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KOMODO APP PRIVACY POLICY

This privacy notice (Privacy Notice) sets out the ways in which Komodo Learning Ltd (we, us, our) collect, use and share your personal data (your information) specifically in connection with your use of the Komodo app. 

Komodo Learning Ltd publishes digital learning resources. It provides the Komodo app via app stores for use on mobile devices.

This policy applies to the processing of your information by Komodo Learning Ltd as data controller. The data controller decides how your information is used and protected. We take your privacy and our responsibility to protect your information seriously and will take care in use and handling of your personal data.  Read our privacy notice to understand:

 

  • Who we are

  • Children

  • What information we collect about you

  • How we use information we collect about you

  • Who can see your information

  • When we share your information

  • How we look after your information

  • How long we keep your information

  • The cookies we use

  • International Transfers of your information

  • Rights and choices


WHO WE ARE

The Komodo Learning Ltd is a company registered in Northern Ireland (UK)  under company number, 206386904 with our registered address as set out below. 

FAO:     HEAD OF DATA PROTECTION

Address:   109-113 Royal Avenue, Belfast BT1 1FF, UK

Email:     ged@komodomath.com


CHILDREN

Parental consent

Use of the Komodo app requires parental consent. This is verified on registration and by requiring a card payment method.

COPPA

Komodo app is in complete compliance with COPPA

Third Party Data Sharing

Komodo App does not share or transmit personally identifiable information or device information to third parties.

School Use Exception

Where the Komodo app is paid for by a school to its pupils the teachers will have access to personally identified information of learners. Note that this does not apply when a family registers / pays for a subscription. Families may however opt to invite teachers to support their children in Komodo.

Advertising

The Komodo app does not include third-party analytics or advertising.

COPPA

Komodo app is in compliance with COPPA

GDPR

Komodo app is in compliance with GDPR

 

WHAT INFORMATION WE COLLECT ABOUT YOU

Information you provide

During your interaction with us as a registered subscriber to the Komodo app we collect information from Parents in order to manage the online account and to personalise the learning for the learner. The includes age information and information relating to the learners' individual learning needs. If you create a password it will be hashed so it is known only to the creator. Payment card information will be stored only by our payment provider Stripe.com in order to ensure maximum security protection.

Schools:

If you are a pupil and your school or college has provided information about you to us which we will process on your school’s behalf or for the purposes of providing services to you.

Learners, Parents

This information about you as a learner may include your contact details, your age and date of birth, your gender and any further information your parent has provided to help us assign appropriately personalised learning.

We collect information from parents when you:

  • create an account in our website;

  • subscribe to or accept access to  one of our digital platforms such as Komodo maths and Kickstart

  • are added as a teacher user to Komodo maths and Kickstart  our digital platform by one of your teacher colleagues   

  • subscribe to our newsletters

  • apply for technical support assistance 

  • interact or correspond with us by  letter, phone, SMS, email or via our website

  • complete one of our surveys

  • use our mobile devices or website applications (apps)

  • sign up to  attend events we hold or interact with us in person

  • submit contributions to our publications by post or via our website or our contact form

  • enter into a contract with us to publish an article or ebook

  • enter a prize competition or draw

  • submit  permission requests 

Protection of Personal Data

We will take all reasonable precautions to ensure that all the personal data that is submitted to us for the purposes above remains secure and have procedures to protect the storage and disclosure of personal data. You must ensure passwords are not shared and are kept securely. You are responsible for ensuring that personal data is transferred to us securely from your device.  


HOW WE USE INFORMATION ABOUT YOU

We use your information lawfully. We do not sell your information to third parties. 

However we may share your information as set out in the section 'When We Share Your Information'. The details of how we use your information and the legal bases for our use are set out below:

We may use such personal data collected to:

  • process your request, for example, to purchase products or access services and to administer your account

  • communicate with you and provide information about our products and services 

  • send you marketing communications about products, services, activities, promotions or other matters that we feel may be of interest or use to you

  • contact you about products you have bought or services you have subscribed to

  • communicate with you and your school to provide support services

  • analyse your use of our websites, our apps and response to our communications and improve the services we offer, including personalising our communications with you.

Pupil Information

If you are a pupil your school will have provided information about you to us which will process on its behalf in order to:

  • support your learning

  • monitor and report on your progress

  • assess the quality of our services

We will process your data for these purposes in accordance with instructions from your school and will report on the outcome of our services to your school.  We will not give information to any third parties (other than contractors providing services to us with whom we have an agreement) without the consent of your school.  Where possible we will anonymise personal data.

Teachers/Tutors

If you are a teacher or staff of a School or college, we will process your information provided to us by your School or by you:

  • to support you teaching and use of any digital platform products  

  • to process any orders you make for products and services on behalf of the School or Institution or on your own behalf as the case may be.

  • Obtain feedback from you in surveys relating to our products and services/ educational topics

When we have your consent to contact you, we may use your information to:

  • to keep in contact with you and provide you with marketing communications about our news and new products that we believe may interest you;

  • tell you about new website features or services;

  • send you newsletters;

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you, particularly where we process children’s personal data.  Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing you have rights and choices which include the right to object (please see the section headed ‘Your Rights and Choices’).

We may use your information for the purposes listed below on the basis of our legitimate interests:

  • to contact you about products you bought from us;

  • to contact you about submissions you made or content you provided to us;

  • to respond to your queries and correspondence;

  • to collect and store accurate data of our customers 

  • to administer your account with us;

  • to deal with enquiries or complaints  as necessary to provide customer support in providing the correct products and services to our website users

  • to analyse your use of our websites and apps and your responses to our communications;

  • to personalise, enhance, modify or otherwise improve the services and/or communications that we provide to you; 

  • to create our educational analysis tools

  • to mark assessment tests

  • to prepare aggregated benchmarks for the purpose of building educational tools and performance indicators  from the results of anonymised data


WHO CAN SEE YOUR INFORMATION

Any learner information resulting from your use of the Komodo app will be viewed only by staff of Komodo learning ltd. 


WHEN WE SHARE YOUR INFORMATION

We will not share personal information derived from use of the Komodo app outside Komodo Learning Ltd.


HOW WE LOOK AFTER YOUR INFORMATION 

We look for opportunities to minimise the amount of personal information we hold about you.  Where appropriate we anonymise and pseudonymise your information. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as: 

  • ensuring the physical security of our offices, warehouses or other sites;

  • ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;

  • maintaining a data protection policy for, and delivering data protection training to, our employees;

  • limiting access to your personal information to those in our company who need to use it in the course of their work and ensure it is kept behind a user password verification system.

You are responsible for ensuring that passwords are not shared and are kept securely.


HOW LONG WE KEEP IT FOR

We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our legitimate interests, such as for the purposes of exercising our legal rights or where we are permitted to do so for purposes of academic, literary expression and research purposes. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example:

  • we archive our email and paper correspondence regularly and destroy unnecessary information;

  • We operate a best practice email retention policy requiring password protected folders and departmental shared drives to provide restricted access to information;

  • We conduct regular access reviews to keep access profiles and policies up to date;

  • We conduct periodic review and purge cycles of documents in accordance with our document retention policy;

  • we retain information relating to orders, refunds and customer queries for approximately 7 years;

  • we retain information relating to commercial contracts for approximately 7 years after expiration or termination whichever is the sooner;

  • we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently;

  • in the case of Komodo maths, we will delete your account details 2 years after the end of your subscription period unless you request us to delete it earlier. 


THE COOKIES WE USE

We do not use cookies within the Komodo app. This is applicable to the website and company privacy policy.


YOUR RIGHTS AND CHOICES

Your Right to Object

You have the right to object to our using your information on the basis of our legitimate interests (refer to ‘How We Use Your Information’ above to see when we are relying on our legitimate interests). If you want to do this you can contact us using the details in the section 'Who We Are'.

Your Right to Withdraw Consent

The right to withdraw your consent for our use of your information in reliance of your consent (refer to section ‘How We Use Your Information’ to see when we are relying on your consent), which you can do by contacting us using any of the details in the section 'Who We Are'.

Your Other Rights and Choices

You also have other choices and rights in respect of the information that we hold about you, including: 

  • the right to request access to the information that we hold about you to check that we are acting lawfully;

  • the right to receive a copy of any information we hold about you in a structured, commonly-used, machine readable format or in another format of your choice;

  • the right to request that we transfer your information to another service provider in a structured, commonly used, machine-readable format;

  • the right to ask us to correct information we hold about you if it is inaccurate or incomplete;

  • the right to ask us, in certain circumstances, to delete information we hold about you;

  • the right to ask us, in certain circumstances, to restrict processing of your information.

You may exercise your rights and choices by contacting us using the details above 'Who We Are'.

You can also prevent processing for marketing activities by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing. 

Your Right to Complain

Please contact us if you have any questions or are unhappy about the way your information is used. We hope we will be able to resolve any problems or issues you may.

You also have the right to lodge a complaint about us and our use of your information to the UK Information Commissioner’s Office ( https://ico.org.uk/) or the relevant authority in your country of work or residence; 

CHANGES TO THIS PRIVACY NOTICE


We may make changes to this Privacy Notice from time to time. We will post any changes to our site.

This Privacy Notice was updated on 22nd April 2020.