This privacy policy (together with our Terms of Use and any documents referred to in them) sets out the basis on which we process any personal data that we collect about you and the children in your care or that you teach, using the Gooseberry Planet apps (“Apps”) and any of our other Platforms or services available through the Apps, Platforms or our website, www.gooseberryplanet.com (“Website“). Please read this privacy policy carefully. By using our Platforms, Website and/or downloading an App (together referred to as the “Platform” or “Platforms”) and ticking the box to accept our terms of use (which incorporate this privacy policy) you confirm that you accept this privacy policy. References to “you” and “your” are to the parent/legal guardian or other person (as applicable) that has downloaded an App or registered on the Platform.  The relevant school or other organisation is responsible for its staff using the Platforms.

Protecting personal data is very important to us and the use of a Platform by a child is subject to the consent of their parent or legal guardian.

For parents and legal guardians

By downloading and registering to use any Platform, you consent to us using your data, as well as the data of the children you register or allow to use a Platform, for the purposes of providing the Platform, as set out in this privacy policy.

For teachers

By using any Platform, you consent to us using your data, as set out in this privacy policy.
By registering or allowing children to use a Platform, you confirm that you have obtained consent from the children’s parents or legal guardians for their child to use a Platform and for us to use their data in accordance with this privacy policy. We need you to obtain this consent because children are unable to give consent for themselves.

For teachers, governors and other staff

By using any Platform, you consent to us using your data, as set out in this privacy policy.

WHAT INFORMATION DO WE COLLECT ABOUT YOU AND YOUR CHILDREN, AND WHY?

Information you give us

The Platforms obtain the information you provide when you download and/or register on them. Registration with us is mandatory in order to be able to use a Platform.

When you register with us and use a Platform, you generally provide: (a) your name, email address, age (to confirm you are 18 or over), user name, password and other registration information; (b) a name and an email address for each child using an App, if using the Gooseberry Play App (in order for them to log in separately and for you to monitor each child’s progress) and the child’s year group at school if using the Gooseberry Student App (to check age appropriateness); (c) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications from us; (d) information you provide us when you contact us for help; (e) credit card information for purchase and use of a Platform (if not dealt with through an appstore); and (f) information you enter into our system when using a Platform, such as contact information.

We may also use the information you provide to us to contact you from time to time to provide you with important information, required notices and marketing promotions from us about our own products if you have opted in.

Automatically collected information

In addition, the Platforms may collect the following information automatically:

•    technical information including the type of mobile device you use, your mobile device’s unique device ID, the internet protocol (IP) address of your mobile device, your mobile operating system and the type of mobile internet browsers you use (in order to ensure the Platforms are presented in the most effective way for you and your device); and

•    information about the way you use any of the Platforms or your visits to our Website including time spent using a Platform, time spent on a particular level and other interaction information (in order to improve the service we provide to you and to report progress to you as teachers and parents/legal guardians).

Information we receive from other sources

We may receive information about you and your children if you use our Website or other services we provide. Such data may be combined with data collected from the Platforms and used in the same way as set out in this privacy policy.

Cookies

Our Platforms use cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our Platforms and also allows us to improve them.  A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device. Cookies contain information that is transferred to your device’s hard drive.

We use the following cookies:

•    Strictly necessary cookies. These are cookies that are essential for the operation of our Platforms. They include, for example, cookies that enable you to log into the Platforms and use our services.
•    Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Platforms when they are using them. This helps us to improve the way things work, for example, by ensuring that users are finding what they are looking for easily.  We may also use Google Analytics, a web analysis service provided by Google, Inc. which sets a number of cookies in order to provide us with information around your use of our services.
•    Functionality cookies. These are used to recognise you when you return to our Platforms. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You 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 Platforms.

Do the Apps collect precise real time location information of the device?

The Apps do not collect precise information about the location of your mobile device.

DO THIRD PARTIES SEE AND/OR HAVE ACCESS TO YOUR INFORMATION OBTAINED BY THE APPS OR OUR WEBSITE?  Only aggregated, anonymised data are periodically transmitted to external services to help us improve the Platforms, and our service.  Third parties will not be able to identify you from such data.  We will share your information with third parties only in the ways that are described in this privacy policy.

We may disclose your information:

•    If we are required to do so by any legal or regulatory obligation or request;
•    When we believe in good faith that disclosure is necessary to protect the rights, property or safety of our business, our customers, or others.  This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
•    With our trusted service providers who work on our behalf (for example, our lawyers), who do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement;
•    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 we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
•    In order to enforce or apply our Terms of Use and other agreements or to investigate potential breaches.

Our Platforms may, from time to time, contain links to and from other websites.  If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them may have their own privacy policies and that we do not accept any responsibility or liability for these policies or the websites.  In particular, our Safeguarding CPD has been developed using a Platform provided by LearnUpon Limited (“LU”).  LU will have access to information provided by you while visiting their website.  Their privacy policy is available at www.learnupon.com/privacy-policy.  We do not accept any responsibility or liability for their policy or website.

WHERE DO WE STORE YOUR PERSONAL DATA?

The personal information that we collect from you will be stored by us on servers in the European Economic Area and will not be processed or transferred by us outside of the European Economic Area.  LU may store your data outside the EEA.

YOUR OPT-OUT RIGHTS

You can stop all collection of information by the Platforms easily by uninstalling the Apps or ceasing to access the Platforms. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.  You can also request to opt-out of marketing emails from us by selecting the opt-out option at the bottom of such email or by emailing us at privacy@gooseberryplanet.com.

ACCESS TO YOUR INFORMATION

The Data Protection Act 1998 gives you the right to access information held about you.  Unlike many organisations, we will not charge you when providing you with the details of the information we hold about you.  You can make a request for this information by contacting us by email at privacy@gooseberryplanet.com or by post at Gooseberry Planet Ltd, Unit 8, Rooks Farm, The Street, Rotherwick, Hants, RG27 9BG.

DATA RETENTION POLICY, MANAGING YOUR INFORMATION

We will retain information you give us for as long as you use the Platforms and for a reasonable time thereafter.  We will retain automatically collected information for up to 24 months and thereafter may store it in aggregate.  If you’d like us to delete the information you have given to us via the Platforms, please contact us at privacy@gooseberryplanet.com and we will respond in a reasonable time.  Please note that some or all of the information you give us may be essential in order for the Platforms to function properly.

SECURITY

We are concerned about safeguarding the confidentiality of your and your children’s information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain.  For example, we limit access to this information to authorised employees and contractors who need to know that information in order to operate, develop or improve our Platforms.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.  Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data whilst it is transmitted to us.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

CHANGES

This privacy policy may be updated from time to time for any reason and changes will be posted on this page.  Where we make any major changes to our privacy policy we will notify our registered users via email or text message.  You are advised to consult this privacy policy regularly for any changes, as continued use of the Platforms is deemed approval of all changes.

CONTACT US

If you have any questions regarding privacy while using a Platform, or have questions about our practices, please contact us via email at privacy@gooseberryplanet.com or phone on +44 (0)1865 366 468 or by post to Gooseberry Planet Ltd, Unit 8, Rooks Farm, The Street, Rotherwick, Hants, RG27 9BG.  We have notified the Information Commissioner’s Office about our data processing activities under notification number ZA194101.