Privacy Policy

For the purposes of the Data Protection Act 1998 (the "Act") the data controller is Pibbon Ltd, a company registered in the United Kingdom with registration number 09149901 whose registered office address is at 86-90 Paul Street, London, England, EC2A 4NE.

1. In this Notice we explain how we will handle your personal data.
2. We will ask you to consent to our use of cookies in accordance with the terms of this Notice when you first visit the Site.
3. The Site and App incorporate privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit some other uses of your information depending on the controls we have implemented from time to time.

1. In this Section 2 we have set out:
   • the general categories of personal data that we may process;
   • in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
   • the purposes for which we may process personal data; and
   • the legal bases of the processing. When we refer to a "legal basis", we mean the provision of the General Data Protection Regulation under which we conduct the relevant processing.
2. We may process data about your use of the Site, App and our products and services ("usage data"). This may include:
   • in relation to the use of the Site, your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use are collected to help us improve our website for you.
   In relation to the use of our products and services, we generate anonymised, unique ID references for each App account to allow us to provide our service to you, and use non-identifying information regarding your usage of the App or Site including tap/click-based behaviour and your device and software models and versions, to ensure we provide you with the correct versions of features for your hardware and software. We collect parent email addresses in order to provide our service and send necessary messages to you. We also collect your child's name or pseudonym, under the same grounds. Permission is requested for this use within the app at the point of registration, and all data collection is visible and clear in the interface. In each case the legal basis for this processing is our legitimate interests and provision of contract. Usage data is typically aggregated in such a way that it contains no information pertaining to an individual at all. In such cases, it will not be personal data and will no longer be governed by this Privacy Notice at all
3. We may process your account data ("account data") being the information provided to us when you register an account via the Site or App. This may include parent name and email address. We only obtain account data from you directly, and it may be processed for the purposes of operating our Site and App, providing our products and services, ensuring the security of our Site, App and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is; in connection with the account data necessary for us to provide our products or services to you, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; and otherwise, your consent to such processing.
4. We may process your personal data that are provided in the course of the use of our services ("service data"), whether by you or by any third party with whom you and we have a separate contractual relationship. The source of the service data is you or the relevant third party. The service data may be processed for the providing our services, ensuring the security of the Site, App and our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is either the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, or, where we have no contract with you, your consent to such processing in relation to any contract you may have in place with the relevant third party.
5. We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). This may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is your the performance of our contract with you as a user of our services.
6. We may process information relating to transactions, including purchases of goods and services, that you enter into with us through our Site, App or otherwise ("transaction data"). This may include your contact details and the transaction details, although we do not have any access to your card details, and these will only be available to our payment processing service provider. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
7. We may process information contained in or relating to any communication that you send to us ("correspondence data"). This may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of the Site or App, our business and our communications with users.
8. We may process any of your personal data identified in the other provisions of this Privacy Statement where necessary in connection with legal claims. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
9. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
10. Please do not supply any other person's personal data to us, unless we prompt you to do so.

1. We may provide your personal data to our third party service providers, strictly to the extent necessary for them to provide the relevant services to us. We will never do so for advertising purposes. We do not pass any identifiable child data to any third parties. We do not collect any other personally identifiable information ourselves beyond first names, in compliance with COPPA regulations.
2. Out service providers include
   • Our hosting service providers, DigitalOcean, Inc., and Google, Inc., who may process certain information in hosting our platform, data and systems.
   • Functional Software, Inc. ('Sentry') to whom we send usage and crash data to help us fix problems in the application.
3. Each of these service providers may further provide your personal data to their own service providers who provide necessary support functions (for instance, the third parties who host their servers). However, such disclosure will again only be for the purpose of providing the relevant services to us.
4. We may also provide your personal data to any acquirer of our business or assets (in which case our accumulated data, including your personal data, will be comprised in our business or assets).
5. We may disclose your personal data if required to do so by law, to prevent an unlawful act, or otherwise to appropriate authorities in connection with any civil action or criminal report or investigation relating to your activities.
6. Otherwise, we will not provide your personal data to any third parties. In particular, we do not provide your personal data to third parties for marketing purposes.

1. In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
2. The hosting facilities for our App is located within the EEA. The hosting for our Site and App is provided by DigitalOcean, Inc. and Google, Inc.. Our App is hosted on their servers in Amsterdam (DigitalOcean, Inc.) and Ireland (Google, Inc.), and we may transfer all personal data to our hosting service providers in that country. To improve the speed of delivery of our website, versions of our Site are hosted on servers in multiple global locations.
3. Some of the third parties to whom we may transfer your personal data, discussed in Section 3, may be located outside the EEA or may transfer your personal data to their own service providers located outside the EEA. If so, then we will ensure that transfers will only be made to countries in respect of which the European Commission has made an "adequacy decision", or otherwise will only be made with appropriate safeguards, such as the use of standard data protection clauses adopted or approved by the European Commission. You may contact us to enquire about such safeguards so that you may obtain a copy of them or so that we may direct you to them.

1. This Section 5 sets out our data retention policies, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. We will retain and delete your personal data as follows:
   • all account and service data will be retained for as long as we provide products or services to you, or as long as you have an account with us. Twelve months after the end of such period it will be deleted from our systems;
   • enquiry and correspondence data will be retained in accordance with our email archiving policies. Typically this will provide for data to be archived after twelve months, and deleted entirely after six years;
   • transaction data will be retained for six years; and
   • usage data will be retained for between three and twelve months from collection, and then deleted. As an exception, usage data relating to App performance, or aggregated usage data from which no individual can be identified, may be retained by us indefinitely, as this provides us with important insights into user behavior and is a significant business asset.
4. We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

1. In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. You can read guidance from the Information Commissioner's Office at www.ico.gov.uk for a fuller explanation of your rights.
2. Your principal rights under data protection law are:
   • the right to access;
   • the right to rectification;
   • the right to erasure;
   • the right to restrict processing;
   • the right to object to processing;
   • the right to data portability;
   • the right to complain to a supervisory authority; and
   • the right to withdraw consent.
3. You have the right to confirmation as to whether or not we process your personal data and, where we do, to access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5. In some circumstances you have the right to the erasure of your personal data. These might include if:
   • the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
   • you withdraw consent to consent-based processing;
   • the processing is for direct marketing purposes. However, there are certain general exclusions of the right to erasure, for example where processing is necessary for compliance with a legal obligation; or in connection with legal claims.
6. In some circumstances you have the right to restrict the processing of your personal data. Where processing has been restricted on this basis, we may continue to store your personal data and will observe the restrictions on processing except in the case of processing permitted by applicable law (for example, in connection with legal claims or for reasons of public interest).
7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
   • the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or
   • the purposes of the legitimate interests pursued by us or by a third party.
8. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing is for legal claims.
9. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
10. To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
13. You may exercise any of your rights in relation to your personal data by written notice to us.

1. We may use cookies for the following purposes:
   • authentication - we use cookies to identify you when you visit the Site and as you navigate the Site;
   • status - we use cookies to help us to determine if you are logged into the Site;
   • security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our Site and services generally;
   • analysis - we use cookies to help us to analyse the use and performance of the Site; and
   • cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
2. Our service providers use cookies and those cookies may be stored on your computer when you visit the Site.
3. Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all the features on our Site.

1. The Site and App are owned and operated by Pibbon Ltd. Our address details are at the top of this agreement.
2. We are registered in England and Wales under registration number 09149901, and our registered address is 86-90 Paul Street, London, England, EC2A 4NE.
3. Our principal places of business are noted at the top of this document.
4. You can contact us:
   1. by post, using the registered or office addresses given above;
   2. by email, using the email address published on the Site or in the App application from time to time.

The Site contains links to third party websites and refers to third party service providers and other entities. If you follow a link to any third party website or deal with any third party entity referred to on the Site, then you should note that these third parties may have their own privacy and cookie policies, and that we are not responsible for their use of any personal data which you may provide to them. You should ensure that you have read and understood any relevant policies. Where present in the App, these will always be protected by a 'parental gate'. If you follow a link to any third party website or deal with any third party entity referred to on the Site, then you should note that these third parties may have their own privacy and cookie policies, and that we are not responsible for their use of any personal data which you may provide to them. You should ensure that you have read and understood any relevant policies.

Although we do our best to ensure the security of personal data provided to us (and to use only reputable service providers), any transmission of data via the Internet is by its nature insecure and we cannot guarantee the security of any personal data you provide to us.

Amendments We may update this Notice from time to time by publishing a new version on the Site and/or on the listing page for the App. You should check occasionally to ensure you are happy with any changes to this Privacy Notice, although we will notify you of material changes to this Notice using the contact details you have given us.

If you have any questions, comments or requests regarding the Terms or any concerns about any material featured on our Site, please contact us at contact@pibbon.com.