Privacy policy

This Privacy Policy was last updated on 9 September 2024.

We are committed to providing safe, educational and entertaining services to our customers and their children. We take your privacy seriously, particularly where your children are interacting with our products. Welcome to our privacy policy.

Mrs. Wordsmith Group Limited is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website or use one of our apps and tell you about your privacy rights and how the law protects you. For the purpose of this policy the terms ‘you’ and ‘your’ mean ‘account holder(s)’ (which may be a parent, guardian or teacher) and/or ‘user(s)’ ( which may be a child or school student).

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. COOKIE POLICY

12. CALIFORNIA CONSUMER PRIVACY ACT

13. CONTACT A DATA PROTECTION AUTHORITY
    
    

1. Important information and who we are

Purpose of this privacy policy

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

• purchase or download our products;

• use our services;

• create an account on our website or one of the apps;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

• We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology

The website is not intended for children and we do not knowingly collect data relating to children from the website.

The apps are meant to be played by children, and we carefully control and limit what information we collect.

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 Group 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 12625063. We are also registered with the Information Commissioner's Office under reference ZB128651.

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 your legal rights , please contact the data privacy manager using the details set out below.

• Email address: privacy@mrswordsmith.com;

• Postal address: Hatch House Farm, West Woodhay, Newbury, Berkshire, RG20 0BH.

• Phone number: +44 20 4592 9037

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 9 September 2024.

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 your relationship with us.

Third party links

The website may include links to third party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The apps do not have external third party links, but we do collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology.

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:

• Contact Data includes billing address, delivery address, email address and telephone number(s) of the account holder (which may be a parent, guardian or teacher);

• Identity Data includes

• account holder first name and last name, school and class if applicable     

• user (child or school student) first and last name, date of birth, age, school grade, school     

• Financial Data includes account holder payment information such as card details;

• Marketing and Communications Data includes account holder preferences in receiving marketing from us.

• Profile Data includes:

• Account holder and user login details - email address and password;

• purchases/orders placed by the account holder or downloads of apps or digital content from our website;

• account holder interests, preferences, feedback, reviews and survey responses;

• user language;

• user learning and game progress;

• user audio

• Technical Data about account holders and users includes:

• internet protocol (‘IP’) address;

• your login data;

• your browser type and version;

• time zone setting and geographical location (through IP address);

• browser plug-in types and versions;

• operating system and platform; and

• other technology on the devices account holder’s and user's use to access our website;

• unique user IDs that we ascribe to account holders and users;

• Transaction Data includes details about:

• payments to and from account holders;

• deliveries to account holders and any returns;

• details of products account holders have purchased/ordered or downloaded from us;

• Usage Data includes information about how:

• account holders and users use our products and services;

• account holders respond to direct marketing that we send.

We may 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 your Usage Data to calculate the percentage of users accessing a specific website feature. 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 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 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 (for example, to provide you with products/services). In this case, we may have to cancel the provision of the products/services but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about account holders and users including through:

• direct interactions with the account holder. You may give us your Identity, Contact, Financial and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• purchase or download our products;

• create an account on our website or in an app;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

• interactions with school account holders via Clever and Wonde platforms. The disclosure of school student user personal data through these platforms is solely controlled by the school account holder and/or teachers. 

• automated technologies or interactions. As account holder and/or users     interact with our website or apps, we will automatically collect Technical Data about their equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details;

• third parties. We will receive personal data about account holders from various third parties as set out below:

• Technical Data from:

• analytics providers;

• advertising networks; and.

• search information providers.

• Transaction Data from payment processing and delivery service providers such as Shopify and PayPal.

Cookies

For more information about the cookies we use, please see cookie policy below.

4. How we use your personal data

We will only use personal data when the law allows us to do so. Most commonly, we will use personal data in the following circumstances:

• where we need to perform a contract we are about to enter into or have entered into with the account holder;

• 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;

• where we need to comply with a legal obligation.

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

We have set out below, in a table format, a description of all the ways we plan to use personal 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 personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Unless detailed, the following purposes are for the processing of account holder personal 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.

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 – account holders and schools only

You will only receive marketing messages from us if you have permitted these or requested these from us.

You can ask us to stop sending you marketing messages by:

• following the opt-out links on any marketing message sent to you; or

• contacting us at any time.

However, where you opt out of receiving these marketing messages, we may still continue to process your personal data for other purposes.

We will not share your personal data with third parties 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 may transfer your personal data to our affiliated companies or third parties in locations around the world for the purposes described in this privacy policy, and in any event where we have a lawful basis on which to do so. For those third parties to whom we transfer your personal data (listed in the External Third Parties), we ensure a similar degree of protection is afforded to it by:

• transferring to countries that have been deemed to provide an adequate level of protection for personal data (an ‘adequacy decision’); 

• where there has been no adequacy decision, using a standard contract, where recognized by law, which ensures personal data has the same protection as it has in the country of origin; 

• obtaining your consent; or

• other lawful means of transferring personal data.

Please contact us if you want further information (including a copy of the standard contract, where applicable) on the specific mechanism used by us when transferring your personal data outside of the country of origin.

Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer.

We will take steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy policy and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal data.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used/accessed in an unauthorized 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 once it has been (so far as we are able to establish) over 12 months since you last visited our website.

9. Your legal rights

STATE PRIVACY RIGHTS

Under some U.S. state laws residents may have the rights listed below. 

• Right to Know: The right to request the personal data that we collect, use or disclose and information about our data practices;

• Right to Request Deletion: The right to request that we delete the personal data we have collected about a user; 

• Right to Opt-Out of Data Sales: The right to restrict the sale to third parties of a user’s personal data that we have collected; 

• Right to Non-Discrimination: The right to not be discriminated against for exercising any of these rights;

• Right to Correct Information: The right to update or correct the personal data that we collect;

• Right to Limit Use or Disclosure of Sensitive Personal Information: The right to limit the use and disclosure of Sensitive Personal Information (as defined under the CPRA);

• Right to Access Information Related to Automated Decision Making: The right to inquire about our logic involved in automated decision-making applied to personal data we collect; and

• Right to Opt-Out of Automated Decision-Making Technology: The right to request a user’s removal from having automated decision-making applied to a user’s personal data that we collect.

To request further information pursuant to a user’s “right to know” or to request deletion of personal data pursuant to the user’s “right to request deletion”, please contact us at privacy@mrswordsmith.com.

We will acknowledge receipt of such request within 10 business days, and provide a substantive response within 45 calendar days, or inform the user of the reason and extension period (up to 90 days) in writing.

Only a user or an authorised agent may make a request related to such user’s personal data. Note that to respond to a user’s requests to access or delete personal data as outlined in applicable state laws, we must verify the user’s identity.

EEA Privacy Rights

If you are a resident of or located within the European Economic Area (EEA), 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.

App specific guidance

An Adult User can review, change, prevent the further use of, or delete, the information they provided when registering for a Service, including by adding or removing Child Users to the Account, by updating information through the Parent or Guardian Section of the Service.
When we change or delete any Personal Information at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules.

10. Glossary

LAWFUL BASIS

• App or Apps means the Readiculous or Word Tag games (including schools) available for download on the Apple iOS App Store and the Google Android Play Store.

• 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 personal 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.

• Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

EXTERNAL THIRD PARTIES

We use a variety of third-party service providers to help us provide services related to our own services. Service providers may be located inside or outside of the UK, and the European Economic Area (“EEA”). We hold Data Processing Agreements (DPA) in place with all the third-party services, that guarantee that adequate safeguards are put in place with respect to the protection of such Personal Data as required by applicable privacy laws, including the UK and EU’s GDPR Data Protection laws. We do not sell personal information to third parties. You can contact us with questions regarding these third-parties' data practices.

The following are examples of these:

• Payment processing providers (acting as controllers):

• PayPal, Inc. (incorporated and registered in Delaware, USA with company number C3842984 and whose registered office is at 2221 North 1st Street, San José, CA 95131);

• Shopify Inc. (incorporated and registered in Canada with company number 847871746 and whose registered office is at 151 O'Connor Street, Ground Floor, Ottawa, ON, K2P 2L8);

• Stripe Inc. (incorporated and registered in Delaware with company number 270465600 and whose registered office is at 510 Townsend Street, San Francisco, CA 94103);

• Delivery service providers (acting as controllers):

• Shipbob Inc. (incorporated and registered in Delaware, USA with company number 5531564 and whose registered office is at 120 N. Racine Avenue, Suite 100, Chicago, Illinois).

• Service providers (acting as processors):

• 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), a provider of cloud computing and storage services;

• Appsflyer UK Ltd (incorporated and registered in England and Wales with company number 10246990 and whose registered office is at 5th Floor Merck House, Seldown Lane, Poole, BH15 1TW), a provider of data analytics services;

• Google UK Limited (incorporated and registered in England and Wales with company number 03977902 and whose registered office is at Belgrave House, 76 Buckingham Palace Road, London, SW1W 9TQ), a provider of data analytics services.

• Wonder

• Clever

• DeltaSNA (Unity)

• Qonversion

• Sentry

• Gorgias

• MiriGrowth

• PlayTestCloud

• Klaviyo

• Firestore

• Neo4J Aura

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. 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. Cookie Policy

Our website uses cookies to distinguish you from other users of our website. (For ease, we also refer to technology similar to cookies used in our apps as ‘cookies’.) A cookie is a small file of letters and numbers that we store on your device, if you agree. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

At this time, we do not respond to internet browser ‘do not track’ requests/signals.

We use the following cookies:

• strictly necessary cookies. These are cookies that are required for the operation of our website. They include (for example) cookies that:

• enable you to log into secure areas of our website;

• use a shopping cart; or

• make use of e-billing services;

• analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works. For example, by ensuring that users are finding what they are looking for easily;

• functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region);

• targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

How can I manage my cookies?

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. All cookies will expire after 12 months (at the latest).

For more information about cookies you can visit About Cookies.

You can also choose how web browser cookies are handled by your device via your browser settings. Some devices allow you to control this through your device settings. If you choose not to receive cookies at any time, websites may not function properly and certain services will not be provided. Each browser and device is different, so check the settings menu of the browser or device to learn how to change your settings and cookie preferences.

You can find information on how to manage cookie settings on certain browsers via the following links:

 

• Google Chrome Turn cookies on or off - Computer - Google Account Help

• Microsoft Edge Microsoft Edge, browsing data, and privacy

• Mozilla Firefox Enhanced Tracking Protection in Firefox for desktop | Firefox Help (mozilla.org)

• Microsoft Internet Explorer Delete and manage cookies (microsoft.com)

• Opera Web preferences - Opera Help

• Apple Safari – Official Apple Support
  
  

To find information relating to other browsers, visit the browser developer's website.

If you would like more information about the cookies used on our website, please contact us.

12. California Consumer Privacy Act

Californian consumers can access our California Consumer Privacy Act notice by clicking here.

13. Right to Contact a Data Protection Authority

You have the right to contact your Data Protection Authority.

If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority if you prefer. Contact details for Data Protection Authorities in the EEA are available here.

To contact the Swiss authorities please visit  this website. To contact the UK authority please visit  this website. Where appropriate, your local data protection authority may also forward the matter to the Department of Commerce or FTC for consideration.

This policy was last updated on 9 September 2024