Last Updated: July 28th, 2023
Contents
- Overview
- What does this Privacy Policy cover?
- What Personal Information do we collect from you?
- Cookies
- How do we use Personal Information collected from you?
- Who do we share your Personal Information with?
- Our legal grounds for processing Personal Information
- Where is your Personal Information stored and processed?
- How long do we keep your Personal Information?
- How do we secure your Personal Information?
- What about the privacy of children?
- Changes to this Privacy Policy
- Your rights
- Contacting us, further questions and how to make a complaint
1. Overview
This is the Website and Software Privacy Policy ("Privacy Policy") of Business with the distinctive title “Every Lesson Counts” located at 9 Town Lane, Bebington ch63 5jb, United Kingdom, and we are the data controller in respect of the Personal Information (as defined below) that we collect from you. It covers information our Business collects from users and visitors of our official website ("Site") and our entertainment software (“Software”), for mobile devices, personal computers and Internet-connected consoles.
When we use the terms "we", "us" or "our" we refer to the Business with the distinctive title “Every Lesson Counts”.
By accessing our Site or Software, you confirm that you have read and understood the entirety of this Privacy Policy.
You have various rights in respect of our use of your Personal Information as set out in the 'Your Rights' section below. Two of the fundamental rights to be aware of are that you may:
- ask us to stop using your Personal Information for direct-marketing by email. If you exercise this right, we will stop using your Personal Information in this regard; and
- ask us to consider any valid objections you have to our use of your Personal Information where we process your Personal Information on the basis of our, or a third party's, legitimate interests.
2. What does this Privacy Policy cover?
- We process certain information about you visit or when you use our service provided by our Site or Software. Some of that information may enable you to be identifiable ("Personal Information").
- This Privacy Policy explains how we collect, store and use your Personal Information when you visit or use our Site or Software. It also describes the types of Personal Information we collect, how we use this Personal Information to ensure we provide a relevant and timely Service to you, and to improve your experience.
3. What Personal Information do we collect from you?
| Information you submit to us | Visiting our Site or using our Software without registration | Technical Information (see below) |
|---|---|---|
| If you register with us via our Site or Software | First Name, Last Name, Date of Birth, Email address and password | |
| If you sign in via Social Media such as Facebook or Google |
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| If you use the messaging function |
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| If you enter a contest | If you go on to win a competition we may need your postal address in order to send you potential prizes. | |
| If you attend a Every Lesson Counts event |
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| If you contact us | Name, phone number or email address and any other Personal Information you provide to us in the course of our communication. | |
| Automatically Collected Information | Technical and Statistical Information |
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4. Cookies
We and our third-party partners, such as advertising networks, social media widgets, and analytics providers, use cookies and similar technologies to provide, support and improve "Every Lesson Counts" Service and each of the uses outlined and described in this Privacy Policy. Our partners also may collect information about your online activities over time, on other devices, and on other websites or apps. Those third parties may have their own privacy policies governing their use of your Personal Information. To switch off cookies, you need to change your browser settings. For further information about how to do this please visit http://www.aboutcookies.org/. Please note that if you choose to switch off cookies on your device that will mean certain functions of our Site and Software cannot operate properly and the usability of our Services will be affected.
Read our Cookie Policy to learn more.
5. How do we use Personal Information collected from you?
We, or third-party data processors acting on our behalf, use the Personal Information we collect from you in the following ways:
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To provide, develop, maintain, tailor and improve any services that we operate
For example, we might use your Personal Information to:
- verify your identity;
- allow access to the Site and Software;
- store information about preferences;
- customise the content on the Site or Software in order to provide a more suitable, enriching and improved user experience for you, including the online advertising displayed;
- ensure security of the Site or Software
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To conduct analysis and marketing activity
For example, we might use your Personal Information to:
- monitor the number of users using the Site or Software in certain geographical locations;
- provide advertisers, information providers and service providers with information on the types of advertisements and information which can or should be displayed or provided to you
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To protect you, us and others
For example, we might use your Personal Information to:
- promote safety and security, to protect you and your Personal Information;
- protect users of the Site or Software and our Business against threats such as fraud or cyber-attacks.
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To conduct direct marketing and promotion
For example, we might use your Personal Information to:
- contact you from time to time with material that we think may be of interest to you, unless you ask us not to; or
- advertise or promote new functions, events or news by sending e-mail newsletters to you.
All email newsletters include the option to unsubscribe. We will not provide your email address to any third parties for marketing purposes.
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To communicate with you
We may use your contact details to communicate with you in order to respond to queries you have raised with us.
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For other purposes
- for internal corporate reporting, Business administration, ensuring adequate insurance coverage for our Business, ensuring the security of Business facilities, research and development, and to identify and implement Business efficiencies;
- to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so;
- to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so;
- if you contact us on social media, to monitor your interactions with us and our brand online, where it is in our legitimate interests to do so for market research and for planning future marketing campaigns; or
- if we use your photograph or video footage from an event, to amplify the event to a broader audience and for internal presentation purposes, where it is in our legitimate interests for marketing and Business development purposes or where we have your consent.
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Anonymous data
We will anonymize or aggregate data collected and use and disclose it for any Business purpose. However, no single individual will be identifiable from the anonymised details we disclose for these purposes.
6. Who do we share your Personal Information with?
Trusted Partners: We may share your Personal Information with the following trusted partners and agents only if they need such information to perform their specific obligations or services to us. You may request a copy of the list of these partners by using the contact details here.
- The trusted partners, suppliers, sub-contractors and agents who cooperate with us to provide you with our Services and advertising, such as IT service providers, mailing houses and companies which store our data.
- The trusted partners, suppliers, sub-contractors and agents who cooperate with us to provide the Site or Software, or in collecting, storing or processing your information for us.
- Analytics and search engine providers, and research institutions and suppliers, that assist us in the improvement and optimisation of, and understanding of the use of and behaviour on, the Site or Software. For example, we may use Google Analytics to collect and process information about how our Services are used.
Other disclosures: We may also share your Personal Information with other organisations or individuals:
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If it is in our legitimate interests to do so to run, grow and develop our Business; in particular:
- if we sell or buy any business or assets, we may disclose your Personal Information to the prospective buyer or seller of such business or assets; or
- if all or substantially all of our assets are acquired by a third party, in which case Personal Information held by us will be one of the transferred assets.
- To meet any applicable law, regulation, legal process or enforceable governmental request.
- To enforce applicable legal terms and conditions or our other legal rights, including investigation of potential breaches of our Terms of Use.
- To detect, prevent, or otherwise address fraud, security or technical issues.
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To protect against or prevent harm to the rights, property or safety of Our Business, our users or the public as required or permitted by law.
Any such third parties are limited (by law and by contract) in their ability to use your Personal Information for any purpose other than to perform those obligations / provide their services. We will always require them to use your Personal Information in accordance with our instructions, with the terms of this Privacy Policy and any other appropriate confidentiality and security measures we require from them.
Except as detailed in this Privacy Policy, we do not rent, sell, or share personal information about you with other people or unaffiliated companies without notifying you and, where necessary, obtaining your permission. If you have given us your consent for us to use your Personal Information in this way, but later change your mind, you should contact us and we will stop doing so.
7. Our legal grounds for processing Personal Information
We may only process your Personal Information if we have a legal basis for doing so. This section sets out the legal grounds on which we rely in order to process your Personal Information.
We consider that the legal bases for using your Personal Information are as follows:
- use of your Personal Information is necessary to perform our obligations under any contract with you (for example, to comply with our Terms of Use which you accept by browsing the Site or using the Software);
- our use of your Personal Information is necessary for complying with our legal obligations;
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where neither of the above two legal bases applies, use of your Personal Information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of the Site or Software). Our legitimate interests are:
- to run, grow and develop our Business;
- to operate and secure the Site and Software;
- marketing, market research and development;
- to protect our users and Our Business from fraud or harm; and
- for internal group administrative purposes.
If we rely on our (or a third party's) legitimate interests for using your Personal Information, we will undertake a balancing test to ensure that our (or the third party's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of your Personal Information. You can ask us for information on this balancing test by contacting us.
Other uses of Personal Information (including special categories of Personal Information) may be subject to your consent (which you may withdraw at any time after giving it).
If we rely on your consent for us to use your Personal Information in a particular way, but you later change your mind, you may withdraw your consent by contacting us and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to provide services to you.
8. Where is your Personal Information stored and processed?
We will process and store your Personal Information in the locations of our servers.
We comply with applicable laws in respect of the international transfer of Personal Information.
If you are located in the European Economic Area ("EEA"), please note that we may transfer your Personal Information to locations outside the European Economic Area, including USA and Japan. Some of those locations may not offer a similar level of protection to European regulations. In these cases, we will ensure that there are adequate safeguards in place to protect your Personal Information in accordance with this Privacy Policy. These adequate safeguards include, in the case of entities based in countries outside the EEA (including Japan), entering into data transfer agreements with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries.
Further details on the steps we take to protect your Personal Information, in these transfer cases is available from us on request by contacting us at any time.
9. How long do we keep your Personal Information?
We will not keep your Personal Information longer than reasonably necessary to fulfil the purposes described in this Privacy Policy or as prescribed by law. In particular, we will implement a retention policy which stipulates the length of time we keep Personal Information. We will securely delete the Personal Information that we no longer need, and update, archive or securely delete Personal Information if it goes out of date. Therefore, we will retain any personal data related to your account for as long as you keep it open.
We do not retain the contact information you provide about others for matching purposes after we have performed the matching.
The length of time we retain Personal Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise of defend our legal rights.
10. How do we secure your Personal Information?
We take steps in an effort to treat your information securely and in accordance with this Privacy Policy. Unfortunately, though, the internet cannot be guaranteed to be 100% secure and, as such, you acknowledge and accept that we cannot guarantee the security of your Personal Information transmitted to the Site or Software and that such transmission is at your own risk.
Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
11. What about the privacy of children?
We recognise a special obligation to protect personal information about children. We urge parents to instruct their children to never give out their real names, addresses or phone numbers without permission when they are on line.
If parents believe that we have unintentionally collected their children’s personal information, they may request the deletion of the information by contacting us at hello@elcworld.co.uk.
12. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. We will post any Privacy Policy changes on our Site. Depending on the significance of the changes, we may display a more prominent notice. Please check back frequently to see any updates or changes to our Privacy Policy.
13. Your rights
You have various rights in relation to your Personal Information. In particular, you have a right to:
- obtain confirmation that we are processing your Personal Information and request a copy of the Personal Information we hold about you;
- ask that we update the Personal Information we hold about you, or correct such Personal Information that you think is incorrect or incomplete;
- ask that we delete Personal Information that we hold about you, or restrict the way in which we use such Personal Information;
- withdraw consent to our processing of your Personal Information, where we are relying upon your consent as our legal basis for processing such Personal Information;
- object to our processing of your Personal Information;
- prevent the processing of your Personal Information for direct-marketing purposes by email; or
- ask us to consider any valid objections which you have to our use of your Personal Information.
To exercise any of your rights, please contact us.
We will consider all such requests and provide our response within a reasonable period (and in any event any time period required by applicable law). Please note, however, that certain Personal Information may be exempt from such requests in certain circumstances.
14. Contacting us, further questions and how to make a complaint
If you have any queries about our collection, use or storage of your Personal Information, please contact our Business’s Data Protection Officer by email: hello@elcworld.co.uk
If you are unhappy with the way we handle your Personal Information, or any privacy query or request that you have raised with us, we would always prefer you to contact us first. However, you have a right to complain to the EU Data Protection Authority ("DPA") in the country where you usually live or work, or where an alleged infringement of privacy law has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.