Privacy Policy
This privacy policy may relate to the processing of your child's personal data. Parents or guardians should read this privacy policy before deciding whether or not to consent to your child's personal data being processed.
Pobble Education Ltd (we, us, our) is committed to protecting and respecting your privacy.
This privacy policy (together with our Terms Of Use and any other documents
referred to in it) (Privacy Policy) sets out the basis
on which any personal data we collect from you, or that you provide to us,
will be processed by us. Personal data includes but is not limited to
information such as your name, e-mail address, residential and/or postal
address, telephone number, date of birth and credit/debit card details.
We advise you to read this Privacy Policy carefully to understand our views
and practices regarding your personal data and how we will treat it.
By using our website pobble.com and pobble365.com (and any related sites, mobile sites, services
or apps) (together, our site) and/or providing personal information you
consent to us obtaining personal information from you and holding and
using personal information that is provided by or obtained from you in
accordance with this Privacy Policy.
For the purpose of data protection laws (including the GDPR), the
controller (also known as the data controller) is Pobble Education Ltd
of Unit 15, Utopia Village, 7 Chalcot Road, London, NW1 8LH. We are
registered with the Information Commissioner's Office with registration
number: ZA144557.
Our nominated representative for the purpose of data protection laws is
Tom Garbutt (tom@pobble.com).
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Information we may collect from you
- The information we collect about you will depend on the services
which you receive through our site. We may collect and process the
following personal data about you:
- Information that you provide by filling in forms on our site.
This includes information provided at the time of becoming a member
of our site, registering to use our site, subscribing to our service,
posting material or requesting further services. We may also ask
you for information when you enter a competition or promotion we
sponsor and/or when you report a problem with our site. This
information may include your name, photograph, likeness, audio
and video recordings of you, your contact details, location and school.
- Information that you provide when communicating with us through our site.
- If you contact us, we may keep a record of that correspondence.
- Information that you provide when completing surveys on our site
(which we may ask you to complete and we use for research purposes
although you do not have to respond to them).
- Details of transactions you carry out through our site
and of the fulfilment of your orders.
- Details of your visits to our site including, but not
limited to, traffic data, location data, weblogs and other communication
data, whether this is required for our own billing purposes or otherwise
and the resources that you access.
- We value choice and believe that you should be in charge of your
own personal data, therefore in respect of pupils using our site, the
personal data that we collect will be only such personal data as is absolutely
necessary to provide services which the children (via their parents or
guardian) and their teachers have given their consent. This personal
data may include:
- Name
- Name of school
- Date of birth
- Gender
- Photograph
- Likeness
- Audio and video recordings
- School year
- Assessment data
- Name and email address of parents and teachers
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IP Addresses
We may collect information about your computer, including where
available your IP address, operating system and browser type, for
system administration and to report aggregate information to our
advertisers. This is statistical data about our users’ browsing
actions and patterns, and does not identify any individual.
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Cookies
Our site may use cookies to distinguish you from other users of
our website. This helps us to provide you with a good experience
when you browse our website and also allows us to improve our site.
For detailed information on the cookies we use and the purposes for
which we use them see our Cookie Policy.
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Where we store your Personal Data
- The data that we collect from you may be transferred to, and
stored at, a destination outside the European Economic Area (EEA).
It may also be processed by staff operating outside the EEA who
work for us or for one of our suppliers. Such staff maybe engaged
in, among other things, the fulfilment of your order, the processing
of your payment details and the provision of support services.
If your personal data is transferred outside of the EEA we will
ensure that adequate safeguards are put in place to ensure that
your personal data is processed to the same standards as if it
were processed within the EEA.
- Where we have given you (or where you have chosen) a password
which enables you to access certain parts of our site, you are
responsible for keeping this password confidential. We ask you
not to share a password with anyone.
- Unfortunately, the transmission of information via the internet
is not completely secure. Although we will do our best to protect
your personal data, we cannot guarantee the security of your data
transmitted to our site; any transmission is at your own risk.
Once we have received your information, we will use strict
procedures and security features to try to prevent unauthorised access.
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Uses made of your Personal Data
- In accordance with data protection laws, we will only process
your personal data where we have a lawful basis for doing so.
In respect of your personal data, these bases are where it is
necessary to provide services to you under the performance of the
contract we have with you; where we are required to do so in accordance
with legal or regulatory obligations; where you have given your consent;
and/or where it is in our legitimate interests to process your personal
data provided that these do not prejudice your own rights, freedoms
and interests. We use information held about you in the following
ways (and in accordance with the following lawful bases):
- verify your identity and your school (necessary for the performance of a contract);
- provide you with personalised visits to our site to help us make your experience as enjoyable as possible (legitimate interests);
- provide you with our services which you have signed up for, including additional services added by us from time-to-time (necessary for the performance of a contract);
- identify you so you can log-in to our site (necessary for the performance of a contract);
- recommend goods, services or promotions which may be of interest to you, except where you have requested otherwise (consent or legitimate interests)
- develop our offers and the layout of our site to ensure that our services are as useful and enjoyable as possible (legitimate interests);
- contact you (necessary for the performance of a contract and/or consent); and
- send out email alerts you may have signed up for to ensure that content from our site is presented in the most effective manner for you and for your computer (consent).
- In relation to children and pupils, we may include your first
name, age, photograph and primary school by your work published
on the site. We will notify parents or guardians of children / pupils of
this when obtaining consent for all such processing.
- All content, as well as the information listed in paragraph
5.2, which is submitted to our site may be accessed by the
public generally and may be shared on social media platforms.
By signing up to our site you agree to such access and sharing.
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- We may disclose your personal information to any member of
our group, which means our subsidiaries, our ultimate holding company
and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- We will not disclose your personal data to third parties
except in the following limited circumstances:
- if we are under a duty to disclose or share your
personal data in order to comply with any legal obligation,
in order to enforce or apply our terms of use, terms and conditions
of supply and other agreements; or to protect our rights,
property, or safety, our customers, or others. This includes
exchanging information with other companies and organisations
for the purposes of fraud protection and credit risk reduction.
- if you post or send offensive, inappropriate or objectionable
content anywhere on or to our site, or otherwise engage in any
disruptive behaviour on our site, or are otherwise in breach of
the terms of any of our other policies or terms of use, we may
disclose your personal data to relevant law enforcement authorities;
- where we reasonably believe that you are or may be in
breach of any of the laws of England and Wales (for example,
because content you have posted may be defamatory), we may use your
personal information to inform relevant third parties such as
your employer, e-mail/internet provider or law enforcement
agencies about the content and your behaviour; or
- if we or substantially all of our assets are acquired
by a third party, in which case personal data held by it about
its customers will be one of the transferred assets;
- in the event that we sell or buy any business or assets,
in which case we may disclose your personal data to the prospective
seller or buyer of such business or assets.
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Your Rights
- You have the following rights in relation to your personal data:
- a right to access your personal data held by us;
- right to receive certain personal data in machine-readable format;
- a right to have inaccurate personal data rectified;
- a right to object to processing where lawful basis is that it
is in our legitimate interests, but please note that we may still
process your personal data where there are other relevant lawful
bases or where we have compelling grounds to continue processing
your personal data in our interests which are not overridden by
your rights, interests or freedoms;
- a right to have certain personal data erased where it is no
longer necessary for us to process it, where you have withdrawn
your consent pursuant to paragraph 7.1.6, where you have
objected pursuant to paragraph 7.1.4, where your personal
data has been unlawfully processed, or where erasing your personal
data is required in accordance with a legal obligation;
- where we have specifically requested your consent to process your
personal data and have no other lawful conditions to rely on you
have the right to withdraw this consent;
- a right to request an explanation of the logic involved where
we make decisions about you solely through automated means; and
- a right to complain to the Information Commissioner's Office.
- Please be aware that whilst we will try to accommodate any request
you make in respect of your rights they are not absolute rights. This means
that we may have to refuse your request or may only be able to comply
with it in part.
- Where you make a request in respect of your rights we will
require proof of identification. We may also ask that you clarify
your request. If we receive repeated requests or have reason to
believe requests are being made unreasonably we may not be required to respond.
- You also have the right to ask us not to process your personal
data for marketing purposes. We will inform you (before collecting
your data) if we intend to use your data for such purposes or if
we intend to disclose your information to any third party for such
purposes. You can exercise your right to prevent such processing by
checking certain boxes on the forms we use to collect your data.
You can also exercise the right at any time by contacting us at hello@pobble.com.
- If you would like to contact us about our processing of your
personal data or to enforce your rights, you may do so by
emailing us at: hello@pobble.com.
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Retention
We will retain your personal data for the period necessary to provide
you with the services. Thereafter, your personal data shall be retained
for up to 5 years following the closure of any accounts you hold with
us (if applicable) or the last contact with us emanating from you.
Please note, however, that we may be subject to legal and regulatory
requirements to keep personal data for a longer period, in particular
pursuant to any applicable statutory limitation period.
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Children
- We are committed to providing special protection for the privacy
of children who may visit our site. We encourage parents and
legal guardians to spend time online with their children and
become familiar with the features of our site.
- We do not knowingly solicit, collect, use or retain any
personal information for any purpose whatsoever from users of
our site who are aged 13 or under without first obtaining the
written consent of that persons parent(s) or legal guardian(s)
aside from limited processing for the purposes of obtaining consent.
- We recommend that persons who are aged 13 or under consult
with the parents before sending any information about themselves
over the internet.
- If a parent or legal guardian becomes aware that their
child or children has provided us with any personal information
without their written consent, we invite you to notify us so
that we may delete this information from our site and our records
and discontinue any related services or features. We appreciate
your co-operation in assisting us to provide a safe and enjoyable
online experience for your children.
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Third Party Sites
Our site 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.
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Changes to our Privacy Policy
Any changes we may make to our privacy policy in the future will
be posted on this page and, where appropriate, notified to you.
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Contact
Questions, comments and requests regarding this privacy policy
are welcomed and should be addressed to hello@pobble.com.