Privacy Policy

1. About This Document

1. This Privacy Policy explains what happens with any personal data we gather in relation to:
   1. your use of our website at www.lettersandsoundsphonics.com (our "website");
   2. your use of our Grow the Code software and subscription service (the “Service“); and
   3. any customer service or other enquiries you submit to us.
2. We recognise our obligations under data protection legislation and we are committed to keeping personal data safe and secure. You should read this Privacy Policy so that you understand how we will handle your personal data.
3. Our aim is to only use and hold your personal data in ways that you would reasonably expect us to.
4. We reserve the right to amend this Privacy Notice from time to time. If we amend this Privacy Policy we will make you aware of this via updates posted on our website.
5. If you have a Subscription to use the Service, this Privacy Policy should be read in conjunction with our Subscription Agreement. 

2. Our Grow the Code service and Privacy Policy are provided by:
Australia:Smart Kids Education Limited, registered number ARBN 169 891 114 with our registered office at Suite 303, Level 3, 12 Mount Street NORTH SYDNEY NSW 2060 (the "Company" or "we", "us" or "our").
New Zealand (and rest of the world):Smart Kids Education Limited, registered number 9429037872236 with our registered office at 7 Mono Place, Mt Wellington, Auckland 1051, New Zealand (the "Company" or "we", "us" or "our").
United Kingdom:Smart Kids (U.K.) Limited, Registered in England & Wales Company No. 03525873, Registered office: Elizabeth House, 13-19 London Road, Newbury, Berkshire, RG14 1JL
If you have any questions regarding this Privacy Notice or how we process your personal data please contact our Data Protection Representative at: privacy@growthecode.org

3. What personal data do we gather?

1. “Personal data” is any information about an individual from which that individual can be identified. It does not include data from which an individual cannot be identified, for example anonymised data.
2. The types of personal data we may collect, use, store and transfer consist of the following:

• IP address
• Individual contacts at Schools or organisations who have subscribed to use the Service. 
• User of the Service: (e.g. an individual teacher) Full name, e-mail address, access credentials, usage data.
• Students and pupils whose personal data may be uploaded to the Service or captured by the Service: Name, class details, educational attainment information (e.g. progress and results of assessments etc).

4. How do we collect personal data?

1. We may collect personal data about you from the following sources:
   1. Information you provide to us via our website; and
   2. Information that is provided to us when you register to use the Service; and
   3. If you are a User of the Service, information that is provided to us by your School (e.g. to enable you to use the Service); and
   4. Information which is uploaded to or captured by the Service when it is used (e.g. information concerning students and pupils and their educational attainment).

   5. How do we store personal data and keep it secure?
   

1. We use reasonable and up to date security methods to:
   1. keep data secure; and
   2. prevent unauthorised or unlawful access to personal data; and
   3. prevent the accidental loss of or damage to personal data.
2. All personal data provided to us is stored on secure Microsoft Azure servers in the USA.
3. We have in place policies, procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction including procedures to deal with a security breach.
4. We will ensure your personal data is only accessible by those who need to see it for their specific role.
5. We will only transfer personal data to a third party if that third party agrees to comply with our procedures and policies or if they have put in place equivalent policies and procedures of their own.

6. How and why we will use personal data?

1. We will usually only process personal data where:
   1. the processing is necessary to comply with our legal obligations;
   2. the processing is necessary for the performance of a contract (e.g. our Subscription Agreement to use the Service);
   3. the processing is necessary for our legitimate interests or the legitimate interests of third parties; or
   4. the processing is necessary for the exercise or defence of legal claims.
2. Where the legal reason for processing is the performance of a contract with you, if you do not provide relevant personal data we will not be able to fulfil our contractual obligation(s) to you and this may have a detrimental impact on you.
3. We do not sell or rent personal data which you provide to us.
4. If you have any questions about the contents of the above (for example, if you would like to understand what our “legitimate interests” are for any specific processing activity) please contact our Data Protection Representative at privacy@growthecode.org
5. The list below provides examples of the various ways in which we may use personal data and the reasons we rely on when processing personal data:

• To assist or improve the individual’s use of the website.
• To provide the Service for use by the School or organisation.
• To process payments for Subscription Fees.
• To enforce the terms of our Subscription Agreement.
• If an individual contact at a School or organisations who has subscribed to use the Service has consented, to provide them with information about our products and services, promotions and offers. 
• If a user of the Service (such as a teacher) needs access to the Service; to improve the Service and the user experience; to ensure all use of the Service is properly licensed and compliant with our Subscription Agreement. 
• Students and pupils (whose personal data may be uploaded to and captured by the Service) To provide the Service; to improve the Service and the user experience. 

7. How we keep personal data accurate?

1. We will keep the personal data we store accurate and up to date.
2. We will take every reasonable step to erase or rectify inaccurate data without delay.
3. Please tell us if your personal details change or if you become aware of any inaccuracies in the personal data we hold about you or for you.
4. We will contact you if we become aware of any event which is likely to result in a change to your personal data.

8. How long will we keep your personal data?

1. We will not keep your personal data for longer than is necessary for the purpose(s) for which we process it.
2. This means that data will be destroyed or erased from our systems when it is no longer required.
3. For guidance on how long certain data is likely to be kept before being destroyed, contact our Data Protection Representative privacy@growthecode.org

9. What rights do you have in respect of your personal data?

1. You have the right to:
   1. request access to any personal data we hold about you;
   2. request that any inaccurate personal data we hold about you is rectified;
   3. request to have your personal data erased;
   4. request to have the processing of your personal data restricted (for example, if you think the personal data we hold about you is inaccurate you can ask us to stop processing it until we will either correct it or confirm it is accurate);
   5. object to certain types of processing, including processing based on legitimate interests, automated processing and processing for direct-marketing purposes; and
   6. withdraw consent to the processing of your personal data (where the legal reason for the processing of your personal data was your consent).
2. If you wish to exercise any of the rights set out above, you must make the request in writing to our Data Protection Representative. Please      note some of these rights are restricted in some circumstances privacy@growthecode.org

10. Automated decision-making

1. We do not conduct automated decision-making (including profiling) in connection with your personal data.

11. Who will have access to the data we hold?

1. Our personnel who need to access your personal data will view it in order to provide our services to you and provide you with any      information you have requested. All of our personnel understand the need to keep your personal data confidential and to use it only for legitimate purposes.
2. In addition to our own personnel, other personnel from our service providers may process personal data on our behalf (for example, third      party hosting companies; external software developers who assist us to further develop the Service).
3. We may disclose your personal information to third parties:
   1. if we or substantially all of our assets are acquired by a third party, in which case personal data held by us will be one of the transferred       assets; 
   2. if we are under a duty to disclose or share your personal data in order to comply with legal obligations or to protect the rights, property or safety of others; 
   3. If you or your school has entered into an agreement with that third party which entitles the third party to access your personal information.
4. If your personal data is provided to any third parties you are entitled to request details of the recipients of your personal data or the      categories of recipients of your personal data.
5. Apart from the situations referred to above, we will not disclose your personal data to a third party without your consent unless we are      satisfied that they are legally entitled to access your personal data.

12. Cookies

1. You can configure your browser to block, disable or delete cookies.  However, if you use your browser settings to block all cookies (including      essential cookies) you may not be able to access all or parts of our Website or Service.
2. Our website and Service may use cookies to distinguish visitors and users of our website and Service. These cookies sometimes process personal data. This helps us to provide you with a good experience when you browse our website or use our Service and also allows us to improve our website and Service.
3. Information about the specific cookies we use and the purposes for which we use them:

• We use session cookies to remember who is logged into the Service when they use the Service. 
• We also use functionality cookies to remember what settings have been selected when Users use the Service as well as which school last logged in to the service from a machine. 

13. Right to make a complaint

1. If you have any issues with our processing of your personal data and would like to make a complaint, you may contact us via our Data      Protection Representative  privacy@growthecode.org or your local Commissioner’s Office.