Parents / Guardians - This privacy policy contains information about the processing of your child's personal data. Parents or guardians should read this privacy policy carefully and also check their education providers’ privacy policies for further information about how they process your child’s personal data. Please also read our child friendly privacy policy which can be found here.
INTRODUCTION
Pobble Education Ltd (“We” or “us”) are committed to protecting and respecting the personal data and privacy of our users (“you”) and the children who benefit from our services.
This privacy policy relates to how we use and collect personal data from users through their use of pobble.com and pobble365.com (referred to collectively as the “Pobble Platform” in this policy) or when they purchase a product or services from us. It also relates to information teachers, tutors, home schoolers and schools who use our systems (“Education Providers”) provide to us about children they teach by inputting this data into the Pobble Platform. It also relates to our use of any personal information you provide to us by telephone, in written correspondence (including letter and email), by SMS, in any chat functionality available on the Platform and in person.
Whenever we are provided with personal data, we are legally obliged to use this information in line with all applicable laws concerning the protection of such information; including the Data Protection Act 1998 and 2018 (DPA) and The General Data Protection Regulation 2016 (GDPR) to the extent to which it is applied by UK GDPR as defined by the Data Protection Act 2018 together with other subsequent laws (“Data Protection Laws”).
This privacy policy also forms part of our Terms of Service and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page. It is important that the personal data we hold is accurate and current. Please keep us informed if you or your child’s personal data changes.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here.
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1. WHO WE ARE AND HOW TO CONTACT US
1.1 For the purpose of the Data Protection Laws, the data controller is Pobble Education Ltd, registered company number 07784707 and we are registered with the Information Commissioners Office with registration number ZA144557. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:
FAO: Jonathan Smith / Director,
Pobble Education Ltd,
Rosehay,
Tremorvah Wood Lane,
Truro,
Cornwall,
TR1 1PZ
Email: privacy@pobble.com
Telephone: +44 (0) 20 8629 1732 and ask to speak to Jonathan Smith.
1.2 The information we collect about you will depend on the services which you receive from us and whether or not we have a direct relationship with you. In some cases, where you have registered for an account with us, we will have a direct relationship with you and you will have provided us with your personal data direct. In other cases, however your child’s personal data will have been provided to us by an Education Provider involved in providing education to your child. We have therefore split out below how the types of personal data we will collect about you and your child will differ depending on whether you are a registered user of the Pobble Platform or are simply the parent or guardian of a child whose details have been provided to us by an Education Provider. You can click the below links to take you to the relevant section of this privacy policy depending on the services you receive from us:
2. THE DATA WE COLLECT ABOUT YOU WHEN YOU SET UP A POBBLE ACCOUNT (POBBLE ACCOUNT DATA)
2.1 We collect and process personal data when you register to set up an account to use the Pobble Platform (regardless of the type of account you hold). Typically the personal data we collect and process will include identity, contract, financial, transactional, technical, profile, usage and marketing and communications data and Pobble Pupil Data such as:
2.1.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, the name of any child linked to a Parent Account.
2.1.2 Contact Data includes billing address, email address and telephone numbers.
2.1.3 Employment Data includes where you work for an Education Provider information about the Education Provider you work for and your position there.
2.1.4 Financial Data includes bank account details..
2.1.5 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
2.1.6 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Pobble Platform and our services.
2.1.7 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
2.1.8 Usage Data includes information about how you use the Pobble Platform products and services.
2.1.9 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.1.10 Pobble Pupil Data includes data held within the Pobble Platform and our systems. This includes information that Education Providers have entered onto our systems about individuals within their class which may contain their personal data such as name, age range and the work they have created. We will keep a record of the information users of the Pobble Platform have submitted. Please see 4. POBBLE PUPIL DATA and 5. HOW POBBLE PUPIL DATA WILL BE USED for further details about how this data is processed.
Please note that we may collect and/or process other personal data from time to time.
2.2 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 to be personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate a percentage of users accessing a specific feature of our services. However, if we combine or connect your 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 solely in accordance with this policy.
2.3 We do not collect the following special categories of personal data about you: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
2.4 We only collect data from you directly or via third parties (see the section 7. THIRD PARTIES AND SHARING INFORMATION)
3. HOW YOUR POBBLE ACCOUNT DATA WILL BE USED
3.1 We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. Most commonly, we will use the information about you detailed in section 2 above (“Pobble Account Data”) in the following circumstances:
3.1.1 To carry out our obligations arising from any contracts entered into between you and us (or between the Education Provider you work for and us) and to provide our services including the provision of the Pobble Platform; and
3.1.2 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; and
3.1.3 Where we need to comply with a legal obligation.
3.2 Where we use legitimate interests as the lawful basis for processing your personal data we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest products or obtaining your feedback on our service.
3.3 We will seek to obtain your consent to process your data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above). We do not obtain consent for processing personal data of children through the Pobble Platform as we rely on legitimate interests. (Please see 5. HOW POBBLE PUPIL DATA WILL BE USED below for further details regarding the processing of children’s personal data through the Pobble Platform).
3.4 We have set out below in a table format, a description of all the ways we plan to use your Pobble Account Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new user and customer |
Identity, Contact |
Performance of a contract with you and / or the Education Provider you work for |
|
To verify your identity and the Education Provider you work for |
Identity, Employment |
Performance of a contract with you and / or the Education Provider you work for Necessary for our legitimate interests (to ensure only verified users have access to data belonging to an Education Provider) |
|
To process and deliver your order including:
|
Identity, Contact, Financial, Transaction, Marketing and Communications |
Performance of a contract with you and / or the Education Provider you work for Necessary for our legitimate interests (to recover debts due to us) |
|
To keep a record of the data you have submitted when using the Pobble Platform |
Identity, Profile Data, Usage Data, Pobble Pupil Data |
Performance of a contract with you and / or the Education Provider you work for Necessary for our legitimate interests (to ensure the Pobble Platform is managed and administered correctly and our records are kept up to date) |
|
To manage our relationship with you which will include:
|
Identity, Contact, Profile, Marketing and Communications |
Performance of a contract with you and / or the Education Provider you work for Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
Identity, Contact, Profile, Usage, Marketing and Communications |
Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and the Pobble Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
Identity, Contact, Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
Identity, Contact, Profile, Usage, Marketing and Communications, Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, mobile application, products/services, marketing, customer relationships and experiences |
Technical, Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
Identity, Contact, Technical, Usage, Profile, Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
3.1 We never sell your data to third parties or allow third parties to contact you without your permission.
3.2 You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Parents / Guardians – Please read this section to understand how we will process your child’s personal data when their school, teacher or tutor is using the Pobble Platform.
4. POBBLE PUPIL DATA
4.1 We collect and process personal data about children when their data is provided to us by tutors, teachers or schools who we call “Education Providers” in this policy. Typically the personal data we collect and process will include identity data and copies of a children’s written work inputted into Pobble:
4.1.1 Identity Data includes first name, last name, username or similar identifier, age range, and gender. Each child will be assigned their own Pupil Account which will only be identifiable by their first name and accessible by a unique passcode.
4.1.2 Parent / Guardian Data includes the first name, last name, username or similar identifier of any parent or guardian who has a Parent Account linked to their child (this information is provided by the parent / guardian when they sign up for a Parent Account).
4.1.3 Education Data includes the name of the Education Provider your child uses and any assessment data inputted by that Education Provider.
4.1.4 Content Data includes details about content written by your child which has been submitted by your child’s Education Provider. We advise that children and those uploading their work ensure materials do not include personal data but from time to time we may occasionally receive personal data in the materials submitted if submitted accidentally by an Education Provider. If this happens please contact your Education Provider or us as soon as you become aware so we can remove any such content.
We call this data “Pobble Pupil Data” in this policy.
Please note that we may collect and/or process other personal data from time to time (for example information such as Free School Meal Entitlement, English as an Additional Language (EAL) status and Pupil Premium eligibility information may be collected by Education Providers and/or Pobble in some limited circumstances).
4.2 Marketing Data – please rest assured we do not send marketing information to children who use the Pobble Platform.
4.3 We also collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data could be derived from a child’s personal data, but is not considered to be personal data in law as it will not directly or indirectly reveal their identity. However, if we combine or connect a child’s aggregated data with their personal data so that it can directly or indirectly identify them, we treat the combined data as personal data which will be used solely in accordance with this policy.
4.4 We do not collect the following special categories of personal data about children: details about their race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, genetic and biometric data. Nor do we collect any information about criminal convictions and offences. This information should not be included in any Content Data. If this happens please contact your Education Provider or us and we can remove any such content.
4.5 We collect personal data about children directly from their Education Providers.
5. HOW PUPIL PERSONAL DATA WILL BE USED
5.1 We use the Pobble Pupil Data set out in section 4 above to carry out our obligations arising from any contracts entered into between us and your child’s Education Provider to provide our services to them which enables them to deliver the curriculum by utilising the Pobble Platform.
5.2 We never sell data to third parties or send pupils marketing information.
5.3 We share Pobble Pupil Data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis as set out in the table below. We may process Pobble Pupil Data without the child or their parent or guardian’s knowledge or consent where this is required or permitted by law.
5.4 We have set out below in a table format, a description of all the ways we plan to use Pobble Pupil Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please note that we may process Pobble Pupil Data for more than one lawful ground depending on the specific purpose for which we are using the data. Please contact us if you need details about the specific legal ground we are relying on to process Pobble Pupil Data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To enable Education Providers to use Pobble to deliver the curriculum by use of Pobble’s internal tools (including without limitation lesson plans and the ability to mark work and provide feedback to children) |
Identity, Education Data
|
Necessary for our legitimate interests (to enable us to provide Pobble to Education Providers in accordance with our contracts with them and to enable them to use Pobble to deliver the curriculum consistently to all pupils) |
|
To enable Education Providers and Pobble to know whether a parent / guardian has a Parent Account linked to a particular child |
Parent / Guardian Data |
Necessary for our legitimate interests (to ensure the correct parent / guardian is linked to the correct child and to enable parents and guardians to view their child’s work in the Pobble Platform to enrich their learning) |
|
To enable a child’s work to be published through the Pobble Platform by their Education Provider (“Published Content”) |
Identity, Education Data (Please note an anonymised username or no name will be used for Published Content and only the name of the Education Provider and age range of the child will be listed), Content Data |
Necessary for our legitimate interests (to enable children’s work to be shared with other members of the Pobble Platform to enable others to learn from the work and enrich the learning experience for all) |
5.5 Pobble will not publish a child’s work making it Published Content unless your child’s Education Provider has informed us that we can and that they have the relevant permissions to do so. A child’s work will only be shared with your child’s Education Provider, the users of Pobble linked to that Education Provider, any individual your child’s Education Provider has appointed to moderate your child’s work and any linked Parent Account, unless the work is published by your child’s Education Provider as Published Content. We require all Education Providers to seek the permission of the relevant parent or guardian before publishing a child’s work on the Pobble Platform. Please see our Terms of Service for further details about Published Content. Please contact your Education Provider or us if you wish to have any Published Content relating to your child removed from the Pobble Platform at any time
5.6 All Published Content may be accessed by other users of the Pobble Platform, the public generally and may be shared on social media platforms.
5.7 Please contact your Education Provider if you have any general questions about how they process your child’s personal data.
6. IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you or your child’s Education Provider, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or your Education Provider (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you or your child’s Education Provider if this is the case at the time.
7. THIRD PARTIES AND SHARING INFORMATION
7.1 We will keep your information within our organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you / your child’s Education Provider. We have contracts in place with our data processors. We require all third parties to respect the security of the personal data we provide them with and to treat it in accordance with the law. We do not allow our third-party service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with our instructions.
7.2 Please see below the list which sets out the categories and locations of recipients of personal data.
|
SERVICE PROVIDERS WHO MAY RECEIVE PERSONAL DATA |
|
AWS - Europe (London) |
|
Google (Data studio) - USA |
|
Mailchimp / Mandrill - USA |
|
Stripe - USA |
|
Chargebee - USA |
|
Hubspot - USA |
|
Stitch - USA |
|
Hotjar - Ireland |
|
Userflow - USA |
|
Secure document disposal service |
7.3 All Published Content (as described in section 5) may be accessed by the public generally and may be shared on social media platforms who will then process it in accordance with their own privacy policies.
7.4 In addition third parties may provide us with personal data and they should only do so where the law allows them to. We receive Pobble Pupil Data from Education Providers when they input the personal data into the Pobble Platform (Please see 4. POBBLE PUPIL DATA and 5. HOW POBBLE PUPIL DATA WILL BE USED above for further details). If you have any questions about how your child’s Education Provider processes personal data about you and your child you should contact them in the first instance.
7.5 If Pobble or substantially all of our assets are acquired by a third party, personal data held 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.
8. WHERE YOUR DATA IS HELD
8.1 In most cases your data is stored by us and our processors in the UK or EEA. Where your personal data is transferred outside of the UK or the EAA, we have ensured that:
8.1.1 an adequacy decision has been made by the European Commission permitting the transfer of data to that country; or
8.1.2 standard contractual clauses (SCCs) are in place and we have received assurances that an adequate level of protection of the personal data is achieved (based on a case by case assessment of the circumstances of the transfer), including adequate technical and operational measures in place to protect the personal data.
9. APPLICATIONS TO WORK FOR US
If you apply to work for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.
10. DATA RETENTION
Our data retention policy is dictated by the Data Protection Laws and is available for inspection by submitting a written request using the contact details provided in this policy. 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 see our FAQs for further detail about our retention periods. 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.
11. YOUR RIGHTS
11.1 Under the Data Protection Laws your rights are:
11.1.1 To be informed – We must make this privacy policy (sometimes referred to as a privacy notice) available with the emphasis on transparency over how we process your data.
11.1.2 Access – You are entitled to find out what details we may hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their Personal Data by making a formal request under the Data Protection Laws. Such requests should be in writing to the contact details provided in this policy. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy).
11.1.3 Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
11.1.4 Erasure – This is also known as the request to be forgotten. Under Data Protection Laws you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy.
11.1.5 Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
11.1.6 Portability – You have the right to obtain and reuse your personal data that you have provided to us.
11.1.7 Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.
11.1.8 Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
11.2 Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarised above on your on behalf or on behalf of a child in your care.
11.3 If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
12. CHANGES TO THIS PRIVACY POLICY
We keep our privacy policy under regular review and you should check back regularly to ensure you are aware of changes to it. We may display this notice to you from time to time to help ensure you are aware of its contents.
13. COMPLAINTS
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance
Pobble Education Ltd,
Rosehay,
Tremorvah Wood Lane,
Truro, TR1 1PZ,
Cornwall, UK
