Privacy Policy for LetterSchool

(Last updated January 31 2019)

Introduction

Welcome to LetterSchool – the #1 app for children for learning to write!

This privacy policy is intended for the users & schools of the LetterSchool – Block letters & LetterSchool – Cursive Letters.

For the privacy policy of the website and the free app, please click here.

At LetterSchool, we are committed to protecting you and your family’s personal information. We want LetterSchool to be a safe and enjoyable environment for everyone. In this Privacy Policy, we’ll explain the what we do with the information you give us and which we may collect from you as part of providing the LetterSchool service.

The LetterSchool app is designed for 3-8 year old kids and we have drawn together this Privacy Policy for you, the parent or guardian.

LetterSchool does not seek to collect any personally identifiable information directly from children under the age of 13.  If you are under 13, please do not submit any personally identifiable information to LetterSchool .

This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States and Latin America regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online.

We also comply with the Dutch Data Protection Act (Algemene verordening gegevensbescherming), the Dutch Telecommunications Act (Telecommunicatiewet) and the European General Data Protection Regulation (“GDPR”).

Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information about the personal information relating to you (your personal data) which LetterSchool collects about you – and what we do with it. This includes any data you provide during the sign up process, use of the LetterSchool app or website, or by signing up to our newsletter.

There may be specific occasions when we collect or use personal data about you and we may provide further information on what information we are gathering and why. This Privacy Policy is designed to supplement any other notices and won’t override them.

LetterSchool does not seek to collect any personally identifiable information directly from children under the age of 13.  If you are under 13, please do not submit any personally identifiable information to LetterSchool .

LetterSchool as Controller

LetterSchool is the trading name of Letterschool Enabling Learning BV, a Dutch company with office at Kabelweg 21, 1014BA, Amsterdam, The Netherlands.

A Controller is the person or entity which decides the purposes for which any personal data will be used. As LetterSchool the LetterSchool app and the data collected and used to allow you your family access to the app, LetterSchool is the data controller and responsible for your personal data.

Contact details

Full name of legal entity:  Letterschool Enabling Learning B.V.

Email address: [email protected]

Postal address: Pierre Lallementstraat 742, 1097JR Amsterdam, The Netherlands (our office is at Kabelweg 21, 1097JR, Amsterdam, The Netherlands)

If you have any questions about this Privacy Policy, or if you would like to exercise any of the rights to which you are legally entitled (see information on this, below), please contact us using the details set out below.

You have the right to make a complaint at any time to the Autoriteit Persoonsgegevens (APG), the Dutch supervisory authority for data protection issues (https://autoriteitpersoonsgegevens.nl/en). We take data protection issues very seriously at LetterSchool and are confident that the processes we have in place will keep your personal data safe. If, however, there are any issues, we would really appreciate the chance to resolve anything that’s concerning you, before you approach the ICO.

Changes to the Privacy Policy

The date of the latest version of the Privacy Policy is set out above. We have recently refreshed our Privacy Policy following a change in the law on data protection, although because we have always safeguarded your data, we have not had to make any changes operationally. Our Privacy Policy will be updated from time to time – you can always come back here and check for any changes. Alternatively, any material changes to the Privacy Policy will be highlighted in our newsletters if you choose to receive them, or flagged within the LetterSchool app.

Third-party links

Our website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. When you leave our website, be sure to read the Privacy Policy of any website you go to – we don’t control these third-party websites.

The data we collect about you

Personal data, or personal information, means any information about an individual which can identify that individual. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together into the following categories:

• Identity Data We only collect Identity Data when you contact us through our customer support. By only using the app we don’t collect your first name and last name. LetterSchool does not seek to collect any personally identifiable information directly from children under the age of 13.  If you are under 13, please do not submit any personally identifiable information to LetterSchool .
• Contact Data includes any email address which you might provide to us, for example when signing up to the newsletter or mobile phone number if you registered via one of our mobile operator partners. You can use the LetterSchool app without providing us any contat data.
• Technical Data includes your browser type and version, user agent, time zone setting and location, operating system and platform.
• Profile Data includes your preferences and any feedback or survey responses.
• Usage Data includes information about how you use our website and the LetterSchool applications. Please note that this may include personal data relating to your child’s use of the LetterSchool app e.g. records of content they have interacted with.
• Marketing and Communications Data includes whether you would like to receive newsletters or other promotions from LetterSchool.

Please note that any processing of financial data is carried out by the payment provider chosen by the user e.g. ITunes, Google Play etc. As such, LetterSchool does not collect, store or have access to any financial data.

We also collect, use and – where necessary to provide the LetterSchool service – we might share what we will call Aggregated Data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data (using the definition above) to calculate how many users are using a particular feature of the LetterSchool app. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, then we treat the combined data as personal data – which will always be used in accordance with this Privacy Policy.

We do not collect any data which is not necessary to provide the LetterSchool service to you.

How is your personal data collected?

If you would like to create a LetterSchool account, then we will need some contact data from you – we will never ask for your child’s name or child’s contact data. If you don’t provide that contact data, then you still will be able to play and use LetterSchool – although some functionalities might not be available.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • create an account on our website or on our app;
  • request newsletters to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with the LetterSchool App and our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, automated event logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may receive data about you from various third parties as set out below:
  • Technical Data from the following parties:
    (a) advertising attribution networks such as Adjust based outside the EU; and
    (b) analytics providers such as Google based outside the EU
  • (c) email providers such as Customer.io based outside the EU
• Transaction Data from providers of technical, payment and delivery services such as Apple, Google based outside the EU.
• Authentication to LetterSchool via single sign on providers such as Facebook.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the circumstances set out below. These are called lawful bases for processing:

• For performance of a contract with you – where you have requested access to the LetterSchool app and we use your contact data to set you up as a subscriber, or an account holder (if you create a LetterSchool account) and provide the service to you and your family.
• Where we need to comply with a legal obligation.
• Where it is necessary for our legitimate interests(or those of a third party) to manage the LetterSchool app to ensure the best service/product and the best and most secure experience. We will always make sure we balance any legitimate interest against any potential impact on you.

We do not generally rely on your consent as a legal basis for processing your contact data (except for marketing, on which see more below). We only use your data where it’s necessary to provide you with the LetterSchool service you have asked to receive – so, we are using your personal data to enable us to perform our contractual obligations to you. It is, however, important to LetterSchool that you have understood and agree with what

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 your personal data, and which of the legal bases we rely on to do so. We have also explained what our legitimate interests are, where relevant.

We might process your personal data for more than one lawful basis depending on the situation – as explained in the table below. If you would like further detail on any of the information set out below, please get in touch.

Purpose/Activity	Type of data	Lawful basis for processing
To create a LetterSchool account for you	(a) Contact	Performance of a contract with you
To manage our relationship with you, which might include asking you to leave a review or take a survey	(a) Contact (b) Profile (d) Marketing and Communications	(a) Performance of a contract between us (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to participate in a promotion, competition or complete a survey	(a) Contact (b) Profile (c) Usage (d) Marketing and Communications	(a) Performance of a contract between us (b) Necessary for our legitimate interests (to study how customers use the LetterSchool app)
To administer and protect the LetterSchool app and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Contact (b) Profile (c) Usage (d) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage (c) Profile	(a) Performance of a contract between us (b) Necessary for our legitimate interests (to keep the LetterSchool app and our website updated and relevant, to develop our business and to inform our business strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Contact (b) Technical (c) Usage (d) Profile (e) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing and opting out

We want to provide you with choices regarding certain personal data uses, particularly around marketing. Where you have provided your consent, we will send you newsletters. You can tell ask us to stop sending you newsletters whenever you would like to, by using the contact details above, or by using the opt-out link in the newsletters we send.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the LetterSchool app and website may become inaccessible or not function properly.

Cookies are small text files that we place in visitors’ computer browsers to store their preferences. Our cookies themselves do not contain any personal data. Our cookies may reference the personal data you provided during registration. We reference the information you provided via an encrypted identifier. Where we link these unique identifiers with your personal information, we will treat the unique identifiers as personal data as long as they are linked.

We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate LetterSchool. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your internet browser’s “help” file.

When your kids use LetterSchool, we collect certain non-personal information by placing and accessing LetterSchool cookies on the device they are using. Cookies do not contain any personal data, so we do not use cookies (or other covert or non-consensual methods) to acquire contact information about your kids or other users of the device.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that that we need to use it for another purpose which is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will let you know and we will explain the legal basis which allows us to do so.

Please note that where we have to carry our processing where required by the law, we may process your personal data without your knowledge or consent.

Disclosures of your personal data

We may have to share your personal data with third parties set out below, for the purposes set out in the table in paragraph 4 above.

• Service providers acting as processors based both inside and outside the EU who provide IT and system administration services
• Cloud infrastructure providers such as Google, based outside the EU
• Analytics and event tracking providers such as Google Analytics, based outside the EU
• Advertising attribution networks such as Adjust based outside the EU
• Email providers such as Customer.io based outside the EU
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may acquire or merge with other businesses. 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 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.

International transfers

Some of our external third parties are based outside the European Economic Area (EEA) – which is all EU member countries as well as Iceland, Liechtenstein and Norway. So, their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we make sure that similar levels of protection are in place. Below are some examples of how we do this:

• We will only transfer your contact data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts which may have been approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you would like further information regarding the transfer of your personal data out of the EEA.

Data security

We have put in place security measures to prevent your contact data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Additionally, 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.

Via the app, we encrypt the transmission of Personal Information using secure socket layer technology (SSL). We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. If you have any questions about security on our site, please contact us at [email protected]

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• 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.
• 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.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you feel the processing 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.
• 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your 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.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not usually 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 may 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 may 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.

Contacting Us

If you wish to contact us about any privacy questions or concerns you may have, please do contact our team via the website.

You can also write to us at our parent company, Letterschool Enabling Learning, at our postal address:Pierre Lallementstraat 742, 1097JR, Amsterdam, The Netherlands).