Data Protection Privacy Notice

1. What is Personal Data?

Personal data is data that can be used to identify a living individual. The processing of personal data is governed by the EU General Data Protection Regulation (EU) 2016/679 and the Data Protection Acts 1988-2018.

2. Who are we?

We are Wriggle Learning Limited, a private limited company (no 591587) registered in Ireland at Unit G6, Calmount Business Park, Ballymount Road, Dublin 12, D12 XW25 (‘Wriggle’, ‘us’, ‘we’, ‘our’).

Wriggle (contact details below) is the data controller of any personal data that you or your child or your child’s school provides to us for the purpose of dealing with us. This means that Wriggle decides how your personal data is processed and for what purposes.

3. Our Commitment to Privacy

Wriggle is committed to protecting the privacy of children, parents, guardians and educators (‘data subjects’) that provide us with personal data. We have appropriate policies and procedures in place to process and protect any personal data that we hold about these data subjects in connection with the provision of products, services and information.

3. Child Safety

Parents and guardians are advised that use of the internet, including our website, by children should only be done with your permission, guidance and supervision. Children under the age of 16 must receive permission from their parent or guardian before sending personal data to us. Parents and guardians should take note of any parental notices included on the website and direct your child in a way that is consistent with these notices.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect you and your child’s personal data, we cannot guarantee the security of such data transmitted via the website and any transmission is at your own risk. Once we have received yours and your child’s data, we will use procedures and security features on the website to try to prevent unauthorised access. You acknowledge that we are not responsible for any intercepted information sent via the Internet, and to the extent permitted by law, you hereby release us from any and all claims arising from the use of intercepted information in any unauthorised manner.

You should be aware that when you or your child discloses personal data on our website or on our social media accounts, that information can be collected, correlated and used by third parties. These third parties or other website users or social media users may use you or your child’s information to send you or your child unsolicited messages. Such activities are beyond our control. Please do not post or allow your child to post any personal information on the website, on our social media accounts or otherwise on the Internet that you or your child wish to keep private.

Wriggle’s website and other communications channels may, from time to time, contain links to and from the websites of third parties to which we have no affiliation. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms and conditions and that we do not accept any responsibility or liability for those policies, terms and conditions or for the activities on those websites.

4. How do we process your data?

Wriggle complies with its legal obligations by using personal data only for specified, lawful purposes; by not collecting or retaining excessive amounts of data; by keeping personal data up to date; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate organisational and technical security measures are in place to protect personal data.

The personal data that we collect includes identification details (e.g. name, date of birth, school attending, user codes), location details (e.g. address), contact details (e.g. email address, phone number), banking details (e.g. debit card details) for payment processing and images (e.g. photos) where you consent to their use for marketing including social media purposes.

Children under the age of 16 who visit our website and/or provide us with personal data must have the consent of their parent or guardian. Adults who provide us with personal data in relation to children confirm that they are the parent or guardian of the children involved or have the express authority of such parent or guardian to provide such information.

5. What is the legal basis for processing your personal data?

Depending on how and why you engage with Wriggle we may use your personal data for the purposes set out in the following table which also sets out the legal basis(es) for processing your data:

Purpose	Legal Basis
Marketing and promoting Wriggle’s products and services events, news and activities	Consent (Article 6(1)(a) GDPR)
Sale of products and services and fulfilment of orders	Performance of a contract (Article 6(1)(b)) GDPR
Creating accounts for you with third parties including but not limited to educational publishers.	Performance of a contract
Provide technical support for devices and software purchased from Wriggle	Performance of a contract
Improving the functioning of our website and e-commerce shop to better serve customers	Wriggle’s legitimate interests (Article 6(1)(f) GDPR

6. Sharing your personal data

We do not sell, rent, share, trade or otherwise provide access to any of your personal data or that of your child except for certain trusted third parties. These include: delivery services used to deliver products that you order; educational publishers and software providers; insurance partners when you purchase gadget insurance; our professional advisors e.g. our auditors where disclosure is strictly necessary; payment processors for debit and credit card payments and other parties e.g. banks where disclosure may be necessary for purposes such as fraud prevention.

Please note that debit and credit card payments are processed by a third-party payments processor and that the processing of personal data for payment purposes is subject to their terms and conditions and their privacy policy. You can find more details on our payments page.

7. International Transfer

All personal data processed by Wriggle is stored within the European Economic Area or countries whose data protection regimes have been designated as adequate by the European Commission.

8. How long do we keep your data?

We keep personal data relating to children who visit our website for two years after they have completed secondary school. We keep personal data on parents and guardians for two years after their youngest child has completed secondary school. We keep data relating to educators for two years after their last interaction with Wriggle.

9. Your rights and your personal data

You (parents, guardians, children and educators) have the following rights with respect to your personal data:

• To access and request a copy of your personal data, which Wriggle holds about you;
• To request your personal data is erased where it is no longer necessary or lawful for Wriggle to retain such data (with an automatic right to erasure where the data relates to a person under 16);
• To request that a restriction is placed on further processing of your personal data where there is a dispute in relation to the accuracy or processing;
• To request that Wriggle correct any personal data if it is found to be inaccurate, incomplete or out-of-date;
• To object to the processing of personal data by Wriggle;
• To request that Wriggle provides you with a copy of personal data that you have provided and, in certain circumstances, to transmit that data directly to another data controller.

You also have the right to lodge a complaint with the Data Protection Commission should you be unhappy about any aspect of Wriggle’s handling of your or your child’s personal data or any request to us.

10. Contact Details

For further information about our policies or to exercise all relevant rights or submit a query or a complaint please in the first instance contact the Data Protection Coordinator at:

Wriggle Learning Limited,

Unit G6, Calmount Business Park,

Ballymount Road,

D12XW25

Email: data protection@wrigglelearning.ie

10. Complaints

You have the right to make a complaint to the Data Protection Commission which you can contact by phone: 1800 437 737; via website www.dataprotection.ie or by writing to:

The Data Protection Commission,

21 Fitzwilliam Square South

D02 RD28