Privacy and Cookie Policy

Last update: April 2020

1. Introduction: Data Controller

We at Kloodle Limited take privacy and data protection seriously. We are fully committed to respecting and protecting your personal information as this Privacy and Cookie Policy (“Policy”) will outline. If you have – after reading this Policy – any questions you are always welcome to email us at privacy@kloodle.com. 

This Policy applies to Kloodle, a trading name of Kloodle Limited, a company registered in England and Wales under registration number 08497166 with its registered address: 21 Broad Street, Bury, Lancashire. We may refer in this Policy to Kloodle as “we”, “us” or “our”.

This Policy also applies to the storing and processing of personal data by schools that are our direct customers. Please check our Children’s Privacy Statement for information about the use of our services by children.

In accordance with Article 13 and 14 GDPR (EU 2016/679) we inform our visitors and subscribers (“User(s),” “you,” or “your”) about our privacy and data protection policies. The Policy governs the privacy of visitors on our website and subscribers to our services and sets out the relevant areas of privacy and data protection. It will summarize our obligations as Data Processor. Moreover, we will explain the way we store, process, and protect data and personal information. Please read Section 6 of this Policy where all your rights under the applicable law are mentioned.

2. Our website

We proactively protect your privacy and make sure all necessary steps are taken to protect your privacy. Our website complies with all data protection laws and regulations in the UK and Wales that apply to your privacy. Currently, because of Brexit, the GDPR applies in a so-called transitional period. In the event of relevant changes, we will inform you immediately. However, you are always responsible for checking this page regularly for any updates and changes.

3. Contacting us

In case Users are contacting us through our website or by creating an account, they do so in their discretion and at their own risk. Your personal data is kept private, is fully processed in a secure manner, and in accordance with a reasonable retention period based on the applicable law. We guarantee a safe and secure form of data transmission. However, each User remains solely responsible for providing his/her information to us.

When you contact us through the Kloodle website, mobile application, social media channels or by any other means, we will retain your data based on legitimate business interests, and your data will be stored by us as long it is legally required. 

4. Use of your personal data

In addition to the purposes listed in this Policy, your personal data may be used for other purposes that are relevant to our business:

• Personal information is collected to build an online record of achievement and a reflective journal for students;
• Data is collected to identify the school or college a User belongs to;
• Email is collected communicate information about our system to User;
• Data is inputted by students and used by schools and colleges for their records to capture information such as work experience participated in, education history, activities participated in, reflections on activities;
• Track your usage of our websites and monitor your activity to improve our services.

This list is by no means complete, and your data may be used in other ways as long as we have obtained your express permission or in case of a legitimate business interest or legal duty.

5. Children and privacy

Please, always seek the guidance and permission of your parent or legal guardian before using our services and providing us with personal information. We do not expressively collect or process any personal data from children under the age of thirteen (13). If you are aged twelve (12) or under, we ask you to do not provide us with any information regarding yourself and others. 

If you are the parent or legal guardian of a child who is under the age of thirteen (13) and you become aware that your child by using our services gives us personal information without your consent, please contact us at: privacy@kloodle.com. After a request for removal from a parent or legal guardian, we will immediately delete all information regarding minors from systems. When you are under the age of sixteen (16), we may also seek to obtain the consent of your parent or legal guardian. Please check our Children’s Privacy Statement for information about the use of our services by children.

6. Third-Party Processors

Kloodle makes use of third parties in order to operate our services. These parties have limited access to your data. Under the GDPR, those third-parties are Data Processors. We make use of the following third-party processors. Please check their respective privacy policies.

In the future, we may work with other third-party service providers with who Kloodle will act on a daily basis, including but not limited to IT system and service providers, marketing and sales agencies, market research organizations, data or storage service providers.

All third-party service providers are bound by an agreement to prevent them from using your personal data in any different way than is instructed to them by us. Each third-party service provider may make use of their own Data Processors. But in any case, they have the legal obligation to meet the same level of data protection. We will never take any responsibility or be liable for any data breaches made by the Data Processors, or their sub-processors. 

In case your personal information is transferred out of the European Economic Area, or the UK and Wales, the country it is transferred to must have the same level of privacy and data protection laws as in the GDPR. 

7. Your rights

Under the GDPR, you are considered a Data Subject with certain individual rights. You have the following rights.

Access to your personal data

You have the right to receive a copy of the personal data we have stored and information about how we process your data.

Correction of your personal data

If your data is incorrect or incomplete, you can correct it yourself by logging into your account or by contacting us at privacy@kloodle.com

Erasure of your personal data 

In case you believe we don’t have good reason to process your information for a longer period of time, you can request the deletion of your personal data. We will immediately grant such a request unless there is a legal obligation to keep your personal data for a more extended period of time. 

Transfer of your personal data 

On your request, we may always provide you with a digital copy of your data in a machine-readable format, or transfer it directly to a new Controller. 

The objection to the processing of personal data

You can always request us to discontinue the storing and processing of your data in a particular way. In addition, you can also object in case we do so based on your consent by contacting us. 

Right to file a complaint

We’d like to resolve any complaints directly with you. Please contact us at privacy@kloodle.com. In any event, you also have the right to complain to the Information Commissioner’s Office (ICO) by calling or emailing them through this link: https://ico.org.uk/make-a-complaint/.

8. Opt-out, social media and third-party websites

We may send you marketing materials and specific offers unless you have explicitly requested us not to do so. We always provide Users the option to opt-out from receiving such messages. However, you cannot opt-out from messages necessary for the fulfillment of our contractual obligations. Such communications also may take place with you directly through social media when you contacted us via social media.

Our website may use direct links to social media, such as sharing options for web content. Users are solely responsible for the use of the respective social media channel through our website. Users must use social media platforms with all necessary care, particularly regarding their privacy and personal information. 

Our website and/or mobile application may contain links to third-party websites. We do verify the contents of those websites. However, we cannot guarantee the quality and accuracy of the contents of such websites. As a result, Users should be advised before they click such external links. Users may do so is at their own risk. Kloodle is never liable for any damages or losses caused by visiting any external links.

9. Changes to our Privacy Policy

We may amend our Privacy Policy from time to time to comply with new privacy laws and regulations. Each User is solely responsible for checking this page regularly to see if there are any changes in our privacy and data protection laws.

10. Use of Cookies

We use cookies to improve the experience of each User on our website. On their first visit, each User may allow or disallow the use of cookies on their computer or device. This practice complies with current legislation to obtain explicit consent from Users before placing cookies. 

Cookies are small files saved to the User’s hard drive that track, save and store information about the usage of the website. It allows us to offer our Users a tailored experience on our website. If you wish to deny the use and storage of cookies, you should take all necessary steps within the security settings of your web browsers by blocking all cookies from our website.

In addition, we make use of tracking software from Google Analytics and Intercom that will save a cookie to your hard drive to monitor your engagement on, and usage of our website. The use of Google Analytics does not encompass the storage of personal information. In the future, other cookies may be placed through the use of external vendors for conversion or referral tracking. We will always inform you when that is the case when you visit our website for the first time.