LIFE NINJA PRIVACY AND COOKIES POLICY

Please note that where a Life Ninja Education Ltd application is provided to you through an Organisation you are affiliated with then in that instance you are subject to the Organisations particular data policies as they are Controller of your data. If under any circumstances Life Ninja Education Ltd are deemed to be Controllers of your data then these terms will also apply to you.

Note this agreement may be updated from time to time and you agree that you will be bound to the updated terms through your ongoing use of the apps and platform.

Where the application is provided to you directly by Life Ninja Education Ltd without a third party Organisation providing you with access then the terms of this Privacy Policy apply to you.

Where applicable this privacy policy applies to all applications supplied on the Life Ninja Education platform including Zap Maths, the Zap Range, Message Ninja and Learning Ninja.

OUR PRIVACY POLICY IN PLAIN LANGUAGE

1. We only ask for data we need
2. We only store data for as long as we need to
3. We will resolve any issues quickly
4. It’s your data; if you want to see it, have it or delete it just let us know

YOUR RIGHTS UNDER GDPR (GENERAL DATA PROTECTION REGULATION)

1. The right to be informed about how your personal information is being used
2. The right to access the personal information we hold about you
3. The right to request the correction of inaccurate personal information we hold about you
4. The right to request that we delete your data, or stop processing it or collecting it, in some circumstances
5. The right to withdraw consent for any communication or consent-based processing at any time
6. The right to request that we transfer or port elements of your data either to you or another service provider
7. The right to complain to your data protection regulator – as a United Kingdom registered company we fall under the Information Commissioner’s Office (ICO)

To exercise any of these rights contact us at privacy@lifeninja.net or write to us at Studio 109, 109b Marton Road, Middlesbrough, England, TS1 2DU. If your application is provided via a school or other third party please contact them in the first instance.

WHAT THE PRIVACY POLICY GOVERNS

This privacy policy governs Your use of the software application(s) (“Application”) for mobile and any other device(s) that was created by Life Ninja Education Limited and the processing of the data obtained and stored as part of providing that service.

DATA CONTROLLER AND DATA PROCESSOR

You should know that Life Ninja Education Limited (ZA639692) is a processor of your personal information registered with ICO, the Data Commissioner in the United Kingdom. Where the software is provided through an Organisation you are affiliated with the organisation is the Data Controller of your personal data. Where software is provided directly to you through Life Ninja Education Ltd, Life Ninja is Data Controller of your personal data. As such we are subject to the principles of GDPR (EU) 2016/679 (EU GDPR). Regardless of your geographic location as a user GDPR principles and obligations are to be extended to all persons. The principles of GDPR are regarded as a human right and as such are extended to all our users. The legal bases for which we collect and use the information depends on what the information is and why we collected it.

WHERE THE SCHOOL OR ORGANISATION IS THE DATA CONTROLLER

Where an application is provided to a user by a school or organisation which uses the provided platform to add the parent and their child’s relevant data then the school is fulfilling the role of Data Controller and Life Ninja Education Ltd (the application and platform publisher) is fulfilling the role of a Data Processor.

In the event you wanted to exercise any of your rights under GDPR you would contact the school to make your request. Life Ninja Education Ltd admin systems have been designed to help schools or organisations easily fulfil their obligations under GDPR, we also will assist schools or organisations as required to help them fulfil any such obligations as required.

THE FOUR LEGAL BASIS WE RELY ON

Contract. This means we need the information to perform our contract with you.  For example, in order to create a login to your school or organisation account we need to be provided with your email address.

Legitimate Interests. This means we have a legitimate interest that does not outweigh your privacy rights. When we collect and process information based on our legitimate interests, we consider how we can accomplish what we need to in a way that is the least obtrusive on your privacy.

Legal Obligation. We may need to use your personal information to comply with a law enforcement preservation request, subpoena, or other legal process or to protect the rights of other users.

Consent. If we have no other legal basis for collecting or using your information, we will ask you for consent for a specific purpose.  If we do, you have the right to withdraw consent at any time. Withdrawing your consent will not apply to any processing conducted in reliance on lawful processing bases other than consent.

WHAT ARE MY OPT-OUT RIGHTS?

Opt-out of all information collection by uninstalling the application, you can use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. If you wish to have your data erased as is your right in most circumstances under GDPR you will need to contact us or the third party for example your child’s school through which you have received this application. If you for example are using Message Ninja an application provided through your child’s school, the school are in this instance the Data Controller using the Message Ninja platform to Process your information and as such the school as Data Controller would be responsible to enact a request to have any users information deleted (forgotten).

DATA RETENTION POLICY, MANAGING YOUR INFORMATION

We will retain User Provided data for as long as You use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. If You would like us to delete User Provided Data that You have provided via the Application, please contact us at privacy@lifeninja.net and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

CHILDREN

If a parent or guardian becomes aware that his or her child has provided us with information without their (the parents or guardians) consent, he or she should contact us at privacy@lifeninja.net. We will delete such information from Our files within a reasonable time.

SECURITY

We are concerned about safeguarding the confidentiality of Your information. We provide physical, electronic, and procedural safeguards to protect information We process and maintain. For example, We limit access to this information to authorised employees and contractors who need to know that information in order to operate, develop or improve our Applications.

We use leading third party providers for data storage and application security in order to  provide industry standard robust security for information We process and maintain. We also undertake regular internal security testing and employ the services of third party security experts to rigorously test the security of our applications and processes.

WHERE THE INFORMATION IS PROCESSED AND STORED

Life Ninja processes information using EU located servers and services. These services include a number of Google services including Firebase and G-suite utilised as part of the Control and Processing of Customer and User information. Life Ninja utilises the latest technologies and established third parties who are committed to the principles and obligations of the GDPR. While the various Google services we employ are based in Europe Google reserves the option to process data using US based systems as the need arises to deliver a consistent service, in the event they should need to do this any such action would fall under the commitment and obligations of the EU-U.S. Privacy Shield Framework.

Where a school or organisation acts as a data controller on behalf of their parents/users, they have an obligation to ensure the safety and security of their systems to protect access to users data.

Should you decide to use our services when you are outside of the EEA, to deliver the service required your information may need to be transferred outside the EEA.

Where users be there legal entities or organisations are based outside of the UK all data will be processed according to GDPR guidelines. We may also employ the services of contractors or agents outside of the UK to serve foreign or all markets, any data managed or acquired in the course of their duties will be processed according to GDPR guidelines.

SUBSCRIPTIONS

Where a mobile application includes subscriptions the relevant subscription terms are detailed in both the App Store and Google Play store as well as the application itself.

CHANGES

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes. You can request historical versions of this policy by email. Any new versions of this privacy policy will replace any former versions and You agree to be bound to the latest version as long as You are using this application.

DATA BREACH

The GDPR introduces a duty on all organisations to report certain types of personal data breach to the relevant supervisory authority. We must do this within 72 hours of becoming aware of any breach, where feasible. If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, we must also inform those individuals without undue delay.

YOUR CONSENT

By using the Application, You are consenting to Our processing of Your information as set forth in this Privacy Policy now and as amended by Us. “Processing,” means using cookies on a computer/handheld device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United Kingdom. If You reside outside of the United Kingdom Your information will be transferred, processed and stored under the United Kingdom’s privacy standards.

INFORMATION THE APPLICATION MAY OBTAIN AND HOW MAY IT BE USED

Potential sources of collected personal information

1. Schools, teachers and organisations when they register with Life Ninja Education Ltd.
2. Information inputted by schools, teachers and organisations.
3. Parents and users when their device and information is associated with the information linked to their account set up by the school or organisation.
4. Marketing and promotional activities where an employee, partner or agent of Life Ninja Education Ltd acquires school, teacher, parent and or other user information in the course of their marketing and promotional activities.

User Provided Information

The Application obtains the information You provide when You download and register the Application. Registration with Us is optional. However, please keep in mind that You may not be able to use some of the features offered by the Application unless You register with Us.

When You register with Us and use one of the Applications, You may provide (a) Your name, email address, age, user name, password and other registration information; (b) transaction-related information, such as when you respond to any offers, or download or use applications from us; (c) information You provide Us when You contact Us for help; (d) information You enter into Our system when using the Application, such as contact information and chosen username; (e) photos and other uploads submitted to the app by yourself or the school or organisation.

We operate on a minimum user footprint policy in keeping with GDPR rules and guidelines.

We may also use the information You provided Us to contact You from time to time to provide You with important information, required notices and marketing promotions. Any permission for communications from Life Ninja Education Limited or affiliates must be given explicitly by you and recorded as such.

Automatically Collected Information

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile devices unique device ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browsers You use, and information about the way You use the Application.

Do third parties see and/or have access to information obtained by the Application?

Yes, we will share your information with third parties only in the ways that are described in this privacy statement. Such as where relevant and agreed to such as Server Hosts and Analytics providers like Google and Firebase.

We may disclose User Provided and Automatically Collected Information

As required by law; such as to comply with a legal order, or similar legal process. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. And with Our trusted service providers who work on Our behalf, who do not have an independent use of the information We disclose to them, and have agreed to adhere to the rules set forth in this privacy statement such as Google and Firebase.

If Life Ninja Education Ltd is involved in a merger; acquisition or sale of all or a portion of its assets this agreement You enter into by downloading and using the application will pass over to the new owners.

AUTOMATIC DATA COLLECTION AND ADVERTISING

We may work with analytics tools from companies such as Google to help Us understand how the Application is being used, such as the frequency and duration of usage.

NOTE ON THE APP STORES – OWNERSHIP AND LIABILITY

All applications on the Google Play Store and Apple App Store listed under the Life Ninja Education Ltd account on Google Play Store and Life Ninja Ltd account on the Apple App Store are owned and managed by Life Ninja Education Ltd. For an interim period Life Ninja Education Ltd apps are provided on the Apple App Store via the Life Ninja Ltd account until such time as they are transferred to the Life Ninja Education Ltd account. The users of the apps agree through downloading and using the applications that Life Ninja Education Ltd is owner and provider of the apps and that all liability for the provision of the apps lies with Life Ninja Education Ltd and any legal claims for whatever reason in relation to the apps should be directed against Life Ninja Education Ltd.

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ZAP LEARNING SPECIFIC TERMS

The Zap range of products including Zap Maths are owned by Zap Learning Ltd. Zap Learning Ltd is owned jointly by Life Ninja Education Ltd and HW Trading Ltd. The Zap Range is provided on the Life Ninja Education platform, the code and graphical content among other areas is owned by Life Ninja Education Ltd and provided effectively under licence to be used in Zap Learning products. All user data from the use of Zap Maths is processed and managed exclusively by Life Ninja Education Ltd. However any information provided through using the contact forms on zaplearning.co.uk and any zaplearning.co.uk email addresses is subject to Zap Learning Ltd’s Data Registration and managed and controlled by Life Ninja Education Ltd’s Data Controller who is also the Data Controller for Zap learning Ltd.

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MESSAGE NINJA SPECIFIC TERMS

Payment Processing (Message Ninja specific terms)

Life Ninja provides the facility in the Message Ninja application to process payments. In order to provide this service the School or Organisation will need to set up an account with Square our carefully selected third party payment provider (third party payments providers may change as we endeavour to provide you with the best possible processing fees and service). The parent or user is then able to pay a bill raised by the school or organisation securely through the Message Ninja application without sharing any payment information other than the amount billed with Life Ninja. The School or Organisation, Parent/ User will be using the services of the third party payments provider and be subject to the payment providers own privacy policy and terms and conditions.

Life Ninja Education Ltd doesn’t process, store or have access to any sensitive payment information whatsoever at any point in the process.

The information that is visible and stored by Life Ninja Ltd and on behalf of the Organisation is the payment amount, the payment description and where the user opts to store their payment details with the Third Party Payment provider ie Square then Square will provide Life Ninja Education Ltd a list of the users stored cards with all the card numbers anonymised except the last 4 digits.

AUTOMATIC DATA COLLECTION AND ADVERTISING (Message Ninja specific terms)

We may work with analytics tools from companies such as Google to help Us understand how the Application is being used, such as the frequency and duration of usage.

We may provide non personal identifying targeted advertising in MESSAGE NINJA. An example of this would be an advert or offer appearing in your events feed in Message Ninja advertising a holiday club in your local area. In this instance an advert for the holiday club could appear as an event in the application where your school falls within an appropriate geographic radius of the local event being advertised.

SURVEYS AND OTHER ADVERTISING ENGAGEMENTS (Message Ninja specific terms)

Life Ninja Education Ltd application(s) may include features where you are able to choose to participate in rewarded engagements such as completing surveys or watching video adverts. Life Ninja Education Ltd may choose to share a portion of any resulting remuneration in part or in full with you as the end user or the Organisation with which you are affiliated. Any such sharing of remuneration will be clearly described in the relevant application. In the event that you participate in any such engagements you will be sharing your data in some instances directly with the third party (such as Pollfish) who will be responsible for the data you have provided and you will be subject to their particular privacy policies and Terms and Conditions in regards to the particular actions taken and data shared with them.

“Survey Serving Technology

This app uses Pollfish SDK. Pollfish is an on-line survey platform, through which, anyone may conduct surveys. Pollfish collaborates with Developers of applications for smartphones in order to have access to users of such applications and address survey questionnaires to them. When a user connects to this app, a specific set of user’s device data (including Advertising ID which will may be processed by Pollfish only in strict compliance with google play policies- and/or other device data) and response meta-data is automatically sent to Pollfish servers, in order for Pollfish to discern whether the user is eligible for a survey. For a full list of data received by Pollfish through this app, please read carefully Pollfish respondent terms located at https://www.pollfish.com/terms/respondent. These data will be associated with your answers to the questionnaires whenever Pollfish sends such questionnaires to eligible users. By downloading the application you accept this privacy policy document and you hereby give your consent for the processing by Pollfish of the aforementioned data. Furthermore, you are informed that you may disable Pollfish operation at any time by using the Pollfish “opt out section” available on Pollfish website . We once more invite you to check the respondent’s terms of use, if you wish to have more detailed view of the way Pollfish works.

APPLE, GOOGLE AND AMAZON ARE NOT A SPONSOR NOR ARE INVOLVED IN ANY WAY IN THIS CONTEST/DRAW. NO APPLE PRODUCTS ARE BEING USED AS PRIZES.”

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ACCEPTANCE OF THE STANDARD APP STORE AND GOOGLE PLAY TERMS AND CONDITIONS AND PRIVACY POLICIES.

In addition to the terms of this policy document Life Ninja Education Limited reserves the right to insist that the user by accepting this policy agrees to be subject to any of the terms of the standard App Store and Google Play Store terms and conditions and Privacy Policies at the sole discretion of Life Ninja Education Limited.

SEVERABILITY

If any part of these Terms found in this document in its entirety is found to be invalid, illegal or unenforceable for any reason, then that provision will be severed from these Terms to the minimum extent such that the remaining provisions of these Terms will continue in full force and effect.

COOKIES POLICY

WHAT ARE COOKIES

Cookies are small text files that are saved to your computer. We use cookies to remember users during a visit, upon return to the site, and are required to enable certain functionality. In addition, cookies are used to help us understand how our customers use our website and we use this information to help plan improvements to the site enabling us to get to know you better. For example, using persistent cookies allows us to recognise you when you return to the site, identify your preferences so as to provide you with a more personalised service and speed up searches that you conduct when visiting.

By using the Website as per our Cookie Banner Notice and the registration process you give consent for Life Ninja Education Ltd to place Cookies on your computer or device. You may, if you wish, remove any placed Cookies following the information provided below; however certain features of the Website may not function fully or as intended.

THIS APPLICATION OR PLATFORM MAY PLACE THE FOLLOWING COOKIES

1. SESSION COOKIES

Session cookies are used by us to recognise a user throughout a visit. This enables us to remember information that you have entered such as the product you have selected during a purchase which can then be used at each stage of processing your purchase. Session cookies are also used to remember you when you log in for the duration of your visit.

1. PERSISTENT COOKIES

Persistent cookies allow us to retain information and settings about a user for more than one session. These cookies stay on a computer or a device until they expire or a user removes them. They enable us to recognise a user when they return to our site, identify their preferences so as to provide a user with a more personalised service and speed up searches a user conducts when visiting the site. They allow us to tailor marketing and servicing messages to users based on what we know users have or haven’t done in previous sessions. We are able to use this information to optimise the website for a user’s return to the site knowing their previous searches and interactions on the site.

1. WEBSITE ANALYTICS COOKIES

Website analytics cookies enable us to see how people use our website. This gives us the information to be able to make improvements, to make the site easier to use and based on the areas of the site people find most useful.

1. WEBSITE OPTIMISATION COOKIES

We test different versions of parts of the site before we finalise changes to ensure that any improvements make the site easier to use for our customers. These cookies help us to track how a user progresses through sections of the website that we are testing.

1. MARKETING AND TRACKING 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 and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We may also allow selected third party cookies for these purposes. These are regarded as non-essential third party cookies.

1. ADJUSTING YOUR PRIVACY SETTINGS

You can choose to enable or disable Cookies in your internet browser/ device. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however you may lose any information and or functionality that enables you to access and or use the Website more quickly and efficiently including, but not limited to, personalisation settings.

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable or delete them, please refer to aboutcookies.org.

To disable Google Analytics please use this tool

CONTACT US

privacy@lifeninja.net

Life Ninja Education Ltd, Studio 109, 109b Marton Road, Middlesbrough, England, TS1 2DU, United Kingdom.

Life Ninja Education Ltd registered in England company number 12364754 and the Information Commissioner’s Office ZA639692.

Document Version 1.8  02 April 2020