By using the website, www.wriggle.ie, including all webpages containing that address, (the 'Website') including to place an order for our products or services, you permit the collection and use of your personal data and your child’s personal data as outlined below (last updated on 1 May 2017).
1.1 Our Website is operated by Wriggle Learning Limited, a private limited company registered in Ireland, with company number 591587 and having its registered address at Unit G6, Calmount Business Park, Ballymount Road, Dublin 12, D12 XW25 ('us', 'we', 'our'). Words such as 'you' and 'your' mean you or your child, as a user, of our Website.
2. WHAT INFORMATION DO WE COLLECT ABOUT YOU OR YOUR CHILD? 2.1. We may collect and process data you or your child provide to us, for example:
2.1.1. if you or your child contact us, we may keep a record of that correspondence;
2.1.2. information that you submit when you order a product or service from us, which may for example include: your name, your child’s name, your child’s school, your child’s school year, your child’s teacher, your child’s school subjects, you and/or your child’s email address, your child’s date of birth, you and/or your child’s address, you and/or your child’s telephone number, you and/or your child’s other contact details, payment details, delivery address(es) and billing address;
2.1.3. other information that you or your child submit when using the Website and our social media accounts (e.g. LinkedIn, Facebook and Twitter);
2.1.4. details of transactions you carry out with us whether via the Website or telephone, including (for example) your credit card, debit card or other payment account information; and
2.1.5. details of your visits and your child’s visits to the Website including, but not limited to: traffic data, IP addresses, alphanumeric IPs, operating system and browser type, device data, location data, volume and status of data transmission and other communication data and details of the resources that you or your child access.
3. USES MADE OF THE INFORMATION
3.1. We use data held about you or your child for the following purposes:
3.1.1. to ensure that content from Wriggle is presented in the most effective manner for you, your child and the device it is used on;
3.1.2. to use the registered email address or push notifications to notify you or your child about content changes, exciting new features and other information concerning the products or services ordered;
3.1.3. to create accounts with third parties, including but not limited to publishers and other internet service providers;
3.1.4. to use the queries you or your child send to us to provide you or your child with information that you or your child request, to assist with enquiries and to provide you and your child with a better customer service;
3.1.5. to process any transactions made through our Website or by telephone call with us;
3.1.6. to process any support requests (including technical support services and troubleshooting) from you or your child or queries submitted by you or your child to us;
3.1.7. to provide you with information via email regarding our other products or services which we feel may interest you or your child, where you have agreed to this by opting-in to such on the order form on our Website. We may use your email address for this purpose; you may choose not to receive emails of this type by using the unsubscribe link provided in the emails;
3.1.8. to carry out our obligations arising from any contracts entered into between you and us, including any related to products or service from us, and also for the purposes of resolving any complaints or disputes with you or your child or to enforce the Terms & Conditions;
3.1.9. to allow you and your child to access the Website;
3.1.10. to send you follow-up correspondence to confirm aspects of your order(s) or transaction(s) and to notify you about information regarding our contract with you or any product or service that you or your child have ordered or accessed;
3.1.11. to carry out our legal, regulatory and accounting obligations; and
4. DISCLOSURE OF YOUR INFORMATION TO OTHER PEOPLE
4.2. If you or your child provide personal data to us, you understand and agree that we may disclose such personal data to the following third parties:
4.2.1. one or more delivery or transport service providers, to manage the processing and delivery of products ordered;
4.2.2. your child's school;
4.2.3. one or more of our carefully selected publishers and educational software providers;
4.2.4. to our insurance partners, where you have selected to purchase gadget insurance;
4.2.5. any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries;
4.2.6. our professional advisors (for example, our accountants, lawyers and tax advisors);
4.2.7. our payment processor(s) that deal with payments connected with the Website;
4.2.8. to the prospective seller or buyer of any business, shares or assets related to the Website or all or part of Wriggle Learning Limited; and
4.2.9. to a third party if we are under a duty to disclose or share your personal data with that third party in order to comply with any legal obligation, or in order to enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of our group of companies, including but not limited to Wriggle Learning Limited. This includes exchanging information with third parties for the purposes of fraud protection and credit risk reduction.
4.3. W We do not disclose personal data about you or your child to third parties (including advertisers or marketing companies) unless you have consented to that disclosure and/or unless permitted by law. We may provide third parties (including advertisers or marketing companies) with aggregate anonymised information about users of the Website and/or our customers.
4.4. It may be necessary to transfer your personal data or that of your child’s to other group companies or service providers located in countries outside of the European Economic Area (EEA). This may happen where our servers or suppliers and service providers are based outside of the EEA or where you or your child uses our services and products while visiting countries outside of the EEA. The data protection and other laws of these countries may not be as comprehensive as those in Ireland or the EU but in these instances we will take steps to ensure that your privacy rights are respected. You agree that we may transfer your personal data and that of your child and on that basis you agree to this transfer.
5. CHILD SAFETY
5.1. Your child’s privacy is important to us.
5.3. Some of our products, including our digital books, are designed for use by children. However, use of the internet by children, including our Website, should only be done with the permission, guidance and supervision of the child’s parent or guardian. Please take note of any parental notices included on the Website, and direct and instruct your child in a way that is consistent with these notices. We do not knowingly collect information from children without seeking parental or guardian consent. Children should receive permission from their parent or guardian before gaining access to our Website or sending personal data to us.
SECURITY AND CONTROL OF INFORMATION
6.2. If you or your child is provided with a user code or any other piece of information in order to access parts of our Website, you must treat such information as confidential, and you must not disclose it to any third party. We have the right to disable, suspend or restrict any user code, at any time in our sole discretion.
6.3. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect you and your child’s personal data, we cannot guarantee the security of such data transmitted via the Website; any transmission is at your own risk. Once we have received yours and your child’s data, we will use procedures and security features on the Website to try to prevent unauthorised access. You acknowledge that we are not responsible for any intercepted information sent via the Internet, and to the extent permitted by law you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.
6.4. You should be aware that when you or your child voluntarily discloses personal data and agrees to make that information public on our Website or on our social media accounts, that information, along with any substantive information disclosed in such communication, can be collected, correlated and used by third parties. These third parties or other Website users or social media users may use your information or that of your child’s to send you or your child unsolicited messages. Such activities are beyond our control. Please do not post or allow your child to post any personal information on the Website, on our social media accounts or in other areas that you or your child wish to keep private.
7. LINKS TO THIRD PARTY WEBSITES
7.1. Wriggle may, from time to time, contain links to and from the websites of third parties to which we have no affiliation. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms and conditions and that we do not accept any responsibility or liability for those policies, terms and conditions or for the activities on those websites.
8. RETENTION OF DATA
8.1. Your personal data and that of your child’s will be kept for no longer than is necessary for the purpose(s) for which it was obtained, which is generally for as long as your child attends school, or, for so long as may be necessary in light of our legal obligations. Our stance is to keep data for an 8-year period to cover the normal 6-year school period and 2 additional years. All of our data is held securely on Office 365 which is stored on a Microsoft Azure server
9. YOUR RIGHTS AND UPDATING PERSONAL DATA
9.1. You are responsible for notifying us of any changes to your personal data (e.g. contact details) or that of your child’s, held or needed by us, as this is out of our control.
9.2. You and your child have rights under the Data Protection Acts 1988 and 2003 (as amended) and its replacement legislation being the General Data Protection Regulation (which comes into force on the 25 May 2018) and any implementing Irish legislation.
9.3. You may request in writing copies of your personal data and that of your child’s held by us as data controller. We will provide you with a copy of such personal data held by us as soon as practicable and in any event not more than one month after the request in writing is received by us. Generally we will not charge you to access such personal data, except where a request is, in our view, manifestly unfounded or excessive. We may also request proof of identification or status as parent or guardian to verify your access request. All access requests should be addressed to Liam O’Donovan, Operations & Finance Manager at firstname.lastname@example.org.
9.4. We endeavour to keep the personal data you and your child provide to us as accurate, complete and up to date. If you know that personal data that we hold about you and/or your child is inaccurate, incomplete or out of date you should let us know and we will make the necessary amendments, erase or block the relevant personal data. You also have the right to request that we erase past personal data (i.e. “the right to be forgotten”) under certain conditions. All requests should be addressed to Liam O’Donovan, Operations & Finance Manager at email@example.com.
9.5. At any time, you may object to the processing of your personal data and/or that of your child’s, and may request that we block specific uses of such personal data by contacting Liam O’Donovan, Operations & Finance Manager at firstname.lastname@example.org. We must comply with these directions, except in limited circumstances permitted by applicable laws.
9.6. You and your child also have the right to data portability in order to transfer your/their personal data to another data controller in a structured, commonly used, and machine readable format, subject to certain conditions and we may issue guidance or information about these transfers from time to time which are available from us upon request. Please contact Liam O’Donovan, Operations & Finance Manager at email@example.com to exercise this right or request further information.
9.8. You also have the right to complain to the relevant data protection supervisory authority with respect to how we process such personal data.
11. USER FEEDBACK AND COMPLAINTS