Privacy Policy

This Privacy Policy provides you with the information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR) and the Hong Kong Personal Data (Privacy) Ordinance.

Our web site located at www.phonicshero.com (“Website”) and the Phonics Hero Mobile Application (iOS and Android) is owned and operated by Phonics Hero Limited (collectively referred to as “Phonics Hero”, “we”, “our” or “us”). This statement (“Privacy Policy”) describes the privacy practices we have adopted with respect to personal data in operating the Website and Mobile Application. The processing of some data is essential to the functioning of Website and Mobile Application so if you do not accept the terms of this Privacy Policy you should not use the Website and Mobile Application.

Definitions

“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.

“You” and “Your” – When used in this Privacy Policy includes any person who accesses the Website and submits personal data.

“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” can not set their own account up.

Your Consent

By using the Website and Mobile Application you consent to our collection and use of your personal data as described in this Privacy Policy. If we change our Privacy Policy and procedures, we will post those changes on the Website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it.

Data Controller

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”.

Collection of Personal Data and User Information

When you visit the Website or Mobile Application, we may collect three types of information from you:

1. User Personal 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.

School data: school name, country.

Teacher data: name, teacher name, teacher email address, class they manage, password.

Parent data: name, email address, password, child’s name.

We do not collect any “special category” data which could be deemed sensitive, including: race or ethnicity, religion, sexual orientation, political views, trade union membership and physical or mental health.

2. Usage information

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.

3. Student information

This may include: the name, class, teacher and school attended of registered Students. In respect of all nominated Student(s)’ use of the services of Phonics Hero whether at home or at school, we will collect detailed information including the time and duration of all visits to www.phonicshero.com and student scores in all games.

We also use information in aggregate form (so that no individual Student is identified):

  • to aid strategic development
  • to provide such information to actual and prospective subscribers, schools and educational authorities
  • To audit usage of the site

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.

How we protect your personal data

Phonics Hero is committed to safeguarding web users’ personal information in respect of its collection, use, retention security, transfer and access. Personal data is collected by lawful and fair means and only used for lawful purposes directly related to the functions and activities of Phonics Hero. We take all reasonably practical steps to ensure that personal data collected and retained are accurate and protected against unauthorised or accidental access, processing, erasure or other use. We limit the use of and access to your personal data to our designated employees, authorised agents and processors who are instructed to handle your personal data in accordance with this Privacy Policy.

Use of your personal data

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:

  • Where you have provided your consent.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

We use third party providers to administer our working relationship with you and other legitimate reasons. These are our third party providers:

  • Mailchimp for email marketing delivery.
  • Mandrill for account email delivery.
  • Braintree act as the payment gateway for credit card payments. Phonics Hero does not store any credit card details.
  • Capsule for Customer Relationship Management.
  • Google Analytics for analysis of the pages you have visited. This is in an aggregated format so will not have any identifying information.

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.

Deletiing of Data

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, incase they experience difficulties.

Email Communications

When registering as a User, you will be given the opportunity to opt-in to email communications from us. These emails will cover:

  • Updates on products and feature updates.
  • Give free literacy resources.
  • Thought pieces on literacy and phonics.

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 info@phonicshero.com.

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 info@phonicshero.com to request de-registration.

Links to Other Websites

The Website provides hyperlinks to other websites. This Privacy Policy does not apply in respect of such third party websites, and we are not responsible for any personal information about you which they may collect. These third-party hyperlinks are only supplied for the convenience of the Website’s visitors.

Your Rights

Under the Hong Kong Personal Data (Privacy) Ordinance and the General Data Protection Regulation ((EU) 2016/679) (GDPR), 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 info@phonicshero.com. You will not have to pay a fee to access your personal information and we will respond to your request within two working days.

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 info@phonicshero.com

Complaints

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: info@phonicshero.com. 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

Changes to our Privacy Policy

Any changes Phonics Hero makes to this Privacy Policy will be posted on this page. You should check our Privacy Policy regularly to ensure that you are aware of our latest policies.