Privacy Policy

Information we may collect from you

1. 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:
   1. 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.
   2. Information that you provide when communicating with us through our site.
   3. If you contact us, we may keep a record of that correspondence.
   4. 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).
   5. Details of transactions you carry out through our site and of the fulfilment of your orders.
   6. 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.
2. 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:
   1. Name
   2. Name of school
   3. Date of birth
   4. Gender
   5. Photograph
   6. Likeness
   7. Audio and video recordings
   8. School year
   9. Assessment data
   10. Name and email address of parents and teachers

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.

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.

Where we store your Personal Data

1. 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.
2. 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.
3. 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.

Uses made of your Personal Data

1. 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):
   1. verify your identity and your school (necessary for the performance of a contract);
   2. provide you with personalised visits to our site to help us make your experience as enjoyable as possible (legitimate interests);
   3. 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);
   4. identify you so you can log-in to our site (necessary for the performance of a contract);
   5. recommend goods, services or promotions which may be of interest to you, except where you have requested otherwise (consent or legitimate interests)
   6. develop our offers and the layout of our site to ensure that our services are as useful and enjoyable as possible (legitimate interests);
   7. contact you (necessary for the performance of a contract and/or consent); and
   8. 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).
2. 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.
3. 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.

Disclosure of your Information

1. 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.
2. We will not disclose your personal data to third parties except in the following limited circumstances:
   1. 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.
   2. 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;
   3. 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
   4. 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;
   5. 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.

Your Rights

1. You have the following rights in relation to your personal data:
   1. a right to access your personal data held by us;
   2. right to receive certain personal data in machine-readable format;
   3. a right to have inaccurate personal data rectified;
   4. 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;
   5. 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;
   6. 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;
   7. a right to request an explanation of the logic involved where we make decisions about you solely through automated means; and
   8. a right to complain to the Information Commissioner's Office.
2. 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.
3. 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.
4. 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.
5. 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.

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.

Children

1. 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.
2. 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.
3. We recommend that persons who are aged 13 or under consult with the parents before sending any information about themselves over the internet.
4. 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.

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.

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.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to hello@pobble.com.