“Personal data” – Data relating directly or indirectly to an individual from which it is practicable for the identity of the individual to be directly or indirectly ascertained.
“Users” – Teachers and parents/guardians who register on our website become “Users”.
“Students” – “Users” may set up their students/children with accounts which enable them to access the games and will track their performance. “Students” cannot set their own account up.
When a teacher or parent/guardian sets up an account with Phonics Hero on behalf of their students, Phonics Hero acts as the “data controller”.
When you visit the Website or Mobile Application, we may collect two types of information from you: user data and usage data.
Personal data you knowingly choose to disclose that is collected on an individual basis or when you register on the Website for purposes of registering a Phonics Hero account. We collect this data either directly from a parent or via the school.
School details: school name and country.
Teacher data: name, email address, class they manage and password.
Student data: the names, class, teacher and school attended of the Students who will use Phonics Hero. Each student is issued an anonymous username, so the names are only collected for the ease of teacher management and monitoring. The school can anonymise the data if they so wish (first names, initials or codenames).
Parent data (only when parents sign up privately): name, email address, password and child’s name (first name or nickname can be used).
For parents, students and teachers, we do not collect any “special category” data which could be deemed sensitive, including: disabilities, race or ethnicity, religion, sexual orientation, political views, trade union membership and physical or mental health.
In respect of all nominated Student(s)’ use of the services of Phonics Hero whether at home or at school, we will collect the time and duration of all visits to www.phonicshero.com and student scores in all games.
When you look at this Website or Mobile Application, our service provider makes a record of your visit. This shows your domain name server address, operating system, browser type and the pages you have visited. We may also obtain information about your general internet usage to help us improve the Website by using “cookies” which are stored on the hard drive of your computer. Information gathered by using cookies may include the date and time of visits, the pages viewed, time spent at the Website, and the web sites you visited immediately before and after the Website. The service provider only discloses to us aggregate information about the number of visitors. We will only use the information for preparing statistics.
We also use information in aggregate form (so that no individual Student is identified):
Under no circumstances will we make an individual child’s information available to any third parties other than to the User who has nominated that child/student, or in accordance with such User’s instructions.
In our capacity as data controller, we will only use your personal information when the law allows us to. Typically, we will use your personal information in the following circumstances:
We use third party providers to administer our working relationship with you and other legitimate reasons. These are our third party providers:
Third party suppliers will be bound by contracts with us. Their access to your personal data will be limited to the above purposes. These suppliers conform to the GDPR regulations.
Phonics Hero will periodically delete accounts if they are unused. Data on users will be held for seven years. We hold this data for seven years as this is likely to be the period of time it will take your child to learn to read and spell, alongside the added years, in case they experience difficulties.
Schools and Parents can request the deletion of their student’s data at any point.
When registering as a User, you will be given the opportunity to opt-in to email communications from us. These emails will cover:
At any point you can choose to opt-out of these communications. You can do this by clicking the unsubscribe link in the footer of any email you receive from us, or by contacting us at firstname.lastname@example.org.
Phonics Hero also needs to send emails regarding account activation and forgotten passwords. These emails cannot be opted-out of as they are essential to ensure your continued access to our service. If you wish to stop receiving these, you will need to de-register. Please contact email@example.com to request de-registration.
Under the Hong Kong Personal Data (Privacy) Ordinance and the General Data Protection Regulation ((EU) 2016/679) (GDPR), as the owner of your data, you have the right of access, correction, deletion, transfer, deletion or restriction with respect to personal data (known as “data subject access request”). Request for personal data access and correction should be made to Phonics Hero in writing by emailing firstname.lastname@example.org. You will not have to pay a fee to access your personal information and we will acknowledge your request within two working days and provide the information within one month.
At any time you have the right to withdraw your consent to the collection, process and transfer of your personal information. To withdraw your consent please email email@example.com.
If our collection or use of information is unfair, misleading or inappropriate or you have concerns about the security of your personal information we welcome your feedback. You can email us at: firstname.lastname@example.org. If you are in the UK, you have the right to make a complaint to the Information Commissioner’s Office, at the following address:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, UK