Scribeasy Privacy policy

Version 1.0 24/04/2018

1. Introduction

1.1 We are committed to safeguarding the privacy of visitors and service users of website and mobile applications to Scribeasy.com and subdomains.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of visitors and service users of website and mobile applications to scribeasy.com and subdomains; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4 Our website will incorporate privacy controls which affect how we will process your personal data. By using the privacy controls, you will be able to specify whether you would like to receive direct marketing communications and limit the publication of your information. You will be to access the privacy controls via a URL that we will provide.

1.5 In this policy, "we", "us" and "our" refer to Scribeasy LTD. For more information about us, see Section 13.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

3.2 We may process data about your use of our website 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 you and/or your students and/or your employer.  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 our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your account data ("account data"). The source of the account data is you and/or your students and/or your employer.

As part of commitment to protecting the privacy of our learners, their parents, instructors, teachers and any institutions they may be associated to, our, our general policy is to collect as little account data as possible. Details of account data vary according to the following user types and age ranges:

  • Starter users under 14 years of age: a public-facing pen-name, a username for login (we encourage users not to use real names), year of birth, gender (optional), password,  and an email address for a parent or guardian.
  • Starter users over 14 years of age: password and email address.
  • Family account mentor: name, password, credit card details (managed by PCI compliant third party), password and email address.

The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent to our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4 We may process  your information included in your personal profile on our website ("profile data"):

  • Starter users under 13 years of age: a public-facing pen-name ,(we encourage users not to use real names), year of birth, gender (optional),
  • Starter users over 13 years of age: a public-facing pen-name,(we encourage users not to use real names), year of birth, gender (optional)
  • Family account mentor: gender (optional), year of birth (optional), relationship to individual users

The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.5 We may process information that you post for publication on our website or through our services]("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and service.
Publication data includes stories created by learners, comments, summaries and assessment grades made by account holders or mentors, likes and other expressions of approval of published content by user, learning metrics, analytics and gamification aspects, derived from published materials, be they published with our domains or on third-party domains such as social media. Publication data will be processed  to enrich learning experience services: to provide learners and their mentors or instructors with insights and recommendations for improving literacy skills, such as spelling, grammar and lexical diversity, as well as indications of engagement and progress. This may provide references to learners’ performance against external educational benchmarks such as the UK National Curriculum, Common Core Standards etc, though not offered as an accredited assessment serviceThe legal basis for this processing is consent to our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.6 We may process information contained in any enquiry you submit to us regarding goods and/or 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 or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your email address, your card details and the transaction details. 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 consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.9 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 to our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.10 We may process information contained in or relating to any communication that you send to us  ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication.  Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping . The legal basis for this processing is consent to our legitimate interests, namely the proper administration of our website and business and communications with users.

3.12 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 consent to our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.13 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 consent to our legitimate interests, namely the proper protection of our business against risks.

3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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.

3.15 Please do not supply any other person's personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 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.

4.3 We may disclose publication data to third-party suppliers or subcontractors insofar as reasonably necessary for providing  services providing text to speech, grammatical feedback, detection and correction of errors in writing, assessment of and recommendations for lexical diversity and well-being. We are currently researching strategy for delivery of such services and will update this privacy policy document and provide opt-outs whenever such services necessitate third-party suppliers or subcontractors. We do not currently supply publication data to third parties, but may do so in the future, in which case we will update this privacy policy and require all our users to consent to the changes in policy.

4.4 Financial transactions relating to our website and services are may be handled by our payment services providers, Braintree, a division of Paypal. 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 here.

4.5 In addition to the specific disclosures of personal data set out in this Section 4, 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to [countries outside the European Economic Area (EEA)].

5.2 We and our other group companies have offices and facilities in the United Kingdom of Great Britain and Northern Ireland and Spain. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the General Data Protection Regulation, a copy of which can be obtained from here

5.3 The hosting facilities for our website are situated in the United States of America.  Google Cloud provides application hosting, user authentication, database services and hosts some image assets:  Data Processing and Security Terms , EU Model Contract Clauses.   Squarespace hosts the scribeasy.com marketing website :  Privacy Policy here . Cloudinary is our content distribution network (CDN) providing hosting of image assets: Privacy Policy here, and Amazon WS is also used as a CDN, Privacy Policy here.

The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, the EU-US Privacy Shield, a copy of which you can obtain from here.

5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 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.

6.3 We will retain your personal data as follows:

(a) Account, profile, enquiry, transaction,  correspondance and notification data  will be retained for a minimum period of 90 days following subscription expiry, and for a maximum period of 365 days  following subscription expiry.

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of publication data will be determined based on its utility for providing services to promote literacy, creative writing and wellbeing. Some publication data will be used to train machine learning algorithms for the purposes of teaching literacy, such as error detection and correction. This will involve creating datasets and corpora from publication data. Such data will be anonymised as far as possible, using NER (Named Entity Recognition) to remove as much potentially sensitive personal data as possible, and updated periodically to ensure data subjects’ right to data deletion.

6.5 Notwithstanding the other provisions of this Section 6, 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.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

8. Your rights

8.1 In this Section 8, 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.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, 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.  You can access your personal data by visiting the user profile and viewing contents you have created and shared when logged into our website.

8.4 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.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 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. 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 the processing is for the establishment, exercise or defence of legal claims.

8.8 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.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) 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 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.

8.11 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.

8.12 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.

8.13 You may exercise any of your rights in relation to your personal data [by written notice to us] OR [by [methods]][, in addition to the other methods specified in this Section 8].

9. About cookies

9.1 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.

9.2 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.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website. Cookies used for this purpose are: firebase:authUser and firebase:host

(b) status - we use cookies to help us to determine if you are logged into our website. Cookies used for this purpose are: firebase:authUser  and firebase:host

(c) cookie consent - we will use cookies to store your preferences in relation to the use of cookies  - cookies used for this purpose will be listed here once cookie consent is implemented.

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: _ga and _gid

11.4 We use Squarespace to provide hosting.  This service uses cookies for purposes specified in its privacy policy.  You can view the privacy policy of this service provider at https://www.squarespace.com/cookie-policy/ . The relevant cookies are:MUID, MUIDB, SS_MATTR, SS_MID, __utma,  __utmb, __utmc, __utmt, __utmz, __zlcmid, _ga, _gac_UA-91901-13, _gid, _tq_id.TV-72458109-1.7824, _uetsid, crumb, mp_b36aa4f2a42867e23d8f9907ea741d91_mixpanel, ss_cid, ss_cpvisit, ss_cvisit, ss_cvr, ss_cvt, ss_lastid. 

12. Managing cookies

12.1 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:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13. Our details

13.1 This website is owned and operated by Scribeasy LTD

13.2 We are registered in England under Companies House number 11247003.and our registered office is at

4 Spire Place, Warlingham  CR6 9LW

13.3 Our principal place of business is at 81 Herne Hill Road London SE24 0AY.

13.4 You can contact us:

(a) by post, to 81 Herne Hill Road London SE24 0AY;

(b) using our website contact form;

(d) by email, using the email address published on our website from time to time.

14. Data protection officer

14.1 Our data protection officer's contact details are: Paul Ricketts, paul@scribeasy.com.