Privacy and cookies Policy

  1. Introduction
    1. We are committed to safeguarding the privacy of our website and apps (our “Hosted Services”) users.
    2. This policy applies where we are acting as a data controller with respect to the personal data of our Hosted Services users; in other words, where we determine the purposes and means of the processing of that personal data.
    3. We use cookies on our Hosted Services. Insofar as those cookies are not strictly necessary for the provision of our Hosted Services and services, we will ask you to consent to our use of cookies when you first visit our Hosted Services.
    4. Our Hosted Services 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 the publication of your information. The privacy controls are accessed during the registration process. If you wish to change your privacy settings you can contact us:
      1. using our Hosted Services contact form;
      2. by email, using hello@easypeasyapp.com.
    5. In this policy, "we", "us" and "our" refer to Character Counts Ltd. For more information about us, see Section 19.
  2. How we use your personal data
    1. In this Section 2 we have set out:
      1. the types of data subject;
      2. the general categories of personal data that we may process;
      3. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
      4. the purposes for which we may process personal data; and
      5. the legal bases of the processing.
    2. Categories of data subject:
      1. Parents registered at a setting; and
      2. Staff members registered at the setting.
    3. We may process data about your use of our Hosted Services and services ("usage data"). The usage data may include 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 service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent.
    4. We may process your Hosted Services user account data ("account data"). The account data may include your name, phone number and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our Hosted Services, ensuring the security of our Hosted Services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.
    5. We may process your information included in your personal profile on our Hosted Services ("profile data"). The profile data may include your name, telephone number, child’s name and date of birth, email address, profile pictures, and interests. The profile data may be processed for the purposes of enabling and monitoring your use of our Hosted Services and services. The legal basis for this processing is legitimate interests, namely the proper administration of our Hosted Services.
    6. We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may be processed for the purposes of operating our Hosted Services, providing our services, ensuring the security of our Hosted Services and services, maintaining back-ups of our databases and communicating with you. 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 that you post for publication on our Hosted Services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our Hosted Services. The legal basis for this processing is consent.
    8. We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
    9. We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is legitimate interests, namely the performance of the contract with you.
    10. We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our Hosted Services ("transaction data"). The transaction data may include your card details and the transaction details. The source of the transaction data is you and/or our payment services provider. The transaction data may be processed for the purpose of supplying the purchased 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; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely the proper administration of our Hosted Services and business.
    11. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
    12. We may process information contained in or relating to any communication that you send to us ("communication data"). The communication data may include the communication content and metadata associated with the communication. The communication 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 communications with our Hosted Services users and the proper administration of our Hosted Services and business.
    13. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 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.
    14. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
    15. 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.
    16. Please do not supply any other person's personal data to us, unless we prompt you to do so.
  3. Providing your personal data to others
    1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
    2. Your personal data held in our Hosted Services database will be stored on the servers of our hosting services providers identified at aws.amazon.com.
    3. We may disclose any of your personal data to our suppliers or subcontractors identified below insofar as reasonably necessary for the purposes of analysing and developing our Hosted Services.
    4. Third Party Processors and the location of Personal Data
      Name Server locations
      Google United States, Europe
      Streak United States
      Slack United States, Europe
      Trello AWS EC2 data centers.
      Plivo Chicago, Dallas, London, Hong Kong, and Sydney.
      Linode United States, Asia Pacific, European Union
      Firebase United States, Europe
      Survey Monkey United States
      Mode analytics United States, Europe
      Hubspot United States, Europe
      Heroku Europe
      Sentry United States, Europe
      AWS Europe
      Apple United States, Europe, Asia, Global
    5. Financial transactions relating to our Hosted Services are handled by our payment services providers, Stripe . We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://stripe.com/gb/privacy.
    6. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure 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.
  4. Retaining and deleting personal data
    1. This Section 4 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data (by anonymisation).
    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 your personal data as follows:
      1. usage data will be retained for a minimum period of 1 year following the date of collection, and for a maximum period of 3 years following that date;
      2. account data will be retained for a minimum period of 1 year following the date of closure of the relevant account, and for a maximum period of 3 years following that date;
      3. profile data will be retained for a minimum period of 3 months following the date of closure of the relevant account, and for a maximum period of 6 months following that date;
      4. service data will be retained for a minimum period of 1 year following the termination of the contract under which the service was provided, and for a maximum period of 3 years following that date
      5. publication data will be retained for a minimum period of 1 year following the date when the relevant publication ceases to be published on our Hosted Services or through our services, and for a maximum period of 3 years following that date;
      6. enquiry data will be retained for a minimum period of 1 year following the date of the enquiry, and for a maximum period of 3 years following that date;
      7. customer relationship data will be retained for a minimum period of 1 year following the termination of the relevant customer relationship, and for a maximum period of 3 years following that date;
      8. transaction data will be retained for a minimum period of 1 year following the date of the transaction, and for a maximum period of 3 years following that date;
      9. notification data will be retained for a minimum period of 1 year following the date that we are instructed to cease sending the notifications, and for a maximum period of 3 years following that date (providing that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications); and
      10. communication data will be retained for a minimum period of 1 year following the date of the communication in question, and for a maximum period of 3 years following that date.
    4. Notwithstanding the other provisions of this Section 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.
  5. Security of personal data
    1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
    2. We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
    3. Data relating to your enquiries and financial transactions that is sent from our Hosted Services, or from our Hosted Services to your device, will be protected using encryption technology.
    4. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
    5. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our Hosted Services confidential and we will not ask you for your password (except when you log in to our Hosted Services).
  6. Security of personal data
    1. In this Section 6, 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. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    2. Your principal rights under data protection law are:
      1. the right to access - you can ask for copies of your personal data;
      2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
      3. the right to erasure - you can ask us to erase your personal data;
      4. the right to restrict processing - you can ask use to restrict the processing of your personal data;
      5. the right to object to processing - you can object to the processing of your personal data;
      6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
      7. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
      8. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
    3. To the extent that the legal basis for our processing of your personal data is:
      1. consent; or
      2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
      and such processing is carried out by automated means, you have the right to ask for human intervention where such automation leads to decisions that have legal or similar such effect.
    4. If you consider that our processing of your personal data 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.
    5. To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
    6. You may exercise any of your rights in relation to your personal data by written notice to us at hello@easypeasyapp.com.
  7. Third party websites
    1. Our Hosted Services includes hyperlinks to, and details of, third party websites.
    2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
  8. Personal data of children
    1. Our Hosted Services are targeted at persons over the age of 18.
    2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
  9. Updating information
    1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
  10. Acting as a data processor
    1. In respect of profile and customer relationship data provided to us by a nursery, school or institution, we do not act as a data controller; instead, we act as a data processor.
    2. Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
  11. About cookies
    1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    3. Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
  12. Cookies that we use
    1. We use cookies for the following purposes:
      1. authentication and status - we use cookies to identify you when you visit our Hosted Services and as you navigate our Hosted Services, and to help us determine if you are logged into our Hosted Services;
      2. personalisation - we use cookies to store information about your preferences and to personalise our Hosted Services for you;
      3. 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 Hosted Services and services generally;
      4. advertising - we use cookies to help us to display advertisements that will be relevant to you;
      5. analysis - we use cookies to help us to analyse the use and performance of our Hosted Services and services; and
      6. cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
  13. Cookies used by our service providers
    1. Our service providers use cookies and those cookies may be stored on your computer when you visit our Hosted Services.
    2. We use Google Analytics. Google Analytics gathers information about the use of our Hosted Services by means of cookies. The information gathered is used to create reports about the use of our Hosted Services. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.
    3. We use a Facebook pixel on our Hosted Services. Using the pixel, Facebook collects information about the users and use of our Hosted Services. The information is used to personalise Facebook advertisements and to analyse the use of our Hosted Services. To find out more about the Facebook pixel and about Facebook's use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook's use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.
  14. Managing cookies
    1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
      1. https://support.google.com/chrome/answer/95647 (Chrome);
      2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
      3. https://help.opera.com/en/latest/security-and-privacy/ (Opera);
      4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
      5. https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
      6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
    2. Blocking all cookies will have a negative impact upon the usability of many websites.
    3. If you block cookies, you will not be able to use all the features on our Hosted Services.
  15. Cookie preferences
    1. You can manage your preferences relating to the use of cookies on our Hosted Services by visiting: www.easypeasyapp.com
    1. We may update this policy from time to time by publishing a new version on our Hosted Services.
    2. You should check this page occasionally to ensure you are happy with any changes to this policy.
  16. Our details
    1. Our Hosted Services are owned and operated by Character Counts Ltd.
    2. We are registered in England and Wales under registration number 08977183, and our registered office is at 20-30 Whitechapel Road, London, England, E1 1EW.
    3. Our principal place of business is at 20-30 Whitechapel Road, London, England, E1 1EW.
    4. You can contact us
      1. using our Hosted Services contact form;
      2. by email, using hello@easypeasyapp.com.
  17. Data protection registration
    1. We are registered as a data controller with the UK Information Commissioner's Office.
    2. Our data protection registration number is 00012745016.
  18. Data protection officer
    1. Our data protection officer is Jane Bradbury.

This Privacy Policy was last updated in May 2020.