PRIVACY POLICY

1. WHAT IS THIS?

Education Shed Ltd (“we”, “us”, “our”) is committed to protecting and respecting your privacy.

This privacy policy explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure.

This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes.

This policy was last updated on 19th June 2019.

2. WHO WE ARE

We, Education Shed Ltd (company number 10949607), whose registered office is at Severn House, Severn Bridge, Severnside North, Bewdley, Worcestershire, DY12 1ES, UK is the data controller (ICO registration number ZA311518) in relation to the processing activities described below. This means that we decide why and how your personal information is processed.

3. INFORMATION WE COLLECT ABOUT YOU

When you use this website, our products or services, the categories of information that we may collect about you are as follows:

Personal information you give to us: this includes information about you that you give to us by entering information via:

• our Platform, which includes our websites: www.spellingshed.com, www.mathshed.com, hub.edshed.co and play.edshed.co (the “Websites”) and our apps (Spelling Shed and MathShed) where you can also play our games (the “Apps”);
• social media platforms;
• corresponding with us by phone, email or otherwise,

and is provided entirely voluntarily. This includes information provided at the time of registering to use our site and Apps, subscribing to the services we provide through our site and purchasing products, posting material or requesting further services, managing your account online (including accessing documentation and engaging in correspondence with us by phone, email or otherwise). We may also ask you for information when you report a problem with our site.

If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well.

The information you give us includes your name (or pseudonym), display name, email address, an account username, an encrypted account password, payment details, delivery information, information about your school (including name, address and phone number), unique pupil number (UPN), Wonde unique identifier (if applicable), school and school group membership, enquiry details and may include records of any correspondence and responses to any surveys.

Personal information we collect about you: we may automatically collect the following information:

• details of transactions you carry out through the site or Apps and the content you have purchased or accessed;
• user activities when using our products or services, such as Platform usage (including spelling or maths history information, custom lists and scores);
• details of your visits to our site, including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources you access;
• anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see Cookies for further information;
• personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform.
• Personal information we may receive from other sources: we obtain certain personal information about you from sources outside of our business which may third parties including your school (if you are a pupil or teacher), Wonde if your school uses this service or Zoho if you utilise our helpdesk or “Live Chat” customer support services.

4. HOW WE USE YOUR PERSONAL INFORMATION

The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.

Where you have provided CONSENT

We may use and process your personal information where you have consented [(or, if you are a child, and a person with parental responsibility for you/your school has provided consent on your behalf)] for us to do so for the following purposes:

• To identify your user account within our system in order to use our product and provide reporting to your school (if applicable); and
• contact you via email with marketing information about our products, Apps and service if you (i) register for an account with us online and indicate that you would like to receive such marketing from us; (ii) sign up to our newsletter via our website or other medium where available; or (iii) when you refresh your marketing preferences when responding to a request from us to do so.
• You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details.

Where there is a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:

• for marketing activities (other than where we rely on your consent to contact you by email or text with information about our products (including Apps) and services as explained above);
• for analysis to inform our marketing strategy, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our website);
• To provide reporting on your performance in our system to you or to your school (if applicable);
• to correspond or communicate with you;
• to verify the accuracy of data that we hold about you and create a better understanding of you as a customer;
• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
• for prevention of fraud and other criminal activities;
• to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
• to assess and improve our service to customers through recordings of any calls with our contact centres;
• for the management of queries, complaints, or claims; and
• for the establishment and defence of our legal rights.

Where there is a LEGAL REQUIREMENT

We will use your personal information to comply with our legal obligations: (i) to assist an applicable public authority or criminal investigation body; (ii) to identify you when you contact us; (iii) to verify the accuracy of data we hold about you; and (iv) to provide financial management and reporting in line with HMRC.

Where it is required to complete a CONTRACT

We may use and process your personal information where we have supplied you (or continue to supply you) with any products, Apps or services, or where you are in discussions with us about any new product, App or service. We will use this information in connection with the contract for the supply of products, Apps or services when it is needed to carry out that contract with you or for you to enter into it. Please see Information we collect about you about you above for details of the types of personal information we process for these purposes.

5. DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION

Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.

6. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Our suppliers and service providers

We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management), marketing/advertising agencies, email distribution services and administrative services.

When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

Credit/debit card payment processors

When you purchase any products or services online, your credit/debit card payment is processed by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy.

Customer satisfaction surveys

As customer satisfaction is important to us, we may ask a third party research company to contact you for the sole purpose of gathering general information and specific information relating to us and our products and services.

Other ways we may share your personal information

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

7. WHERE WE STORE YOUR PERSONAL INFORMATION

All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA).

If at any time we transfer your personal information to, or store it in, countries located outside of the EEA, including if at any time the United Kingdom is not in the EEA (for example, if our hosting services provider changes), we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

8. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.

Where possible, personal information will be fully deleted from our system automatically when an account has been inactive for approximately 12 months.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your personal information above. The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• for financial management purposes where minimal information is retained;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below); or
• in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

9. SECURITY AND LINKS TO OTHER SITES

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

10. COOKIES

Like many other websites, our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our website). 'Cookies' are small pieces of information sent to your computer or device and stored on its hard drive to allow our websites to distinguish you from other users.

We may use this information to observe your interest use and to compile data in order to improve our site or to aid you in customer service requests.

When you accessed this website, you were presented with a message that notified you of our use of cookies. We had to use a cookie to present you with that notice (you can see details of this cookie in the table below). If you continue to use this website, more cookies and other tracking technologies will be placed on your computer, as described in this policy in order to enhance your user experience whilst on the website.

By continuing to use the website, you are agreeing to the use of such cookies and tracking technology.

A list of the main cookies used on this website, together with details about what each is used for, can be found in the table below.

Cookie Name	Purpose
_ga	Analytics (Anonymous website analytics)
_gid	Google Analytics (Anonymous website analytics)
Spellingshed-_zldp	SalesIQ from Zoho (Live chat customer support)
Spellingshed-_zldt	SalesIQ from Zoho (Live chat customer support)
_session-token_	System session identifier

If you wish to restrict or block the cookies which are set by this Website (or, indeed, on any other site) you can do this through your browser settings. The ‘Help’ function within your browser should tell you how. If you are primarily concerned about third party cookies generated by advertisers, you can turn these off by going to the Your Online Choices site at http://www.youronlinechoices.com/uk/your-ad-choices.

Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer, as well as more general information about cookies. Please note that, as these websites are not owned or operated by us, we are not responsible for any of the content on them.

Please be aware that restricting cookies may mean that you will not be table to take full advantage of all the features or services available on this website.

11. OUR MARKETING

We may collect your preferences to receive marketing information directly from us by email or phone in the following ways:

• if you register an account with us online, we will ask you if you would like to provide your consent to receive marketing information directly from us; or
• if you make a sales enquiry or place an order we may contact you with marketing information in the ways mentioned in the notices presented to you, except where you indicate you would prefer otherwise.

If you do not complete a purchase and have not indicated that you would prefer otherwise, we may send a reminder to you about your incomplete purchase.

If you complete a free trial or have an expired subscription, we may send you reminders and information about our system including new features which may interest you.

From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

We may contact you with marketing information by post or by telephone or with targeted advertising delivered online through social media and platforms operated by other companies by using your personal information, or use your personal information to tailor marketing to improve its relevance to you, unless you object.

You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see Withdrawing your Consent and Objecting to our use of your personal information and automated decisions made about you above for further details on how you can do this.

12. YOUR RIGHTS

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.

• Accessing your personal information
  
  You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
• Correcting and updating your personal information
  
  The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
  
  In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please update your details within your user account or let us know by contacting us in any of the details described at the end of this policy.
• Withdrawing your consent
  
  Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
• Objecting to our use of your personal information and automated decisions made about you
  
  Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
  
  You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.
• Erasing your personal information or restricting its processing
  
  In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
  
  You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
• Transferring your personal information in a structured data file (“data portability”)
  
  Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
  
  You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
• Complaining to the UK data protection regulator
  
  You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.

13. CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.

14. CONTACT US

Please direct any queries about this policy or about the way we process your personal information to our Data Protection Manager using our contact details below.

If you wish to write to us, please write to the address given at the start of this policy.

Our email address for data protection queries is support@edshed.com.

If you would prefer to speak to us by phone, please call +44 345 862 2806 from the UK or +1 888 254 3098 from the USA.