Prompt Privacy Policy

Last Updated: January 2024

Important information and who we are

This Privacy Policy gives you information about how Prompt collects and uses your personal data through your use of this our mobile application and/or website (together the “Prompt Platform”), including any data you may provide when you register with us or sign up to our newsletter. 

The Prompt Platform is intended for use by children and both the Prompt Platform and this Privacy Policy has been designed to take into account the UK Information Commissioner’s Children’s Code. Where we ask for consent to process your personal information, this consent must be given by the relevant parent or guardian.

Controller

Teaching Applications Limited is the controller and responsible for your personal data (collectively referred to as “Prompt”, “we”, “us” or “our” in this Privacy Policy).

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights mentioned below, please contact the us using the information set out in the contact details section below. 

  1. 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 may include first name, last name, username or similar identifier, title, date of birth and gender, if you provide this information.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data may include bank account and payment card details.
  • 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 Prompt Platform. 
  • Profile Data may include your username and password, purchases or orders made by you or any child associated with your account, the history of your their interactions with the Prompt Platform, and certain data associated with their learning profile.
  • Usage Data includes information about how you interact with and use our Prompt Platform, products and services. 
  • 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 app or website feature in order to analyse general trends in how users are interacting with our Prompt Platform to help improve the Prompt Platform and our service offering.

  1. 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:
  • apply for our products or services;
  • create an account on our Prompt Platform;
  • subscribe to our service or publications; 
  • request marketing to be sent to you; or
  • give us feedback or contact us. 
  • Automated technologies or interactions. As you interact with our Prompt Platform, we may 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 for further details.
  • Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
  • 2. How we use your personal data

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 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.

Direct marketing 

During the registration process on our Prompt Platform when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Prompt via email or SMS. 

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. 

Opting out of marketing 

You can ask to stop sending you marketing communications at any by following the opt-out links within any marketing communication sent to you. 

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

01. Cookie Policy

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy

02. Disclosures of your personal data

We do not share personal information about you with other people or non-affiliated companies except under the following circumstances: 

03. Data processors: we will disclose your personal information to our appointed third party data processors, including for the purposes of providing online and other payment services, handling credit checks and fraud prevention, cloud storage and any other services required in order for us to use your information for the purposes specified in this Privacy Policy.

04. Regulatory and/or authority disclosures: We will disclose your personal information to any law enforcement agency, court, police, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, to protect our rights or the rights of any third party or is otherwise in the public interest. 

05. Business and/or share sales: 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 Privacy 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.

06. International transfers

We will implement standard contractual clauses based on the UK Addendum to ensure adequate safeguards are in place to protect your information where it is transferred outside of the UK or the European Economic Area.  Where we share your information with a third party service provider outside of the UK or European Economic Area, we contractually oblige the third party service provider to implement adequate safeguards to protect your information.

07. 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. 

08. Data retention

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.

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. 

09. 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 right to object any time to the processing of your personal data for direct marketing purposes. 
  • 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.
  • 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 using the details below. 

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.

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. Contact details

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us by sending an email to [     ].

11. 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.

12. 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.

13. Third-party links 

The Prompt Platform 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 Prompt Platform, we encourage you to read the Privacy Policy of every website you visit.