PRIVACY POLICY
The website www.vocabulous.co.uk is owned and operated by Vocabulous Limited (“we”, “us” or “Vocabulous”).
Vocabulous is committed to protecting your privacy and will only use the information that we collect about you lawfully. This policy explains how we collect and use your information.
The data controller of your personal information is Vocabulous Limited (company number 14248178) which is registered with the Information Commissioner’s Office (“ICO”) with registration number ZB382688.
By using our website or providing us with your personal information you confirm that you have read, understand and accept the terms of this policy. We may update this policy from time to time without notice to you, so please check it regularly.
1 How we collect information about you
Information you give us
1.1 We may collect personal information from you in the following ways:
a) you fill in forms on our website;
b) our use of cookies (please see our cookie policy);
c) you respond to our mailings, appeals, competitions, advertisements or other correspondence;
d) you subscribe to newsletters or updates or request information about us;
e) you contact us with enquiries or other correspondence (including via social media) or become involved with us in another way;
f) you register a website account; or
g) you report a problem on our website.
1.2 We may collect and process personal information such as:
a) teachers’ names and email addresses (to set up teacher accounts);
b) students’ names and classes (to administer student accounts);
c) information you or a school enters onto our website which may include the following information in relation to students: gender; Special Educational Needs (SEN) status; Able, Gifted and Talented status, Free School Meal or Pupil Premium status. This information is entirely optional and is not required to use the website;
d) records of your correspondence with us, if you have contacted us;
e) subject to your acceptance of our use of cookies, details of your visit to our website, including your internet protocol (IP) address, operating system and browser type, for system administration. We use this in statistical form to help us understand our users’ browsing actions and patterns, and this does not identify any individual;
f) if you are a student accessing the website, information about how many times you have clicked on a link, amounts of time spent on quizzes and page interaction information. This enables us to provide statistical feedback to teachers on the performance and progress of students.
1.3 If providing us with information for inclusion on the website, you may provide us with information about others (e.g. in a case study or an article). You must ensure that they have agreed to you providing us with this information. We recommend that you keep a copy of them having agreed to this, and that you give them a copy of this policy.
1.4 We also work closely with third parties (including, for example, website developers). As well as the web developer being able to access your personal data on our system, they may provide personal data about you to us when dealing with any problem that has arisen in relation to your account. This will not include any personal data to which we do not already have access.
1.5 Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
1.6 We use a third party payment processor, Stripe, to process credit card payments made to us. Transactions are encrypted using SSL technology. We do not retain any credit card numbers ourselves. Stripe's use of your personal information is governed by their privacy policy, which may be viewed at https://stripe.com/us/privacy.
2 Children and Consent
2.1 Children under the age of 18 cannot register to use Vocabulous themselves. Schools must register students as part of a school subscription or trial. Schools must ensure they have determined appropriate grounds in accordance with UK GDPR to transfer personal data of students to Vocabulous.
3 Storing your personal data
3.1 The data we collect from you will be stored within the UK or the European Economic Area (EEA).
4 Uses made of the information
4.1 We will process your personal data, in accordance with our obligations under applicable data protection laws and regulations, for the following reasons and on the following grounds for processing:
a) where you are a teacher, to process your school’s application and administer your accounts (legitimate interests);
b) to send confirmation emails during the account set-up process (legitimate interests);
c) to administer accounts, including password resetting (legitimate interests);
d) to provide you with the information you have requested (legitimate interests);
e) to calculate the amount of time spent on each quiz and the number of times quizzes have been repeated (legitimate interests);
f) to provide statistical analysis to schools on the progress of their own students (legitimate interests);
g) to notify you of changes and improvements to the website (legitimate interests);
h) to comply with applicable laws and regulations, and requests from statutory agencies (legal requirement or legitimate interests);
i) to notify you of any changes to information about us and the services you have purchased from us (legitimate interests);
j) for marketing purposes: to products or services that we provide or provide access to (where you are our existing customer, legitimate interests);
k) for the purposes of research, such as user satisfaction surveys (legitimate interests);
l) for our own internal administrative purposes and to keep a record of your relationship with us (legitimate interests);
m) to keep the website safe and secure (legitimate interests);
n) to manage your communication preferences with us generally (legitimate interests); and
o) to ensure that content from our website is presented in the most effective manner for you and for your computer (consent).
4.2 If you request to receive no further contact from us, we will keep some basic information on a suppression list to ensure we do not contact you again in the future.
4.3 We will keep your personal data for no longer than 90 days following the date that a school deletes your information if you are a teacher or a student or, if later, 90 days from the data that a subscription or trial period expires or is terminated. We retain the information for a 90 day period so that it can be recovered easily if the information is accidentally deleted.
4.4 If, at any time you do not wish to receive further information about us and our services, contact us at info@vocabulous.co.uk.
5 Disclosure of your information
5.1 We may disclose your personal information to third parties in the following circumstances:
a) for invoice payments, we use a third party accounting service, QuickBooks, to create and send the invoices. Transactions are encrypted using SSL technology. The information sent to QuickBooks is limited to the billing person's name and email address, the organisation's name and postal address and what you've ordered. Use of your personal information is governed by QuickBooks’s privacy policy, which may be viewed at https://quickbooks.intuit.com/hk/privacy/;
b) if we are under a legal duty to disclose or share your personal data;
c) where we work with third parties who may have access to your personal data when providing services to us, including:
- web developers;
- web hosting companies;
- companies that provide electronic data storage and transmission services;
- database and cloud providers; and
- providers of third party software that we need to run the website.
d) to our accountants and legal advisors to the extent they need to see your personal data to provide us with advice; and
e) to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
6 Your rights
6.1 What are your rights?
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data. There are certain caveats and exemptions to those rights which mean that in some circumstances you may not be entitled to exercise them, if we believe that is the case upon receipt of a request from you we will let you know.
6.2 Access to your data
You have the right to ask us to confirm that we process your personal data, as well as access to and copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.
6.3 Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information.
6.4 Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you.
6.5 Right to restrict processing
In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we do not have to delete it.
6.6 Data portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller.
6.7 Right to object
You are entitled to object to us processing your personal data:
a) if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
b) for direct marketing purposes (including profiling); and/or
c) for the purposes of scientific or historical research and statistics.
We do not intend to use your personal data to send you direct marketing nor for scientific or historical research and statistics.
6.8 Automated decision making
Automated decision making means making a decision solely by automated means without any human involvement.
You may be subject to automated decision making if you submit a finance application for credit, which would be considered by our third party intermediary. If you do not wish to be subject to automated decision making for that purpose we would be unable to offer you credit.
7 Your right to complain about our processing
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, please get in touch with us so we can help. You can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website - https://ico.org.uk/concerns/.