WHO WE ARE
Woo 360 Ltd, which trades under the name “woo360.co.uk” (“we”, “us” and “our”), a company incorporated in England & Wales with company number 11477284, is the owner of the Website and the data controller responsible for your personal data.
By using our Website or Services or submitting your personal data you are taken to accept the terms of this Policy, so please read it carefully.
PERSONAL DATA WE COLLECT
Personal data means any information that relates to you from which you can be identified. We will collect personal data when you visit the Website or subscribe to, or use, the Services.
We collect the following personal data about you:
- Subscriber information: In order to enable us to set up your account on our Website and provide our Services to you via our Website, you will need to provide us with personal data in order for us to provide you with access to the Services, such as your first name, last name and email address. If you are permitted to access the Services pursuant to a licence we have granted to an education provider or publisher, we may have been provided with certain personal data from that provider or publisher. We will, therefore, hold the information provided by you and your employer to create your user profile, and further information you provide to us from time to time. We may also require certain information from you redeem a benefit, enter a promotion, competition or survey and/or when you report a problem with our Website.
- Automatically collected data: When you visit our Website, our servers record technical information, which includes Internet Protocol (“IP”) address (from which we understand the country you are connecting at the time you visit the Website), type of mobile device you use, a unique device identifier, mobile network information, your login information, browser type and version you use, browser plug-in types and versions, operating system and platform; information about your visit to our Website. This also includes the full uniform resource locators (URL) clickstream to, through and from our Website (including date and time); pages you viewed or information you searched for; page response times, download errors, length of visits to certain pages; and details of your visits to other websites via our Website. Internet protocol (IP) addresses may be considered “personal data” in certain jurisdictions, such as in the European Economic Area (“EEA”), and will be treated in accordance with this Policy.
- Other Information: We also process any personal data you provide when contacting us, being the personal details you choose to give when corresponding with us by phone, post or e-mail or otherwise visiting and interacting with this Website or any other websites we operate.
HOW WE USE PERSONAL DATA
We will collect and process your personal data as follows:
- To acknowledge, confirm and deal with your subscription for the Services or to identify you and manage your account on the Website. Such use of your data is necessary in order to implement your request to become a Subscriber. We will also need to use your data to create and manage your user account and to send an activation email or to verify their email address.
- Where you are a Subscriber, provide you with the Services and contact you regarding your use of the Services. Such use is necessary to respond to or implement your request and for the performance of the contract between you and/or your employer (if you are part of an education provider or publisher) and us.
- With your consent (if given during the registration process), we and our affiliated businesses may provide you, or permit selected third party service providers to provide you, with newsletters, information about goods or services, events and other promotions we feel may interest you. You have the right to ask us not to process your personal data for marketing purposes at any time. You can always unsubscribe from our email communications at any time by following the unsubscribe link in our email communications, or by updating your email preferences on your profile on our Website (for more information on your rights, please see “User rights” section below).
- As necessary for certain legitimate interests, which include the following:
- Where we are asked to deal with any enquiries or complaints you make.
- To administer our Website, to better understand how visitors interact with our Websites and ensure that our Website is presented in the most effective manner for you and for your computer/device.
- If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.
- To share personal data among our affiliated businesses for administrative purposes, for providing the Services and in relation to our sales and marketing activities.
- To conduct analytics to inform our marketing strategy and enable us to enhance and personalise the experience we offer to our Subscribers and our communications, including by creating customer or Subscriber account to enable personalised direct marketing communications.
- We may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, including sharing it with business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behaviour.
- For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Website, network and information systems secure.
- To (a) comply with legal obligations, (b) respond to requests from competent authorities; (c) protect our operations or those of any of our affiliated businesses; (d) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and (e) enforcing or defending legal rights, or preventing damage.
- We may use your personal data for other purposes which you have consented to at the time of providing your data.
As used in this Policy, “legitimate interests” means our interests and our affiliated businesses interests in conducting and managing our organisation. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see “Your Rights” section below).
Your personal data will be stored on servers in the European Union.
You may, at any time, review or ask for the rectification of, any of your personal data that we hold. We are permitted by law to charge an administration fee for the provision of this information to you. You may also object, at no charge, to any further use of your personal data, such as for direct marketing purposes, by contacting us using the contact details available on our Website. Please see the “Your Rights” section below for further information.
DISCLOSURE OF YOUR PERSONAL DATA
We share your personal data with third parties in the following situations:
- Service Providers: We, like many businesses, sometimes hire selected third parties who act on our behalf to support our operations, such as IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide the Services and other goods or services available on this Website or to Subscribers, web analytics providers, providers of digital advertising services and providers of marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the Services we have hired them to provide.
- Affiliated Businesses: We operate on a global scale. In order to provide the Services you request from us, our affiliated businesses may access and process the information which we collect from you for the purposes described above, including offering products and the Services to you. Our affiliated businesses will only use your data for the purposes for which we originally collected it.
- Personnel: We may allow our staff, consultants and/or external service providers acting on our behalf, and our provider of payment services, to access and use your personal data for the activities we have described above. We only permit them to use it to deliver the relevant Service, and if they apply an appropriate level of security protection.
- Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process; (ii) to enforce our terms & conditions or other applicable contract terms that you are subject to or (iii) to protect us, our Subscribers, or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.
We may share aggregated demographic information with our partners, clients and advertisers. This is not linked to any personal data that can identify you.
This Website may include links to third-party websites, plug-ins and applications. Please remember that when you use a link to go from our Website to another website or you request a service from a third party, this Policy no longer applies. Please be aware that we are not responsible or liable for the privacy practices of other websites. We encourage you to be aware when you leave the Website and to read the privacy policies of each and every website that collects personally identifiable information. This Policy applies solely to information collected by us on the Website.
Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to personal data collected by us through our Website and does not apply to these third party websites and third party service providers.
PERSONAL DATA TRANSFERS
Your personal data will be transferred to and stored in countries other than the country in which the information was originally collected, including the United States, Singapore, UAE and other destinations outside the EEA, to our service providers and affiliated businesses for the purposes described above.
Please note that the countries concerned may not provide the same legal standards for protection of your personal data that you have in the United Kingdom or EEA. Where we transfer your personal data to countries outside of the EEA we will take all steps to ensure that your personal data will continue to be protected. We will implement appropriate safeguards for the transfer of personal data to our service providers in accordance with the applicable law, such as relying on our service providers’ Privacy Shield certification or implementing standard contractual clauses for data transfers. We have implemented data transfer agreements pursuant to applicable data protection law in order to implement appropriate safeguards for the transfer of personal data to our group companies in countries outside the EEA. If you would like to receive more information on the safeguards that we implement, including copies of relevant data transfer contracts, please contact us as indicated below.
We employ security measures to protect your personal data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will take steps to ensure that your information receives an adequate level of security protection where it is processed and your rights continue to be protected. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
The transmission of information using Wi-Fi networks and cellular data networks may not be completely secure. Although we will use reasonable endeavours to protect your personal data, we cannot guarantee the security of data transmitted to us using our Website and any such transmission is made at your own risk.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will keep your personal data for as long as reasonably necessary for the purposes described in this Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.
To determine the appropriate retention period for your personal data, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we use your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer our customer, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
In addition, parents, guardians, or school officials can contact us to:
- request copies of the Personal Data we collected about their children;
- direct us to delete the Personal Data we collected about their children;
- direct us to stop collecting or using Personal Data regarding their children; and
- prohibit the disclosure of Personal Data regarding their children to third parties not needed to provide the Service.
Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:
- Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
- Right to erasure: You may ask us to delete or remove your personal data in certain circumstances, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly. Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services and we may need to deactivate your account on our Website.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
- Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Right to object: You may ask us at any time to stop processing your personal data, and we will do so, if we are relying on a legitimate interest to process your personal data – unless we demonstrate compelling legitimate grounds for the processing.
- Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your personal data, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent.
- Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to UK Information Commissioner’s Office (“ICO”). You can find details about how to do this on the ICO’s website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
You may exercise your rights by contacting us as indicated under the “How to Contact Us” section below.
CHANGES TO THIS POLICY
We may amend this Policy from time to time by uploading a replacement Policy to our Website. To ensure that you are always aware of how we use your personal data we will update this Policy from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements.
By continuing to use our Website or providing us with information following such a replacement Policy being uploaded, you agree that you will be deemed to have agreed to be bound by the replacement Policy.
HOW TO CONTACT US
If you have any questions about this Policy or our data processing practices, you can contact us by:
- Writing to us at:
- Woo 360 Ltd, 12 Crown Hill Lane, Great Cambourne, Cambridge, Cambs, CB235AW, UK
- Emailing us at: firstname.lastname@example.org
- Calling us on: +44 1223 911313