Privacy Policy

Introduction

This privacy and cookie policy sets out how VISUAL EDUCATION LIMITED T/A Wordwall uses and protects your personal data and uses cookies. This policy is provided in a layered format so you can click through to the specific areas set out below.

1. Important information and who we are
2. The types of personal data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Cookie Policy
11. Contact details
12. Complaints
13. Changes to the privacy and cookie policy and your duty to inform us of changes
14. Third party links
15. Artificial Intelligence Features

1. Important information and who we are

Privacy Policy

This policy gives you information about how VISUAL EDUCATION LIMITED T/A Wordwall collects and uses your personal data through your use of this website, including any data you may provide when you create and set up an account with us.

We do not intend that children should create an account with us. However, children may use our website.

Controller / Processor

VISUAL EDUCATION LIMITED T/A Wordwall (CN: 05900439) (collectively referred to as "COMPANY", "we", "us" or "our" in this policy) acts in two capacities concerning your personal data:

1. We control the personal data which we collect from you to facilitate your use of the website.
2. We process the personal data that you upload as part of your interaction with the services provided on the website.

If you have any questions about this policy, including any requests to exercise your legal rights, please contact the us using the information set out in the contact details paragraph.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username, password or similar identifier, title, date of birth, gender, school name, role, subject interests and school year.
• Contact Data includes address (i.e. billing address and delivery address), country, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, adverts, products and services.
• AI Interaction Data includes user inputs submitted to AI-powered features, AI-generated responses, and usage patterns of AI functionality within our platform.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

Please note that if as part of your interaction with the website you collect and upload any information as listed above relating to your students for activities including assignments and leaderboards you must have the appropriate grounds.

3. How is your personal data collected?

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

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • sign up for our mailing list
  • request support
  • apply for our products or services;
  • create an account on our website;
  • set assignments, add to leaderboards and share resources
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy at paragraph 10 for further details.
• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe Payments UK Ltd based inside the UK, Microsoft Azure which may be based outside the UK.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

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

Children's data

Our collection of children's data is limited to the child's name, the score they achieved in a game and their progress through an assignment. It is possible further information may be inferred about a child from the way in which a teacher names the resources that the teacher creates. The activities of a child on our website are tracked but the child's data arising from this tracking is completely anonymous provided that the child is not accessing our services through a signed-up account.

If, as a teacher or school, you require (or allow) children to add their personal data while accessing the content that you upload, you will likely be a data controller for the purposes of GDPR and you must ensure that you have the appropriate grounds to collect this personal data from children and keep this data confidential. As a teacher or school, you are solely liable and responsible for ensuring your compliance with GDPR.

Direct marketing

During the registration process on our website when you create and set up your own account and when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email: help@wordwall.net.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any email communication sent to you or by contacting us via email at help@wordwall.net.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to confirmation of a subscription, updates to our Terms and Conditions, checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see paragraph 10.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table within paragraph 4.

For details of the subprocessors we engage to process personal data on our behalf, together with the categories of data they process, their processing locations, and the contractual and transfer safeguards in place, please see our Subprocessors page.

• Each subprocessor agreement requires that subprocessors (a) process personal data only on our documented instructions; (b) implement technical and organisational measures equivalent to those described in this Privacy Policy; and (c) comply with all applicable data-protection laws. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 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.

We may share your personal data provided that we have your explicit instruction to do so for the purposes of, for example, integrating with a Virtual Learning Environment VLE provider or the purposes of Single Sign On SSO.

Please note that if your subscription has been purchased by a corporate body who have contracted with us for the provision of the service (e.g. under a whole-school site subscription service) then your data may be accessed by the particular corporate body.

6. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries or entities that have been deemed by the UK to provide an adequate level of protection for personal data, namely, countries or entities in Europe and the United States of America

7. Data security

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

All remote access to this website is conducted over HTTPS, an encrypted web link secured using Secure Sockets Layer (SSL). This is the same method used by banks and commercial entities to secure sensitive data from interception. We encrypt user data.

We store data on our secure database servers. Physical access to our servers is strictly limited. Access to the servers in the data centre requires proof of identify (photo ID) and is controlled by magnetic card readers and keys to both the cages and individual cabinets that surround the server racks, all of which are monitored by the data centre security staff using CCTV. Remote access to the data is limited to the tools needed by the IT support staff to maintain and operate the servers and is restricted to known users (identified by usernames and secure keys) connecting from known locations (IP addresses).

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

Personal data stored in a user account will be deleted if the account is left inactive for seven years. However, resources which a user has created, and which have been shared with the Wordwall community may be retained in accordance with our Terms of Use.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information. Please note that data for students may be deleted at any time by users through the dashboard.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• 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, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to 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 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.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • 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
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us see Contact details (paragraph 11).

No fee usually required

You will not 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 could 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 could 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.

10. Cookie policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You can find our most recent Cookie Policy here: https://wordwall.net/gu/cookie-policy

11. Contact details

If you have any questions about this Privacy Policy, the Cookie Policy, the Subprocessors page, or about the use of your personal data or cookies or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: privacy@wordwall.net
• Postal address: Visual Education Ltd, Lytchett House, 13 Freeland Park, Wareham Road, Poole, Dorset, BH16 6FA, United Kingdom.

12. Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

13. Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

14. Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy and cookie policy of every website you visit.

15. Artificial intelligence features

We use third-party artificial intelligence services to power automated content generation features within our platform, and enhance the user experience. When you use these AI-powered features, your input data is processed by our AI service providers to generate educational content, resources and games.

We may store your input data to improve the way we design and configure prompts for our AI service providers, to enhance the quality and relevance of AI-generated content. This data is not used to train the underlying AI models operated by those providers.

Third-party AI providers

For information on our AI service providers (subprocessors) please see our Subprocessors page.

User guidance

Please do not submit sensitive personal information, confidential data, or student personal details when using AI-powered features. You are responsible for reviewing and validating all AI-generated content before use.

Your rights regarding AI data

You have the same rights regarding your AI interaction data as described in paragraph 9, including the right to access, correct, delete, or withdraw consent for AI data processing.

AI content disclaimer

AI-generated content is automated and may contain inaccuracies. We do not guarantee the accuracy, completeness, or reliability of AI outputs. You remain responsible for verifying AI-generated educational content before use with students.