Application Privacy Policy
Introduction
Welcome to Hatch House Games Limited’s privacy policy.
Hatch House Games Limited respects your privacy and is committed to protecting your personal data.
Last Updated: 17 February 2021
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
Purpose of this privacy policy
This privacy policy aims to give you information on how Hatch House Games Limited collects and processes your personal data through your use of the App, including any data you may provide through the App.
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.
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. For example, your child(ren) also have legal rights that they may exercise. Furthermore, our Application Privacy Policy also applies in relation to any children under the age of 13.
Controller
Hatch House Games 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, including any requests to exercise legal rights, please contact the data privacy manager using the details set out below.
- Email address: privacy@mrswordsmith.com ;
- Phone number: 1-844-852-2423
- 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 (www.ico.org.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.
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 29 January 2021.
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
Our apps are designed for young users with parents in control. They are educational experiences that support reading development. We collect the following information in our apps for children::
- Parent email address to set up and administer the account;
- Child nickname so the parent can manage their child/children’s accounts;
- Child’s month and year of birth to provide appropriate content;
- Child’s progress to provide parents with updates on the child’s use of the apps;
We collect the following information passively from children:
- 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;
We collect the following information passively from parents:
- Report Data: your preference in receiving reports about your child(ren)’s progress and development as a result of using the App;
- Technical Data which 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 country (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 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.
If you would like to review your child’s information or have it deleted you can do so at any time by contacting the data privacy manager using the details set out above.
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 parents’ 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 here 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.
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;
The following third parties are used in the app in relation to children. These third parties are used solely to support the operation of the app and no personal data is shared for any other purpose:
Our app is built with the Unity Game Engine and does not collect any personal information from users. Unity is able to track the technical performance of the app to manage crashes and critical errors. For more information on Unity, please review the privacy policy: https://unity3d.com/legal/privacy-policy.
We work with DeltaDNA as an analytics provider to help us track player engagement, retention and subscriptions. DeltaDNA does not collect or process personal information but does collect the following non-personal information in order to prepare the weekly “Parent Report”: the child’s date of birth, country, and child’s nickname. It also collects gameplay data such as missions started and completed, cookies earned and levels completed. For more information on DeltaDNA please see the privacy policy here: https://deltadna.com/privacy- 2/?doing_wp_cron=1608244298.3256208896636962890625.
We use Appsflyer as an attribution service to track installs in relation to registered parents and adult users only. For more information on Appsflyer, please see their privacy policy: https://www.appsflyer.com/privacy-policy/.
We use 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), as a provider of cloud computing and storage services.
If you would like more information on these third parties please contact us at privacy@mrswordsmith.com.
We do not serve ads to children and children cannot share any personal data in the app or with other users.
- 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 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.
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;
- withdraw consent at any time where we are relying on consent to process your personal data, including for the purposes of COPPA. (To exercise this right, you may email us at privacy@mrswordsmith.com.) 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.
11. California Consumer Privacy Act
Californian consumers can access our California Consumer Privacy Act notice by clicking here.