MARCOPOLO World School
Privacy Policy

Last updated: 22nd May 2018




MarcoPolo Learning, Inc. (“MarcoPolo”, “we”, “our”, or “us”) takes your privacy seriously. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you or your child (“personal information”).

MarcoPolo operates a number of services that allows your children to access educational and entertaining videos, games and other content and for you to track your children's progress and use of this content, which we make available through the our mobile applications (the "Apps") and our website at www.marcopololearning.com (the “Service”).

This privacy policy applies to our Apps and Service including but not limited to World School, Ocean, Arctic, Weather, Recall and our Website. Terms used in this privacy policy have the same meaning as in our Terms of Service, unless otherwise defined in this privacy policy. Before accessing or using any of our Apps and Services, please ensure you have read and understood this privacy policy.

We may amend this privacy policy from time to time. If we make changes in the way we use personal information, we will notify you by posting an announcement in our Apps and at the top of this privacy policy. You are bound by any changes to the privacy policy when you use our Apps after such changes have been first posted. If we make a material change to this privacy policy and we have your contact details, we will contact you to inform you of the changes before we make them and allow you to opt out.

The data controller for your personal information is MarcoPolo Learning, Inc., 2 Eastbourne Terrace, London W2 6LG, United Kingdom

TABLE OF CONTENTS

CHILDREN’S PRIVACY

Our Apps are intended for children aged 3 to 7. For World School specifically, parents or legal guardians must register, subscribe by making a payment and consent to use of the World School Service to allow their child to use the App. We do not process personal information of children without the consent of a parent or legal guardian.

If you would like to delete your account and all information associated with it, you can do so in the parent-section of the app. If you have any questions please contact us at support@marcopololearning.com

We do not actively allow children under the age of 13 to register with the World School Service. If you become aware that your child has provided us with personal information without your consent, please contact us using the details at the end of this privacy policy so that we can take steps to remove such information and terminate any account your child has created with us.

We work with a number of third party service providers (joint processors) in relation to children. For more information on these, please see Annex 3 below

GENERAL PRIVACY

What We Collect And How We Use It

We collect personal information about you and your child when you voluntarily submit information directly to us when you use our Apps. This can include information you provide to us when you register for an account, fill in a form on the World School Service, create or edit your (or your child’s) user profile on the World School Service, send messages using the World School Service, correspond with us by phone, e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to a survey, enter a promotion or use some other feature of the Apps and Service.

If you choose not to provide personal information, we may not be able to provide all of the World School Service to you or respond to your other requests.

The table at Annex 1 sets out the categories of personal information we collect about you and your child and how we use that information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients of the personal information and information as to how we determine applicable retention periods.

We also automatically collect personal information indirectly about how you and your child access and use the Apps and information about your device that you and your child use to access Apps.

The table at Annex 2 sets out the categories of personal information we collect automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients of the personal information and information as to how we determine applicable retention periods.

We may link or combine the personal information you provide and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you or your child). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Apps and Service and developing new products and features. We may also share such anonymised information with others.

The table at Annex 3 list the various third party service providers (joint processors) we work with to ensure the best possible experience from our Apps.

Marketing And Advertising

From time to time we may contact you with information about our products and services. Most marketing messages we send will be by email or push notifications. We do not send push notification to children without parental consent. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you. If you do not want to receive marketing messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. You can also change your marketing preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or logging into your account on our website or on the App and changing your preferences. If you do not want to receive push notifications, you can manage your preferences through your mobile device settings.

Where you have given us permission to do so, we may share your contact details with selected third parties so that they can provide you with information about products and services that they believe may be of interest to you.

Irrespective of your marketing preferences, we may contact you with important notices related to account administration and your child’s activities.

Cookies And Similar Technologies

We use cookies to distinguish you from other users of our Service. This helps us to provide you with a good experience when you browse our website and also allows us to improve Service.

Cookies are small pieces of code that allow for personalisation of Service experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your browser or device for record-keeping purposes.

We use the following types of cookies:

  • • Strictly necessary cookies. These are cookies that are required for the operation of the Service. They include, for example, cookies that enable you to log into secure areas of the Service, use a shopping cart or make use of e-billing services.
  • • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Service when they are using it. This helps us to improve the way the Service works, for example, by ensuring that users are finding what they are looking for easily.
  • • Functionality Cookies. These are used to recognise you when you return to the Service. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • • Targeting Cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests. We may also share this information with third parties for this purpose. We do not carry out targeting in relation to children.

The cookies we use are designed to help you get the most from the website but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our website. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.

Storing And Transferring Your Personal Information

Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage.

International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in. Some of our service providers will process your personal information outside of the European Union; these international transfers of your personal information are made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this privacy policy.

Your Rights In Respect Of Your Personal Information

If you reside in the European Union or a jurisdiction with similar privacy laws, you enjoy the following rights in respect of your personal information that we hold:

  • • Right of access. The right to obtain access to your personal information.
  • • Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
  • • Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
  • • Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit the personal information you have submitted to us by logging into your account on our App or website.

You may also have the right to lodge a complaint with the data protection regulator:

Information Commissioner's Office (ICO)
Wycliffe House, Water Lane,
Wilmslow, Cheshire,
SK9 5AF

The ICO can also be contacted via email at casework@ico.org.uk or via the ICO helpline on 0303 123 1113

Questions Or Concerns

If you have any questions or concerns regarding this privacy policy, please send us a detailed message to support@gomarcopolo.com, and we will try to resolve your concerns. You can also reach us at:

MarcoPolo Learning, Inc.
2 Eastbourne Terrace
London W2 6LG
UK

PRIVO-Cert™ Safe Harbor Certification Program

MarcoPolo Learning, Inc (owned and operated by MarcoPolo Learning, Inc) are included in PRIVO’s Kids Privacy Assured COPPA Safe Harbor Certification Program (“the Program”). The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO seal. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online. PRIVO aims to help parents and their children exercise control over personal information while exploring the Internet. The PRIVO COPPA certification seal posted on this page indicates MarcoPolo Learning, Inc has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at +1-646-764-3222 or privacy@marcopololearning.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

ANNEX 1 – PERSONAL DATA WE COLLECT

1) Category of personal information

Your registration information. Your email address and password.

How we use it

We use this information to:

  • • operate, maintain and provide to you the features and functionality of the Apps and/or Service;
  • • communicate with you including sending statements and invoices, service-related communications and marketing communications; and
  • • deal with enquiries made by you relating to the Apps and/or Service.

Legal basis for the processing


The processing is necessary for:

  • • the performance of a contract and to take steps prior to entering into a contract; and
  • • our legitimate interests, namely administering the Apps and Service, for marketing purposes and communicating with users.

Comments, chat and opinions. When you contact us directly, e.g. by email, phone, mail or by completing an online form or participating in online chat, we will record your comments and opinions.


How we use it

To address your questions, issues and concerns and improve the Apps and Service.


Legal basis for the processing

The processing is necessary for our legitimate interests, namely communicating with users.

Payment and transaction information. Information such as items purchased and date and time of your transaction.


How we use it

To facilitate transactions, detect and prevent fraud.


Legal basis for the processing


The processing is necessary for:

  • • the performance of a contract;
  • • our legitimate interests, namely the detection and prevention of fraud.

Location Information. We may collect information about your location where you choose to provide it to us (for example, your address if you correspond with us). Your device’s IP address may also help us determine an approximate location.


How we use it

• We may use an approximate location to ensure content on the Apps and Service is relevant to the city or country you are using your device in.


Legal basis for the processing

• The processing is necessary for our legitimate interest, namely to tailor our service to the user and to improve our service generally.

Preferences. Preferences set for notifications and marketing communications.

How we use it

• We use this information to provide notifications and send marketing communications in accordance with your choices.


Legal basis for the processing

• The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing communications.

Information provided by third parties. From time to time, we may receive information about you from third parties and other users. We may obtain information from third parties to enhance or supplement our existing user information. We may also collect information about you that is publicly available.

How we use it

• We may combine this information with the information we collect from you directly. We use this information to contact you, to send you advertising or promotional materials or to personalize the Apps and Service, to pre-populate online forms, and to better understand the demographics of our users.


Legal basis for the processing

• The processing is necessary for our legitimate interests, namely to tailor the Apps and Service to the user and to improve the World School generally.

Profile information for your child. The following personal information of your child will be collected when you create a profile for them: first name; birthday; favorite subjects; gender; and avatar.


How we use it

We use this information to:

  • • operate, maintain and provide to you the features and functionality of the Apps and Service;
  • • create your child’s profile on the App and to personalize content on the App to your child’s preferences.

Legal basis for the processing


  • • The parent or legal guardian of the child has given their consent to the processing.
  • • The processing is necessary for our legitimate interest, namely to tailor our service to the user and to improve our service generally.

All personal information set out above.


How we use it

• We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Apps and Service, to communicate with you, to monitor and improve the Apps and Service, and to help us develop new products and services.

Legal basis for the processing

• The processing is necessary for our legitimate interest, namely to administer and improve the Apps and Service.

2) Categories of recipients

As required in accordance with how we use it, we will share your personal information with the following:


  • • Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include providing mailing or email services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services.
  • • Select third parties. Third parties, so that they can provide you with information and marketing messages about products or services that may interest you.
  • • Purchasers and third parties in connection with a business transaction. Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.
  • • Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Service; and/or (c) protect the rights, property, or safety of MarcoPolo, our users or others.

3) Retention period

For no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.

For more information on our Data Retention policy please contact us at support@marcopololearning.com


ANNEX 2 – PERSONAL DATA COLLECTED AUTOMATICALLY

1) Category of personal information

Information about how you access and use the Apps and Service. For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Apps and Service, the time you access the Apps and Service and how long you use it for, whether you open emails or click the links contained in emails, whether you access the Apps and Service from multiple devices, and other actions you take on the Apps and Service.


How we use it

We use this information to:

  • • present the Apps and Service to you on your device;
  • • determine products and services that may be of interest to you for marketing purposes; and
  • • monitor and improve the Apps and Service and business, and to help us develop new products and services.


Legal basis for the processing


The processing is necessary for our legitimate interests, namely:

  • • to provide and tailor the Apps and Service to the user and to improve the Apps and Service generally
  • • to monitor and resolve issues
  • • to communicate with users
  • • to contact users
  • • for the detection and prevention of fraud.

Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the Apps and Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Apps and Service through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).


How we use it

We use information about how you use and connect to the Apps and Service to present it to you on your device and to determine products and services that may be of interest to you for marketing purposes.


Legal basis for the processing

As above, the processing is necessary for our legitimate interests, namely:

  • • to provide and tailor the Apps and Service to the user and to improve the Apps and Service generally
  • • to monitor and resolve issues
  • • to communicate with users
  • • to contact users
  • • for the detection and prevention of fraud.

Information about your child’s progression in the App. This includes records of your child’s answers and completion of in-App videos or games.


How we use it

We use this information to:

  • • operate, maintain and provide to you the features and functionality of the Apps and Service including providing you with analytics regarding your child’s performance, progression, interests and related behaviors; and
  • • monitor and improve the Apps and Service and business including by using analytics regarding this information, and to help us develop new products and services.

Legal basis for the processing

The processing is necessary for our legitimate interests, namely: to provide the Apps and Service to you and to improve the Apps and Service generally. MarcoPolo also uses consent as a legal basis for processing the child’s progress in the app.



2) Categories of recipients

As required in accordance with how we use it, we will share your personal information with the following:

Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include providing mailing or email services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services.

Select third parties. Third parties, so that they can provide you with information and marketing messages about products or services that may interest you.

Purchasers and third parties in connection with a business transaction. Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.

Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Service; and/or (c) protect the rights, property, or safety of MarcoPolo, our users or others.



3) Retention period

For no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.

For more information on our Data Retention policy please contact us support@marcopololearning.com


ANNEX 3 – THIRD PARTIES

We process you and your child's data with a number of third parties to provide the best possible experience. You will find these listed below along with details of how they are used.

We use the following third-party service providers (joint processors) in relation to you and your child’s data. These third parties do not share you or your child’s data with any other third parties. For more information on these third parties, please email us as support@marcopololearning.com

Mixpanel

Mixpanel is an analytics tool. We use this to track how you use apps such as World School. This allows us to see which areas of the apps work well and what can be improved.

Flurry Restricted

Flurry Restricted is another analytics tool that we use in some of our older apps e.g. Ocean. We use the special restricted version which is specifically made for children’s apps like ours.

Akamai

Akamai is a video-streaming service. We use this service to deliver video content in World School.

Amazon Web Services

Amazon Web Services hosts our servers which hold all user data for World School.

Unity

Unity is the one of the main tools we used to develop our apps.

Google Analytics

Google Analytics is another analytics tool. We use this for our website analytics.

We use the following third party service providers (joint processors) in relation to adults only.

AppsFlyer

Appsflyer is an attribution and marketing analytics tool. It is specifically designed to attribute which site or platform our World School users come from.

SendGrid

SendGrid is a communication-tool that we use to send emails to users, for example: newsletters, password resets or progress reports from World School.