Application Privacy Policy




Welcome to Mrs Wordsmith Limited’s privacy policy.

Mrs Wordsmith Limited respects your privacy and is committed to protecting your personal data.

This privacy policy (together with our terms and conditions, as set out at Terms & Conditions (our T’s & C’s), and any additional terms of use incorporated by reference into our T’s & C’s) applies to your and your child(ren)’s use of our ‘Foolproof Reading’ mobile application software (App) on your and/or your child(ren)’s mobile telephone or handheld device (Device).

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED?
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY
  11. DESCRIPTION OF CATEGORIES OF PERSONAL DATA

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Mrs Wordsmith Limited collects and processes your personal data through your use of the App, including any data you may provide through the App.

This App is intended for children and, where your child(ren) use the App, we will also collect personal data about them. While this privacy policy is addressed to ‘you’, as your child(ren) develop, you should ensure that they understand the information in this privacy policy as it relates to them.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Mrs Wordsmith Limited (referred to as we, us and our in this privacy policy) is the controller and responsible for your personal data. We are a company incorporated and registered in England and Wales under number 09483252.

Contact details

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the data privacy manager using the details set out below.

  • Email address: privacy@mrswordsmith.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:

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.

Changes to the privacy policy and your duty to inform us of changes.

We keep our privacy policy under regular review. This version was last updated on 14th December 2020.

Our privacy policy may change and, if it does, these changes will be notified to you (for example, when you next start the App). The new policy may be displayed on-screen and you may be required to read and accept the changes in order to continue your use of the App.

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 (not real name) 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) and time from install of the App to first (substantive) use;
  • Transaction Data includes details about payments between you and Apple and whether you are a subscriber or are trialling the App.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate Children’s Usage Data to calculate the percentage of users accessing a specific feature of the App. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

Purposes for which we will use 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.
  • Children’s Details
  • Contact Data
  • Report Data
Necessary for our legitimate interests (to provide greater value to certain users of the App).
To create aggregated data.
  • Children’s Usage Data
  • Technical Data
  • Transaction 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.

Marketing

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;
  • Third parties to whom we 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.

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 European Union.


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.

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:

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.


10. Glossary

LAWFUL BASIS

  • 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.

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;