document: title: privacy & cookies
text: Effective from August 22, 2014

At Sumdog, we take your privacy and online safety very seriously. This Privacy Policy describes what personal information we collect from you when you use Sumdog, and what we do with that information. If you have any questions or concerns, please contact us at privacy@sumdog.com.

This Privacy Policy forms part of Sumdog's Terms of Use. When you use Sumdog, you signify that you accept this Privacy Policy, as well as Sumdog's Terms of Use.

### Overview

We do not ask children to enter any information that, by itself, is considered personal information.

Children aren't allowed to set up their own Sumdog account: we ask teachers and parents to make Student accounts for them. When they do this, they enter personal information both about themselves and the children.

When the children use Sumdog, we collect information - for example, about their educational performance. When they play writing games, we ask them not to enter any personal information. Sumdog does its best to enforce this rule automatically. To help provide the safest possible environment, we permit teachers and parents to view what each child has written.

We do not sell our users' information to other companies.

Now for the details...

### Student Users

If you are under 18,

  * you are only permitted to log in to Sumdog as a Student User;
  * before you can log in as a Student User, a parent, guardian or teacher must create an account for you. They do this by first creating a parent or teacher account for themselves.
  * we will not ask you to enter information that, by itself, is considered personal information.



If we discover that we have collected personal information from anyone under 18 without permission from someone with the authority to give permission, we will delete that information as quickly as possible. If you believe that this has happened, please contact us at privacy@sumdog.com.

### Information users give us

Student Users

Student Users are not asked to enter information that, by itself, is considered personal information.

Parent Users

We collect the following personal information from Parent Users.

On sign-up, Parents Users enter their:

  * first & last name
  * email address & password



Parent Users then enter information about each of their children:

  * first and last name
  * date of birth
  * school login details



Parent Users may also send an email invite to other parents by entering their names & email addresses. 

If Parent Users choose to subscribe to premium services, they enter:

  * postal address
  * payment method details



Teacher Users

The following personal information is collected from Teacher Users.

On sign-up, Teacher Users enter their:

  * first & last name
  * email address & password
  * school name and address



Teacher Users may then enter information about their students:

  * first and last name
  * grade level or school year
  * class



In the future, we may ask teachers to enter the date of birth of students. If we do this, it will always be optional.

Teacher Users may also invite other teachers, by entering their names and email addresses. 

All Users

All users can choose the gender and visual appearance of their on-screen avatar. They can also specify profile details, such as their favorite Sumdog game.

In order to provide the best possible service, we reserve the right to extend the types of information we ask users to give us. You can choose not to give us your information. However, this will prevent you from using most parts of Sumdog.

### Information we collect automatically from users

When you use Sumdog, we may collect the following information automatically:

  * educational data from your activity on Sumdog, for example accuracy and speed of answers to Sumdog's questions;
  * text written in Sumdog's writing games;
  * data on your use of Sumdog, for example the last time you logged in;
  * communications you have made with other Sumdog users;
  * technical information, for example the device you use, your operating system and your IP address.



The data we collect automatically may be linked to your account and to the personal information that you have given us.

Some of the information that we collect from Student Users may be accessed by the Parent Users in their Sumdog Family, or the Teacher Users linked to their Sumdog School.

We also use analytics software to help us understand how Sumdog is used. Information recorded by this software is anonymized, and cannot be related to individuals. To help us optimise our email communication, we may use customised links, or small images called web beacons. These allow us to understand how our messages are received by our users.

In order to provide the best possible service, we reserve the right to extend the types of information we automatically collect from users.

### Sumdog uses Cookies

We use small files called Cookies to help make Sumdog easier to use, and to help us improve the site for you. We store these Cookies on your computer.

Cookies can't be used to identify you personally. They simply let us know when you return to the site. This helps us, for example, to remember that you're logged in, or to remember the settings you chose on your previous visit. We store them in the Cookies folder on your computer.

Here's a table describing the Cookies we use:

Cookie name  |  What it's for   
---|---  
browsercheck  |  Tests whether your browser can use Sumdog's other Cookies   
NRAGENT, __utma, __utmb, __utmc, __utmz  |  Monitor Sumdog's performance and speed, and helping us understand how the site is used, so we can optimize it for you   
_sumdog, JSESSIONID, sumdog_shared_cookie  |  Recognize and coordinate your login across Sumdog's servers   
default_school  |  Identifies your school code, so you can log in more easily   
  
You can find out more what Cookies are, and how to manage them, here: http://www.aboutcookies.org/. Please remember, though, that some of Sumdog's services won't work properly if you block Cookies.

### How we store and process your information 

Your information is stored and processed on our servers. The only exception to this is payment card details: for security reasons, these are stored by our payment service provider.

We may transfer your information to other countries for processing and storage. However, we will only do this in locations that follow the "Safe harbor" regulations (http://www.export.gov/safeharbor).

### How we use your information

Your information is used during the normal functioning of the Sumdog service. This may include:

  * personalise Sumdog for you;
  * inform you about our services, or to help you to use them, such as telling you about a new Sumdog game, or notifying you of the end of a trial period;
  * identify and where necessary act against improper or illegal use of Sumdog. This helps keep Sumdog safe for all of our users;
  * analyze usage patterns or request feedback from you about our services so that we may improve the service



Your information is held by Sumdog Ltd. It may also be accessed by our wholly-owned US subsidiary, Sumdog Inc, in accordance with the terms of this Privacy Policy.

If we need to use your personal information for any other purposes, other than the normal functioning of the Sumdog service we will seek your permission prior to doing so.

We will not use your information to develop a personal profile of you.

If you have given us your email address, we may send you messages via email. This may include information about new features or services, or about your usage of the site, or the usage of others in your Sumdog School or Sumdog Family. To choose which types of email you receive from us, please go to http://www.sumdog.com/emails/. Please note that there are certain emails that you can't opt out of receiving, unless you delete your account entirely, as these are concerned with the administration of your account.

Data Deletion Policy

Parent Users or Teacher Users may ask us to delete personal information held in a Sumdog Family or Sumdog School linked to their account by contacting us as described below. We will do this within 30 days of your request.

If you sign up as a Teacher User or a Parent User, and you do not confirm your email address within 30 days of signing up, we will automatically delete your information.

The following information will not be deleted:

  * after a request to delete a Sumdog Family, the Student User accounts will not be deleted if they are also linked with a Sumdog School.
  * after a request to delete a Sumdog School, the Student User accounts will not be deleted if they are also linked with a Sumdog Family.
  * any information required to protect the safety of other Sumdog Users will not be deleted; for example, we keep the conversations held in writing games in case we need to investigate claims of abuse.



We may also use aggregated data that has been derived from your Information after you have deleted it. However, this will not be in any way that might identify you personally.

We will keep your personal information as long as your Sumdog account exists. We may also need to keep your information to comply with our legal obligations, or to resolve disputes or enforce our agreements.

We reserve the right to delete your account after a long period of inactivity. We will make reasonable efforts to contact you using either Parent User or Teacher User email addresses before we do so.

### Data Confidentiality

Generally, we will keep your information confidential, except:

  * where we believe in good faith that disclosure is required by law;
  * to protect the rights or safety of Sumdog's users;
  * to protect the property or rights of Sumdog or its employees;
  * there has been a clear breach of our licensing terms. In this case we may share information with our partners, lawyers and/or law enforcement agencies in the relevant country;
  * if you are a Student User, and your login is linked to a Sumdog School; in this case, any Teacher Users who are members of that Sumdog School will be able to access your information;
  * if you are a Student User, and your login is linked to a Sumdog Family; in this case, any Parent Users who are members of that family will be able to access your information;
  * when you have made a sales or support enquiry from a country in which we work with a partner, in which case we may forward your information to them; 
  * where the information you have given us is used on a profile that can be accessed by other users, or in an activity where it is shared with other users, such as one of Sumdog's writing games; 
  * when you have given explicit permission to pass your information to a third party.



Except as described here, or where authorised by you in writing, we will not pass on your information to any other party.

We may link information about how you use Sumdog to the Personal Information that we collect, but we will only use this linked information internally, and will not disclose it.

We may share statistics derived from aggregated information with our partners worldwide. These statistics do not enable our partners to identify you.

Change in control  
If there is a change in ownership of Sumdog Ltd, or a transfer of some of its assets, or in the unlikely event of it ceasing to continue trading, entering bankruptcy, or similar, your information may be transferred to a third party.

### Content you enter on our website

If you enter offensive, inappropriate or objectionable content on our websites, we may use the information you have given us to stop such behaviour.

Where we believe in good faith that you are or may be in breach of any law, or that your safety is at risk, we may use the information you have given us to inform relevant third parties such as your employer, school, e-mail/internet provider or law enforcement agencies.

### If you're in a different country

By using Sumdog, you give your consent for us to transfer your data to, and process it in, the United States of America. If, by using Sumdog, you would break any applicable laws, we must unfortunately revoke your right to do so.

We comply with the US-EU Safe Harbor Framework for the collection and use of personal data from EU countries. 

### Third parties

Sometimes, third parties with whom we're affiliated with may make offers or provide services to you through Sumdog, either independently, or jointly with us. We will only share information with these third parties to the extent necessary for this purpose.

This may include enabling you to automatically pass information you have given us to your account with a third party, or to gather information from your account with a third party. We have no control over the practices or privacy policies of any third parties, so you should make sure that you understand and are satisfied with them before allowing this.

As part of the provision of Sumdog, we may contract third parties to provide services which require us to share your information with them. Examples of this include sending you messages by email, storing or processing data, and processing payment. These third parties have no right to use your information except as required to provide these services.

If we permit you to add information to a create profile on Sumdog, this information may be displayed to other users.

You should bear in mind that information you disclose online, for example as part of a profile, or in written communications on the site, may be available to other users, who may be able to collect and use it without either Us or you knowing.

### Keeping your information safe

Your information is protected by your password. We also take all reasonable steps to prevent attack on Sumdog, including permissions verification.

Parent Users and Teacher Users are responsible for using their best efforts to select and protect their login details, including restricting access to your Sumdog account, and logging off after using Sumdog.

We will use all reasonable efforts to keep your information private, but like any internet service provider, we cannot absolutely guarantee this. It is always possible that the security of your information may be compromised, for example by unauthorized access, or by failure of hardware or software.

### Updating this privacy policy

We may change this Privacy Policy from time to time. How we use the information we collect is covered by the Privacy Policy in effect at the time it is collected. If we change the way we use Personal Information, we will notify you by updating this Privacy Policy.

### How to contact us

If you have any query regarding this Privacy Policy or your Personal Information on Sumdog, please e-mail privacy@sumdog.com. Alternatively, please write to Sumodg Inc, 902 Broadway, New York, NY NY 10010, or call 877-9786364. Outside of North America, please write to Sumdog Ltd, 43 Queensferry Street Lane, Edinburgh, EH2 4PF, UK or call +44 (0)1312261511.

Under the Data Protection Act in the UK, Parent Users have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. (We may charge for information requests and will require you to prove your identity with 2 pieces of approved photographic identification). We will use reasonable efforts to supply, correct or delete personal information about you on our files. Please send requests by post to the Data Protection Manager at the address above.