PRIVACY POLICY

Introduction

Wendy Pye Publishing Ltd (WPPL, we, us. our) is committed to providing safe educational websites, applications and other platforms (collectively defined as Sites) for teachers, parents and students. To help ensure a rewarding online experience for our visitors, we provide you with this outline of our information and privacy policy (Policy).
As we continue to offer new and different types of content and services, we may modify our Policy from time to time. However, we will treat all personal information we collect in accordance with the Policy in effect at the time the information is collected. If you use a Site or provide information to us via a Site (e.g. by trialing a subscription, purchasing a subscription or entering a competition) then you agree to be bound by the Policy.

If you do not agree to this Policy, or are under the age of 18 and your teacher, parent or guardian does not consent to you providing information to us, you should not use the Site or provide any information to us. Further information relating to the use of a Site (and our products and services including subscriptions) by children is set out in section 8 of this Policy.


If you have any questions, comments, or concerns regarding our Policy, please contact us at the following address: Wendy Pye Publishing Ltd, 413 Great South Road, Ellerslie, Auckland 1051; support@sunshinedigital.net


1. What information do we collect?

In the course of providing products and services (including subscriptions) through a Site and enabling the creation of accounts for subscriptions and free trial access, personal information will be collected, being information relating to an identifiable individual. This personal information may include information such as name, address, phone number, date of birth, email address, log-in details and passwords, payment details, school names, teacher names, class room name or number, reading level and reading and activity results. We may also collect details of your visits to a Site including IP address and information relating to the areas of the Site that you visit.


2. How will we use this information?

We may use your personal information for the following purposes:

    (a) to operate and manage the Sites and allow you to use the content on the Sites;
    (b) to establish accounts, process any orders for products or services you have purchased from us including
 subscriptions, and to contact you about them;
    (c) to look at and respond to any messages, complaints or other queries you might send us;
    (d) to notify you about any changes to any of our the Sites, products or services;
    (e) to identify you and provide you with access to relevant parts of the Sites;
    (f) to send you newsletters and other communications where we think this may be of interest to you and for related
 marketing purposes;
    (g) to provide you with information on products or services we think might interest you based on your preferences;
    (h) to allow you to enter competitions and contact you about them;
    (i) to improve the content and services we offer; and
    (j) to make our the Sites, products and services more effective and user-friendly.


We may also use your personal information to comply with the requirements of any applicable law or, if we consider necessary, to meet legitimate business interests (e.g. to protect against fraud or other security threats).


3. How do we share information?

We may disclose your personal information to third parties in the following circumstances:

    (a) to any company within the WPPL group of companies;
    (b) to any third parties who need to use this information for the purposes of providing products or services through
 a Site or for the purposes for which we use information;
    (c) in the event that we sell or buy any business or assets, to a prospective seller or buyer of such business or assets;
    (d) to comply with applicable laws where disclosure of personal information is required.

Information may be transferred between countries (and servers located in such countries) as part of the sharing of personal information as above. Except as set out above or as required by applicable law or any regulatory authority, we will not otherwise disclose any personal information to any person unless you agree that we can.


4. What security measures do we take?

We are committed to providing safe educational Sites for teachers, parents and students. Transmission of information via a Site or over the internet is however never completely secure, and we cannot guarantee security of all personal information that might be transmitted to our website. However, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorised access, maintain data security, and correctly use the information we collect online.


5. Do you use Cookies?

To help ensure a rewarding online experience, Cookie technology helps us to know how many people visit us and where visitors go on a Site. Cookies are small bits of information we send to your computer. Among other things, this non-personally identifiable information allows us to know which areas are favourites, which areas need a bit of improvement, or what technologies and services are being used by our visitors so that we may continually improve online experiences.


6. How long will you keep my personal information?

We will retain your personal information while you have an account with us and are continuing to visit a Site and for as long as is reasonably necessary for the purposes set out in this Policy. Relevant factors will include the services that we provide, the need to comply with our contractual obligations, the need to enforce our contractual obligations and the need to comply with legal and regulatory requirements.


7. How can you access your personal information?

You may have rights under applicable laws (including as a data subject) to request access to personal information, rectification of personal information, deletion of personal information, the restriction or withdrawal of consent to processing of personal information or transfer of personal information. You may also have rights to make a complaint about any of the foregoing. Any requests or complaints must be made in writing. We will comply with any requests or respond to any complaints as required by applicable law.


8. Do you collect information from children?

We market and sell our subscriptions to adults (being teachers, parents or guardians) who purchase or otherwise subscribe to our products and services, which can then be used by children under the supervision of adults. We do not market or sell to children under 18, and we take what steps we reasonably can to seek consent from a parent or guardian whenever we can identify that a minor is attempting to purchase or register for a subscription to any product or service. If we do collect personal information from a child with the consent of an adult who supervises the use of a product or service, we will only collect information that is reasonably necessary for the child to participate in the use of the product or service.
Parents and teachers should instruct children to never volunteer personal information online without consent. Schools that allow children to use our products or services and provide consent to the collection of personal information on behalf of a child are in turn responsible for notifying and obtaining any consent required from parents to guardians under applicable law.


Effective Date

This Policy is effective as of 31 March 2019. WPPL reserves the right to change the Policy at its sole discretion. Users will be informed of any such change by WPPL posting a new privacy policy on relevant Sites. The effective date of any change of policy will be identified.