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FlashAcademy App: Mobile Application Privacy Policy (for app users)

Learning Labs Limited (we) are committed to protecting and respecting your privacy.

SCOPE OF POLICY

This policy (together with our end-user licence agreement as set out at www.FlashAcademy.com (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

  • FlashAcademy mobile application software (App) available on our site or hosted on www.flashAcademy.com (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
  • Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites), unless the EULA states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

  • Where you are a consumer, we will be the data controller.
  • Where you are a school, you will be the data controller and we will be the data processor.
  • Where we are the controller, the data controller shall be Learning Labs Ltd for the purposes of the Data Protection Legislation.

We may change the Privacy Policy from time to time by amending this page.

INFORMATION WE COLLECT FROM YOU

We collect and process the following data about you:

Information you give us (Submitted information): You may give us information about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by e-mail or chat). This includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of our Sites. The information you give us will depend on how you make use of our services and will normally include your name, e-mail address and password.

Information we collect about you and your device. Each time you visit one of our Sites or use one of our Apps we may automatically collect certain information. By using the App or any of the Services, you agree to us collecting and using the following technical information about the devices you use the App on and related software, hardware and peripherals to improve our products and to provide any Services to you:

  • technical information, including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, (Device Information);
  • information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content, check ins, (Content Information);
  • details of your use of any of our Apps or your visits to any of Our Sites 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 (Log Information).

Location information. We may also use GPS technology or your IP address o determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by contacting us at team@FlashAcademy.com.

Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

If you contact us, We may keep a record of that correspondence.

Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

On what basis can we process your information?

The legal grounds for processing your personal data are as follows:

  • It is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you, namely in order for us to provide you with our Services, as set out in our Terms of Use at https://flashacademy.com/eula/
  • Where you have given us consent to the processing of your personal data for one or more specific purposes.
  • It is necessary for the purposes of our legitimate interests, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this, we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you. Our legitimate interests include the provision, improvement and promotion of our Services
  • Where we need to comply with a legal obligation; or in rare circumstances:
  • Where we need to protect your interests (or someone else’s interests); and/or
  • Where it is needed in the public interest or for official purposes

Cookies

We use cookies to distinguish you from other users of the App, App Site, Appstore or Service Site. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and Our sites.

Uses made of the information

We will hold and use personal information about you in the following ways:

  • To provide you with the App and our Service we will process your data as necessary to provide this, including to analyse and report on learning progress, assignment progress and general activity using the App.
  • To provide you with information about products and services we feel may interest you
  • Communicate with you during the course of providing our Services.
  • Statistical purposes so we can analyse figures to help us manage our business and plan strategically for the future.
  • Track your use of our Services including your use of our Sites, in order to personalise your repeat visits to our Sites and to administer and improve these.
  • To notify you about changes to our Services.
  • To ensure that content from our Sites is presented in the most effective manner for you and for your computer.
  • Respond to any complaint against us.

How long we keep your data for

We will keep your personal information for as long as you do not opt out of receiving marketing communications from us and for any time periods by law where we are under a legal obligation or entitlement to retain your data for longer, such as accounting and litigation purposes.

Disclosure of your information

We will disclose some or all of the data we collect from you when you download or use the App to the following third parties who provide us with services that we use as part of providing you with our Services: Google Play Services; Apple App Store/ iTunes Connect; Amazon web services; MongoDB Atlas; MixPanel; Facebook; BranchIO; Google Adwords.        

We may also disclose your information for educational reporting purposes or where legally required to, to educational bodies, such as the DfE, Local Authorities, Multi-Academy Trusts, Education Partnerships or Education Federations.

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 Companies Act 2006.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

We may also disclose your personal information to third parties:

  • 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.
  • If Learning Labs Limited or substantially all of its 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.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
  • In order to:
  • enforce or apply the EULA, Our Terms & Conditions at www.flashAcademy.com will be used to investigate potential breaches; or
  • protect the rights, property or safety of Learning Labs Limited, our customers, or others. This includes exchanging information with [other companies] and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The data that we collect from you is stored securely within the European Economic Area (EEA). There may be occasions where we need to send your data outside the EEA however. Some organisations may be located in countries outside of Europe where data protection laws are not as strict as they are in the UK. Where your personal data is being transferred outside the EU, we will undertake an assessment of the level of protection in light of the circumstances surrounding the transfer. We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information. For a copy of the measures we currently have in place for such transfers, please contact us at Learning Labs Limited, Birmingham Science Park, Holt Street, Birmingham, B7 4BB, England or team@FlashAcademy.com.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services detailed above will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 Sites; 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.

We may collect and store personal data on your Device using application data caches and browser web storage (including HTML 5) and other technology.

Certain Services may include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually 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 Learning Labs Limited, Birmingham Science Park, Holt Street, Birmingham, B7 4BB, England or team@FlashAcademy.com.

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Access to and update of your information

You have the right to access a copy of all personal data held about you free of charge You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent to team@flashacademy.com

Deleting your information

You can 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 you have withdrawn consent for us to process it (as explained 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.

How you can object to us using your data

You can ask us to limit the way in which we are using your information or object to certain types of processing. We will do our best to comply with your request unless we have to use the information for legitimate business or legal purposes.

Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing you with our service.

Any queries or concerns about the way in which your data is being used can be sent to team@flashacademy.com

Moving your information to another organisation

You have the right to request that we send a copy of the personal data we hold about you to another organisation in electronic format, for example when you are dealing with a different service provider. If you would like us to move, copy, or transfer your information to another organisation please let us know at team@flashacademy.com We will respond to you within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.

You have the right at any time to withdraw any consent you have given us to process your personal data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. Should you wish to do so you can contact us at any time via email to team@flashacademy.com

Changes to 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 by e-mail. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

Contact and your right of complaint

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Learning Labs Limited, Birmingham Science Park, Holt Street, Birmingham, B7 4BB, England or team@FlashAcademy.com.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office.  Further details can be found at www.ico.org.uk or by calling 0303 123 1113.