
• Where the breach is likely to result in a risk, report it to the ICO within 72 hours in accordance with Article 33;
• Where high risk to individuals, notify affected users without undue delay in accordance with Article 34;
• Take immediate steps to contain and mitigate the breach; and
• Document the breach, its effects, and the remedial action taken.

Given that our Platform processes children's data, we treat any breach involving Teen Users' data with the highest severity and priority.

8. Data Subject Access Requests (DSARs)

Users (or their parents on their behalf) may submit a DSAR by emailing [email protected]. We will verify the requester's identity, respond within one calendar month (extendable by two months for complex requests), provide data in a commonly used machine-readable format, and not charge a fee unless the request is manifestly unfounded or excessive.

9. International Transfers

Our primary data storage is in the EU. Where data is transferred to countries outside the UK without an adequacy decision, we rely on Standard Contractual Clauses (SCCs), the UK International Data Transfer Agreement (IDTA), or other appropriate safeguards. A Transfer Impact Assessment (TIA) is conducted for each international transfer.

10. Sub-Processor Management

A full list of our sub-processors is maintained and publicly available at kidshustle.app/sub-processors. All sub-processors are bound by Data Processing Agreements requiring them to process data only on our instructions.

11. Recommendations for Future Compliance

As the Platform grows, we recommend the following additional measures:

• Appointment of a formal Data Protection Officer (DPO) in accordance with Article 37, particularly given the large-scale processing of children's data.
• Implementation of a cookie consent mechanism to provide granular control over non-essential analytics tracking.
• Regular third-party audits of data protection practices.
• Formal age verification measures beyond date of birth self-declaration.
• Registration with the ICO as a data controller, if not already registered.
• Completion and publication of a child-friendly version of the Privacy Policy on the website.

12. Contact Us

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.