Mrs Wordsmith Limited respects your privacy and is committed to protecting your personal data.
1. Important information and who we are
- Email address: email@example.com ;
- Postal address: Unit 201 The Shepherds Building, Charecroft Way, London, W14 0EE.
You have the right to make a complaint at any time to:
- the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues; or
- a competent supervisory authority of an EU member state if you download the App outside the UK.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO or another supervisory authority so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Children’s Details are the details that you enter into the App about your child(ren). For example, nickname and month and year of birth;
- Children’s Usage Data is the data about your child(ren)’s use of the App. For example, areas of the App accessed and for how long and levels of the App completed;
- Contact Data is your contact data and includes your email address;
- Report Data is your preference in receiving reports about your child(ren)’s progress and development as a result of using the App;
- Technical Data includes:
- the type of device on which the App is installed;
- your origin. For example, that you clicked on a particular advert on Facebook or searched for the App within the Apple App Store or the Android Store;
- time from install of the App to first (substantive) use;
- the state (e.g. the United Kingdom or France) in which you are located;
- unique user IDs that we ascribe to you;
- Transaction Data includes details about payments between you and Apple and whether you are a subscriber or are trialling the App.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct Interactions. You may give us Children’s Details and Contact Data by filling in forms when you sign-up to use the App or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:
- create username(s) for your child(ren) on the App; and
- request reports from us.
- Automated technologies or interactions. As you and your child(ren) use the App, we will automatically collect Children’s Usage Data and Technical Data.
- Third parties. We receive your Contact Data and Transaction Data from Apple Inc. or Google, LLC (or, in either case, an affiliated company).
4. How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- where we need to perform a contract we are about to enter or have entered with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Click ‘lawful basis’ to find out more about the types of lawful basis that we will rely on to process your personal data.
|Purpose/Activity||Type(s) of Data||Lawful Basis for Processing, Including Basis of Legitimate Interest|
|To develop and deliver reports to you about your child’s use of the App and their development and progress.||
||Necessary for our legitimate interests (to provide greater value to certain users of the App).|
|To analyse our users and subscribers of the App, including creating aggregated data.||
||Necessary for our legitimate interests (to understand users of the App – e.g. which kind of users choose to convert their trial to a paid subscription, how frequently the App is used).|
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We will not use your personal data for marketing purposes.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- External Third Parties as set out in the Glossary;
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers (where they are acting as our processors) to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used/accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for (including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements). We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Otherwise, we will erase your personal data promptly after the later of:
- 12 months from when the App was last used; or
- three months from cancellation of your subscription to the App.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- request access to your personal data;
- request correction of your personal data;
- request erasure of your personal data;
- object to processing of your personal data;
- request restriction of processing your personal data;
- request transfer of your personal data;
- right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want.
- Legitimate interest means processing your personal data to pursue a particular legitimate interest (whether ours or those of third parties). We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
EXTERNAL THIRD PARTIES
Service providers (acting as processors):
- Amazon Web Services EMEA SARL (incorporated and registered in Luxembourg with company number B186284 and whose registered office is at 38, Avenue John F. Kennedy, L - 1855), a provider of cloud computing and storage services;
- Appsflyer UK Ltd (incorporated and registered in England and Wales with company number 10246990 and whose registered office is at 5th Floor Merck House, Seldown Lane, Poole, BH15 1TW), a provider of data analytics services;
- DeltaDNA Limited (incorporated and registered in Scotland with company number SC383152 and whose registered office is at 25 Greenside Place, Edinburgh, EH1 3AA), a provider of data analytics services.
YOUR LEGAL RIGHTS
You have the right to:
- request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
- request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you (if applicable) at the time of your request;
- object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
- you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it;
- request the transfer of your personal data to you or to a third party. We will provide to you (or a third party you have chosen) your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
- withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.