Discovery Education Europe Limited

DoodleLearning – Privacy Notice

Last updated on: 21st December 2023

This Privacy Notice describes the information collection, use, retention and sharing practices of Discovery Education Europe Limited, a company registered in England and Wales (registration number 03261277), whose registered office is located at 9 Palace Yard Mews, Bath, BA1 2NH, United Kingdom, (“Discovery Education”, “we”, “us”, “our) when you interact with us online through our DoodleLearning website at www.doodlelearning.com/ (the “Website”) or through our DoodleLearning applications: DoodleMaths, DoodleEnglish, DoodleTables, DoodleSpell (collectively, the “Learning Apps”) (collectively, the “Services”).

OUR ROLE IN DATA PROCESSING 

The entity responsible for the collection and use (processing) of your personal information is Discovery Education Europe Limited which, for the purpose of the General Data Protection Regulation (“GDPR”) Regulation (EU) 2016/679 and the UK Data Protection Act 2018 (“DPA”), is the data controller. You can contact Discovery Education by email at ukprivacy@discoveryed.com (“Discovery Education’s email address”), by telephone at 0800 6 527 527 or by sending a letter to Discovery Education Europe Limited (Attn: Marissa Jones), 9 Palace Yard Mews, Bath, BA1 2NH, United Kingdom.

PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG

We collect personal information, which is information relating to you as an identified or identifiable natural person (‘data subject’) engaging with the Services; an identifiable natural person is one who can be identified, directly or indirectly. As used in this Privacy Notice, “personal information” includes “Personal Data”, as defined under the GDPR and DPA.

Unless we receive a request to delete this information and no exception to your right to deletion applies, we will delete (1) information associated with a Student account, which is linked to a Teacher/School or Parent account, when the account remains inactive for 24 months and does not have an active subscription; (2) information associated with a Teacher account when the account remains inactive for 6 months and does not have an active subscription; (3) information associated with a Parent account when the account remains inactive for 6 months and does not have an active subscription.

We collect personal information as you engage with our Services.

If you are a Teacher (or Head Teacher) User, this includes when you:

• Sign up as a Teacher (or Head Teacher) User.
  • To create your Teacher account, our education consultant will collect from you, your identifiers (name and email address), and pupils’ identifiers (first name (surname is optional), birth month and year) your professional or employment-related information (school name and address (including post code) and the name of the class). If you wish, you may also provide pupils’ additional identifiers (email address,).. We will also
    collect from you your sensitive log-in details (password) in hashed format.
  • When you (as Head Teacher) sign up for an account for your school, our education consultant will collect your Teachers’ identifiers (name and email address), pupils’ identifiers (first name (surname is optional), birth month and year). If you wish, you may also provide pupils’ additional identifiers (email address), as well as professional or employment-related information (school name and address (including post code), class year group, and the name of the class). We will also collect from you your sensitive log-in details (password) in hashed format.
    
    
    

We use this information to set up your account, manage the account, respond to queries from you and send an invoice to the school should you decide to continue using the Services after the trial period. To the extent the EU or UK data protection laws apply, the legal basis for this processing activity is the fulfilment of a contract with you. If you do not provide this information, we will not be able to set up your account. We also use this information to send you, through our third party email provider, emails necessary to the Services, and if you opt-in to receiving them, marketing emails to provide you additional promotional information about the Services. To the extent the EU or UK data protection laws apply, the legal basis for this processing is your consent. You may withdraw your consent (unsubscribe) at any time by clicking the “unsubscribe” link included at the bottom of each email we send to you. However, we will continue to send you service-related messages. Our emails include a tracking pixel that tracks whether you open the email, whether you click banners in the email, and your subsequent clicks and usage of our Website. We use this information to understand the effectiveness of the email messages.

We also use this information to create and manage the Student user account, and to place the student at the Doodle grade. After the Student user account is created, the Student password will be manually created by the Teacher or automatically generated by us.

• Use the Services. When you use the Services, we also collect your internet or other electronic network activity information (IP address, usage data (e.g., which pages you visited, when you visited them, how much you spent there, which buttons you clicked, device used and app version) from you automatically via “cookies”, pixels, and similar tracking technologies to create aggregated usage reports and to understand how Teachers are using the Services in order to improve our Services. To the extent the EU or UK data protection laws apply to placement of cookies on our Website, the legal basis for this processing is your consent. You may withdraw your consent at any time with effect moving forward by managing your Cookie Preferences by clicking the Cookie Settings link in the footer of our homepage https://doodlelearning.com. To the extent the EU or UK data protection laws apply, the legal basis for the placement and access of strictly necessary cookies is the performance of a contract. These cookies are necessary to provide the Website to you.
  
  
  

• Access the Dashboard: Teachers can view, through the Teacher Dashboard, information with respect to the Student users associated with their account namely: the Student’s name and account details, the Student’s Doodle age, how often Student logs in, rough metrics on how much time they spend in the product and detailed breakdown of their ability in different areas in the curriculum (including areas needing improvement).
  
  
  

If you are a Parent/Guardian User, this includes when you:

• Sign up as a Parent User. When you sign up for a Parent User account (either on the website or on the Learning App), we collect, from you, your identifiers (name, email address) and your child’s identifiers (first name, birth month, birth year), the rating of your child’s level in the relevant subject, sensitive log-in information password (hashed), assigned user ID. If, if signing up through the Website, our third party payment provider (Stripe Privacy Policy) will also collect your sensitive financial information (credit/debit card, security code, expiration date), but we only collect the last four numbers of your payment card, and your billing address . If you sign up through the Learning App, your payment information will be collected by the relevant mobile application platform provider and will not be accessible to us. We use this information to set up and manage your account. To the extent the EU or UK data protection laws apply, the legal basis for this processing activity is the fulfilment of a contract with you. If you do not provide this information, we will not be able to set up your account. We also use this information to send you, through our third party email provider, emails necessary to the Services, and if you consent, marketing emails to provide you additional promotional information about the Services. The legal basis for this processing is your consent. You may revoke your consent (unsubscribe) at any time by clicking the “unsubscribe” link included at the bottom of each email we send to you. However, we will continue to send you service-related messages. Our emails include a tracking pixel that tracks whether you open the email, whether you click banners in the email, and your subsequent clicks and usage of our Website. We use this information to understand the effectiveness of the email messages.
  
  
  

If you create a free trial, we collect the same information and use it to create and manage your account and to enroll you in our free trial. Your sensitive financial information will be held by the relevant payment processor (Stripe or the mobile application platform provider) as above. If you do not opt out of the renewal we will use your sensitive financial information to process your payment for subsequent subscription period(s) in accordance with our Terms of Use via the relevant payment processing provider.

• Use the Services. When you use the Services, we also collect your internet or other electronic network activity information (IP address, information (usage data (e.g., which pages you visited, when you visited them, how much you spent there, which buttons you clicked)) automatically via “cookies”, pixels, and similar tracking technologies to create aggregated usage reports and to understand how Parents are using the Services in order to improve our Services. To the extent the EU or UK data protection laws apply to placement of cookies on our Website, the legal basis for this processing is your consent. You may withdraw your consent at any time with effect moving forward by by clicking the Cookie Settings link in the footer of our homepage https://doodlelearning.com. The legal basis for the placement and access of strictly necessary cookies is the performance of a contract. These cookies are necessary to provide the Website to you.
  
  
  

• Access the Dashboard: Parents can view, through the Parent Dashboard, information with respect to the Student users associated with their account namely: the Student’s name and account details, the Student’s Doodle age, how often Student logs in, rough metrics on how much time they spend in the product and detailed breakdown of their ability in different areas in the curriculum (including areas needing improvement).
  
  
  

For Student Users, this includes when the student:

• Create a Student User account. Student User accounts are created by a teacher, parent, or guardian. When a Student User account is created, we collect, from the creator of the account, the student’s personal identifiers (name and birth month and year), and if you are creating a Student User account associated with a Teacher, you have the option to also provide additional identifiers (email address) We use this information to create a Student user ID and manage the Student User account. To the extent the EU or UK data protection laws apply, the legal basis for processing this information is to fulfil a contract. If we are not provided this information, we are not able to set up the Student User account. We also collect, from the Student, the results of a baseline assessment for the relevant Learning App (DoodleMaths, DoodleEnglish, DoodleTables, DoodleSpell). If this assessment if done by the Student before the account is created, this information is included in the Student account to the extent that is created during the same session. We use this information to calculate the Student’s Doodle Age, i.e., to place the student at the correct level in the Discovery Education curriculum. To the extent the EU or UK data protection laws apply, the legal basis for the processing of this information is it is necessary for the performance of our contract.
  
  
  

• Use the Learning Apps. When a Student uses the Learning Apps, we will track all questions answered (and whether correct or not), the time taken per question, the number of correct answers to questions for each area of curriculum, and the number and frequency of logins to the Learning Apps, and the number of Doodle stars and/or badges earned, maximum stars in a day/week, fastest exercise and its duration. We will also calculate and adjust the Doodle Age based on the percentage of correct answers. We use this information in order to provide the correct content to the Student, determine if any areas require more practice (“powerup”) and adjust the Student’s learning path. To the extent the EU or UK data protection laws apply, the legal basis for the processing of this information is it is necessary for the performance of our contract. If the Student accesses their own dashboard in the Learning App, they can view their own streak (number of consecutive days), the number of Doodle stars and/or badges they have earned and which areas are flagged as “powerup” (requiring more practice).

If you are a website visitor, this includes when you:

• Contact us via telephone or email. When you contact us via telephone or email, we collect, from you, your personal identifiers (name, email address, and telephone number) and any information you choose to include in your message. We use this information to respond to your questions or inquiries, troubleshoot where necessary, and manage your use of the Website. To the extent the EU or UK data protection laws apply, the legal basis for this processing is that it is necessary for the performance of the service requested by you.

• Interact with us on social media. When you interact with our fan page on social networking websites, such as Facebook, Twitter, LinkedIn, and Instagram (each a “Fan Page” and collectively “Fan Pages”), we collect basic engagement metrics and use it to tailor content and marketing and use it to improve user experience as set forth in this section. Please note that we do not control the use or storage of the information that you have posted to any social networking websites. This information is collected and processed by the social networking websites for their own purposes, including marketing. For more information on how Facebook, Twitter, LinkedIn, and YouTube use your personal information, please see Facebook’s Privacy Policy, Twitter’s Privacy Policy, LinkedIn Privacy Policy, and Instagram’s Privacy Policy (Thread’s Privacy Policy).

Facebook, Twitter, LinkedIn, and Instagram (the “Social Networks”) process personal information in the USA where the laws may be less protective than in your country of residence. For example, in accordance with U.S. laws, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in other countries may be entitled to access your personal data.

• Fan Pages. When interacting with our Fan Pages, we collect, from you, your personal identifiers (first and last name) and visual information (photograph (i.e., profile picture)), as well as any information that you provide when interacting with our Fan Pages (e.g., commenting, sharing, and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function. To the extent the EU or UK data protection laws apply, the legal basis for the processing is our legitimate interest in advertising our products via our Fan Pages and communicating with users, customers, and interested parties. Because our Fan Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit. The content posted on our Fan Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to us at Discovery Education’s email address.
  
  
  

• Community Management. We collect, from you, your contact, including “likes”, shares, messages and other interactions with the content, in order to analyze and evaluate how our content is perceived, to learn from it, and to improve our public relations efforts. To the extent the EU and UK data protection laws apply, the legal basis for analyzing your content is our legitimate interest in organizing, facilitating, and optimizing communication with our users and the general public. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email to Discovery Education’s email address.
  
  
  

• Events and Photos. When you register for an event on our Fan Pages, we collect, from you, your personal identifiers (first and last name, email address, telephone number, physical address, and any other information you provide). We use this information to create and manage the event (e.g., to create the guest list, accreditation and admission control, room and personnel planning, planning the catering) as well as to send you your invitation and notifications about the event. We also use this information for prevention of fraud and defense against legal claims. To the extent the EU or UK data protection laws apply, the legal basis for processing your information to facilitate your attendance is the necessity for the performance of a contract with you. If you do not provide this information, you would not be able to participate in the event. The legal basis for the other uses is our legitimate interest in fraud prevention.  At events for which you have registered, photos and video recordings may be made (possibly by a photographer commissioned by us), in which you may also be shown. If you are the central subject of a recording, the photographer will ask you before the recording/taking the photo whether you agree and consent. We use the photos for our public relations and marketing on our various media/digital media outlets. To the extent the EU or UK data protection laws apply, the legal basis for processing your photos where you are the subject is your consent. You can revoke your consent with effect going forward via email to Discovery Education’s email address. The legal basis for taking and publishing photos where you are in the background is our legitimate interest in public relations. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email to Discovery Education’s email address.
  
  
  

• Page Insights. When you visit our Social Network Page, the Social Network records your IP address and other information about your usage behavior on our Social Network Fan Page. The Social Network collects, through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Social Network app through your mobile device (e.g., smartphone or tablet). Social Network uses this information to provide us with statistical evaluations of the use of our Social Network Fan Page. We receive this information directly from Social Network, in the form of aggregated data and anonymous statistics regarding certain data points, such as: age; gender; city/country; device; inquiries from fans about other Social Network fan pages; region and language settings of the users; proportion of men and women; the number of people reached; clicks on posts, “Likes” and reactions; comments and shared content; and total video views. We use this information to analyze and improve the advertising campaigns we conduct through our Social Network Fan Page. We do not collect or process any other personal information in connection with Social Network “Page Insights” function.
  
  
  

To the extent the EU and UK data protection laws apply, we are joint controllers with the Social Network for this processing. For the purpose of the EU and UK data protection laws, the legal basis for this processing is our legitimate interest in statistical evaluation of users on our Social Network Fan Page for the improvement and adjustment of our advertising measures based on the information collected. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email to Discovery Education’s email address.

We do not retain this information independently. For information on data protection and the storage period on the Social Network in relation to its Insights function, see the Social Network privacy policy linked above. It has been contractually agreed with the Social Network that the Social Network is responsible for providing you with information about the processing for Page Insights.

• Information Processed Solely by Social Networks. We do not know how the Social Networks use personal information for its own purposes, how long the personal information is stored on the Social Network or whether the Social Network data is passed on to third parties. If you are currently logged in to a Social Network as a user, the Social Network automatically collects, through trackers on your device, your Social Network ID or a link between the Social Network ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Social Network app through your mobile device (e.g., smartphone or tablet). This enables the Social Network to understand that you have visited our Social Network Fan Page along with other Social network pages that you have clicked on, whether you clicked on Social Network buttons integrated into websites that partner with the Social Network, and other online interactions that report user data to the Social Network. Based on this data, content or advertising tailored to you can be offered. You can find more information about the personal information collected by Social Networks, how it is used and how long it is stored by visiting the Social Network’s privacy policies, linked above.

• Interact with the Website. In addition to the personal information you provide directly to us, we also collect information from you automatically as you use the Website via “cookies”, pixels, and similar tracking technologies. To the extent the EU or UK data protection laws apply to placement of cookies on our Website, the legal basis for this processing is your consent. You may withdraw your consent at any time with effect moving forward by by clicking the Cookie Settings link in the footer of our homepage https://doodlelearning.com. To the extent the EU or UK data protection laws apply, the legal basis for the placement and access of strictly necessary cookies is the performance of a contract. These cookies are necessary to provide the Website to you.

We use essential, performance, marketing, and analytics cookies to collect Parent and Teacher usage, device, and location information (determined through your IP address) when you interact with the Website. Other than essential trackers, these will not deploy unless you provide your consent. We use this information to: (i) enhance user experience on the Website; (ii) conduct analytics to improve the Website; (iii) prevent fraudulent use of the Website and detect unlawful activity; and (iv) diagnosis and repair Website errors, and, in cases of abuse, track and mitigate the abuse. These will not deploy unless you provide your consent. To opt in (or back out) of our use of non-essential cookies, please visit by clicking the Cookie Settings link in the footer of our homepage https://doodlelearning.com. To learn more about your privacy choices, please see YOUR INFORMATION CHOICES [hyperlink to relevant section] below.

Particular third-party cookies to note on our Website include the following:

• Google Analytics. We use Google Analytics to collect information on your use of the Services for its improvement. To collect this information, Google Analytics installs cookies on your browser or reads cookies that are already there. Google Analytics also receives information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to our Website or to another application which partners with Google is restricted by the Google Analytics Terms of Use and Privacy Policy. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on, which can be accessed here.
  
  
  

• Facebook Pixel. We use Facebook Pixel to customize our advertising and to serve you ads on your social media based on your browsing behavior. This allows your behavior to be tracked after you have been redirected to our Website by clicking on the Facebook ad. The Facebook Pixel stores a cookie on your device to enable us to measure the effectiveness of Facebook ads for statistical and market research purposes. We do not have access to the information collected through the Facebook Pixel. However, the information collected via the Facebook Pixel, on the Websites as well as other websites on which Facebook Pixel is installed, is stored and processed by Facebook. Facebook may link this information to your Facebook account and use it for promotional purposes in accordance with Facebook’s Data Policy. Facebook its partners use the Facebook Pixel to show you advertisements on and outside of Facebook. To opt-out of this displaying of Facebook ads, visit your Facebook Ad Settings.  You can also clear and control the information third parties share with Facebook in your Off-Facebook Activity page.
  
  
  

• Microsoft Clarity. We will use Clarity to collect information to analyze your use of the Website to improve our Website and analyze efficiency of online advertisements. We will collect a recording of your session on the Website scroll behavior, click behavior, custom events, page navigation flow, browser type, country, device ID, device type, operating system, and session code errors. In order to collect this information, Clarity may set cookies on your browser, or read cookies that are already there. You can view Microsoft’s Privacy Statement for more information about its data collection practices. To opt-out of the use of your data for interest-based advertising from Microsoft, please visit Microsoft’s opt-out page. To access and clear some of your data, please visit Microsoft’s privacy dashboard.
  
  
  

• Google Ads. We utilize Google Ads to serve ads based on a user’s prior visits to our Websites and Learning Apps. Each Parent/Guardian or Teacher to our Websites and Learning Apps receives a different cookie, and the information collected by the cookie is used to generate conversion statistics and allows us to see the total number of individuals who clicked on our ads. Google Ads enables Google and its partners to serve ads to you based on your visits to our Website and Learning Apps in addition to other websites on the Internet. Please review Google’s Privacy Notice for additional information on how Google uses the information collected. To opt out, you can go to Google’s Ad Settings, or you can install the DoubleClick opt-out add-on
  
  

• Microsoft Ads. Bing’s Microsoft Advertising Platform cookies improve advertising. We use this application to target advertisements based on what’s relevant to a user, to improve reporting on campaign performance, and to avoid showing ads the user has already seen. You can opt out of personalized advertising on Microsoft sites and services by visiting the Ads settings page on your Microsoft privacy dashboard.
  
  
  

• X Pixel. We utilize the X Pixel to serve ads based on a user’s prior visits to our Websites and Learning Apps. Each Parent/Guardian or Teacher to our Websites and Learning Apps receives a different cookie, and the information collected by the cookie is used to generate conversion statistics and allows us to see the total number of individuals who clicked on our ads. X Pixel enables X and its partners to serve ads to you based on your visits to our Website and Learning Apps in addition to other websites on the Internet. For more information, please review X’s Privacy Policy.

To opt in (or back out) of our use of non-essential cookies, please visit by clicking the Cookie Settings link in the footer of our homepage https://doodlelearning.com.] In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent. Please note, if you opt out of these targeted advertising cookies (after having initially opted in), your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt out of each browser or device that you use.

Aggregate and anonymize data. We aggregate and anonymize the data we collect for benchmarking purposes and for internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data, unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws.

Discovery Education will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

DATA RETENTION

We retain your information for as necessary for the purpose for which it was provided for the terms set forth above. We may need to use and retain your personal information for longer for purposes of:

• Compliance with our legal obligations. For example, retaining your records for the purpose of accounting, dispute resolution, and compliance with labor, tax, and financial regulations.
  
  
  
• Meeting our safety and security commitments. Such as keeping our properties secure and preventing fraud.
  
  
  
• Exercising or defending legal claims. We also may need to retain information for longer than the terms in order to meet with legal process or enforceable governmental request.

HOW WE SHARE YOUR PERSONAL INFORMATION

1. General Sharing

Discovery Education shares personal information as described in the PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG Section, and generally in the following instances:

• Within Discovery Education. We share your personal information within Discovery Education for the legitimate business purposes of efficiently and effectively providing the Services, such as accounting and customer service support. Access to your personal information is limited to those on a need-to-know basis. To the extent EU data protection law applies, the legal basis for this is our legitimate interest in providing the Services more efficiently.
  
  
  

• In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings. To the extent EU data protection law applies, the legal basis for this is our legitimate interest in carrying out our business operations or, if required by law, consent.|
  
  

• For legal purposes. We share personal information where we are legally required to do so, such as in response to court orders, subpoenas, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations. To the extent EU or UK data protection law applies, our legal basis is compliance with the law or our legitimate interest in complying with Non-EU data protection law to which we are subject.
  
  
  

• With service providers. We share personal information with service providers that assist us in providing the Website. These service providers are described more specifically in the PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG
  

   

• With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time with effect going forward by emailing us at Discovery Education’s email address (below).

YOUR INFORMATION CHOICES

You have the following choices with respect to your personal information:

• Opt out of marketing communications. You may opt out of receiving marketing emails from us by clicking the “unsubscribe” link provided at the bottom of each email we send. Please note that we will continue to send you notifications necessary to the Services.
  
  
  

• Correct or view your information. You may send an email to Discovery Education’s email address to correct or view certain personal information of yours in our possession.
  

   

• Opt into / Out of To set your cookie preferences, please visit Cookie Preferences by clicking “Cookie Preferences” under the “General” header in the footer of our website. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/.
  
  

  Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s Website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an “opt-out cookie” on your device. The “opt-out cookie” is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.

• Association of National Advertisers opt-out registration: https://dmachoice.thedma.org/
• Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp
• Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info
• European Union (EU) /European Economic Area (EEA) Opt-Out: http://www.youronlinechoices.eu
• In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent.

• Opt out of email tracking. You can disable this tracking by blocking automatic loading of images in your email.

YOUR DATA SUBJECT RIGHTS

Under the GDPR and DPA you are entitled to the following rights:

• Right to access: For any of the processing described above, you have the right to ask us for copies of your personal data. This right has some exemptions, which means you may not always receive all the personal data we process. Applicable exemptions may include the management information exemption (data that we process for management forecasting or management planning about a business or other activity), confidential references (references given or received about an individual), or certain instances of ongoing or prior negotiations with the requestor, among others.
  
  
  

• Right to rectification: For any of the processing described above, you have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

• Right to erasure: When we use cookies and other trackers, send you marketing emails, or process your personal data collected from an event that you attended, you have the right to request erasure of your personal data that we are not obligated to keep in some cases (also known as the right to be forgotten). For example, you can request us to delete your personal data if: (i) we no longer need the data for the purpose it was collected for, (ii) we process the data based on your consent and you revoke your consent, (iii) you object to our processing based on legitimate interest (and we do not have an overriding legitimate interest), or (iv) you object to our processing for direct marketing purposes. We may not be able to immediately erase your personal data if we have a lawful reason or a legal or contractual obligation to retain the personal data or continue the processing.

• Right to restrict processing: For any of the processing described above, if you believe that your personal data is inaccurate, that our processing is unlawful, or that we do not need your personal data for a specific purpose, you have the right to request that we restrict the processing of this personal data. You also have the possibility to request that we stop processing your personal data while we assess your request. If you object to our processing (per your right to object below), you may also request us to restrict processing of your personal data while we make our assessment.

• Right to object to processing: When you interact with us directly or indirectly through the Social Networks, you have the right to object to processing of your personal data, which is based on our legitimate interest, by referencing your personal circumstances. This may apply, for example to processing in connection with our social media pages.
  
  
  

• Right to data portability: You have the right to ask that we transfer the personal data you gave us from one organization to another or give it to you. However, this right only applies when: (i) you have provided your personal data to us; (ii) the legal basis for the processing is your consent or for the performance of a contract; and (iii) the processing is carried out by automated means. You can invoke this right for the processing of the information we automatically collect from you as you interact with the Website via “cookies”, pixels, and similar tracking technologies. This may apply in connection with your account information, and events photos, if applicable.

To exercise these rights, please contact us at Discovery Education’s email address.  

• Right to lodge a complaint: You have the right to lodge a complaint with the Information Commissioner’s Office at: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/y or accessicoinformation@ico.org.uk at their helpline on 0303 123 1113.

INFORMATION SECURITY

We implement appropriate technical and organizational security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. Additional measures include firewalls, muti-factor authentication via single sign on, malware protection, regular staff training, and robust incident response procedures. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.

CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and obtain your consent, if required.

CONTACT US 

If you have any questions or concerns regarding this Privacy Notice, please contact us by email at email at ukprivacy@discoveryed.com, by telephone at 0800 6 527 527, or by sending a letter to Discovery Education Europe Limited (Attn: Marissa Jones), 9 Palace Yard Mews, Bath, BA1 2NH, United Kingdom.