Privacy Policy

Welcome to Trivela. We prioritize the privacy and safety of all our users, especially children who use our website and game, collectively known as the “Platform.” This Privacy Policy explains how we collect, use, and protect personal information from you and from children under the age of 13, in compliance with the Children's Online Privacy Protection Act (COPPA). This privacy notice also informs you about your rights under the Data Protection Act 2018 and UK GDPR (“Data Protection Laws”).

 

When registering for our Platform, please ensure you follow the registration consent process, especially for children under 13, which requires parental or guardian consent.

 

 2. Controller for Personal Data

 

A “controller” is a person or organization who alone or jointly determines the purposes for which, and the way, any personal data is processed. Unless we notify you otherwise, Trivela is the controller of your personal data.

 

This privacy notice applies to the processing of personal data by us in connection with any:

 

a. Users and Potential Users: For the provision of services by us.

 

b. Suppliers: For the provision of products and services to us by suppliers or service providers.

 

c. Visitors: For the provision of services to us as a visitor on our Platform.

 

 3. Types of Personal Data

 

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymized data).

 

Trivela may collect, use, store, and transfer different kinds of personal data which we have grouped together:

 

 a. Data Provided by Parents or Guardians:

 

• Identity Data: When a parent or guardian registers an account, we may collect their name, email address, and other contact information.

• Contact Data: Includes billing address, delivery address, email address, and telephone numbers.

• Financial Data: Includes bank account and payment card details.

• Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• School Data: We may collect data about the child’s school, including the school name, contact details, year group, and teacher’s name and contact details.

 

 b. Data Provided by Children

 

For Children Under 13:

 

- Profile Data: We collect a Fist Name and Password created during account setup by the parent or guardian.

- Usage Data: Data about how the Platform is used, including game progress, maths questions, and features accessed.

- Content Data: Includes information stored on the child's device when using our Platform.

 

For Children Aged 13 and Above:

 

- Profile Data: First Name and Password, and preferences for the child’s account.

- Usage Data: As above.

 

 c. Automatic Data Collection

 

- Device Data: Information about the device used to access the Platform, including IP address, browser type, and operating system.

- Technical Data: Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.

- Transaction Data: Details about payments to and from you and other details for the provision of services you have purchased from us.

 

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated data could be derived from personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity.

 

We do not collect any Special Categories of Personal Data about you or your child (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

 4. How We Collect Personal Data

 

 a. Directly from a Parent or Guardian:

 

You provide us with your personal data through direct interactions, such as when you:

 

- Register to become a member of our website.

- Subscribe to our service or publications.

- Request marketing to be sent to you.

- Provide feedback or contact us.

- Participate in our marketing or promotional events.

- Contact us with concerns.

 

 b. Directly from the Child:

 

For Children Under 13:

 

- We collect limited personal data directly from children under 13, and only with verifiable parental consent. This includes gameplay data and preferences necessary for the game experience.

 

For Children Aged 13 and Above:

 

- Children may provide personal data when they sign up or interact with the Platform, with appropriate consent where required.

 

 c. From Use of Our Platform:

 

- Game Interaction: We collect information on the child’s game progress and maths performance.

- Website Usage: We gather information and statistics about users and visitors to the Platform. We use cookies and similar tracking technologies to enhance user experience. For detailed information, please see our [Cookies Policy].

 

 d. Indirectly from Third Parties:

 

We may receive data from third parties when we:

 

- Provide services or receive personal data from other parties enabling the provision of those services.

- Interact with schools, governmental or regulatory bodies, or other authorities.

- Access publicly available sources, such as public registers or professional networking sites.

 

 5. Parental Consent for Children Under 13

 

In compliance with COPPA, we require verifiable parental or guardian consent before collecting, using, or disclosing personal information from children under 13. Parents or guardians must complete the registration process on behalf of their child and consent to the collection and use of the child's personal data as described in this Privacy Policy.

 

We may use the following methods to obtain verifiable parental consent:

 

- Email sent with a verification link.

- Payment Verification: Requiring a valid credit card or other payment method from the parent or guardian during the subscription process.

 

Parental Rights:

 

- Review Information: Parents have the right to review their child's personal information at any time.

- Revoke Consent: Parents may withdraw consent and request deletion of their child's personal information.

- Control Further Collection: Parents can refuse further collection or use of their child's personal information.

 

To exercise these rights, please contact us at hello@trivelagame.com.

 

 6. Providing Personal Data

 

Where we need to collect personal data by law or under the terms of a contract and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g., providing services). In this case, we may have to cancel our service but will notify you if this is the case.

 

 7. How We Use Personal Data

 

We will only use personal data when the law allows us to. Commonly, we will use personal data in the following circumstances:

 

a. Performance of a Contract: To fulfill our contractual obligations to you.

 

b. Legal Obligation: To comply with legal or regulatory requirements.

 

c. Legitimate Interests: Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

 

d. Consent: Specifically for children under 13, we rely on parental or guardian consent to process the child's personal data.

 

 8. Purposes for Which We Will Use Personal Data

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a member for the provision of our services. 

(a) Identity 

(b) Contact

(c) Marketing and Communications

 

Performance of a contract with you

To set-up a Child Account

(a) Profile Data

Performance of a contract with you

To respond to any enquires 

(a) Identity 

(b) Contact

(c) Profile

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

To process and deliver our services to you including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity 

(b) Contact 

(c) Financial 

(d) Transaction 

 

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests i.e., to recover debts due to us

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy notice

(b) Asking you to leave a review or take a survey

(a) Identity 

(b) Contact 

(c) Profile 

(d) Marketing and Communications

 

(a) Performance of a contract with you 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests i.e., to keep our records updated and to study how you use our products/services

To administer and protect our business and Platform including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data 

(a) Identity

(b) Contact

(c) Device

(d) Technical

(e) Usage

 

(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

(b) Necessary to comply with a legal obligation

To use data analytics to improve our platform marketing, customer relationships and experiences

(a) Device

(b) Technical 

(c) Usage 

Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy

 

Note: Where applicable consent will be used for data analytics obtained through cookies or similar technologies. See our cookies notice 

To make suggestions and recommendations to you about our services that may be of interest to you

(a) Identity 

(b) Contact 

(c) Technical 

(d) Usage 

(e) Profile 

(f) Marketing and Communications

Necessary for our legitimate interests to develop our products/services and grow our business

To improve your child’s maths

(a) Profile

(b) Usage

(a) Performance of a contract with you 

 

 9. Marketing Communications

 

Trivela may send you marketing communications. We do not send marketing communications directly to children under 13. You have the right to object to processing your personal data for direct marketing purposes. You can unsubscribe by using the methods in our communications or by contacting us at hello@trivelagame.com.

 

 10. How We Share Personal Data

 

We may share personal data with:

 

a. Internally: Our employees and contractors who need the data to provide services.

 

b. Suppliers: Service providers supporting our business operations.

 

c. Professional Advisers: Lawyers, bankers, auditors, and insurers.

 

d. Law Enforcement and Regulators: To comply with legal obligations.

 

e. Third Parties in Business Transactions: In the event of a business reorganization or acquisition.

 

For Children Under 13:

 

- With Parental Consent: We may share information with third parties only with explicit parental or guardian consent.

 

- Legal Compliance: We may disclose information as required by law or to protect users.

 

We do not sell or rent personal information collected from children under 13.

 

 11. International Transfers

 

We ensure a similar degree of protection is afforded to personal data transferred out of the UK by implementing appropriate safeguards. Our Platform is hosted by Google Cloud Platform (GCP), with servers based within the EEA. We do not transfer personal data outside of the EEA.

 

 12. Data Retention

 

We retain personal data only as long as necessary to fulfill the purposes we collected it for, including legal and regulatory requirements.

 

For Children Under 13:

 

- Personal data is retained only with parental consent.

- If consent is withdrawn or upon request, we will delete the child's personal information promptly.

 

 13. Parental Rights

 

Parents or guardians of children under 13 have the following rights:

 

- Access: Review the personal information collected from your child.

- Correction: Request correction of your child's personal data.

- Deletion: Request deletion of your child's personal data.

- Withdrawal of Consent: Withdraw consent for further processing of your child's data.

 

To exercise these rights, contact us at hello@trivelagame.com.

 

 14. Data Subject Rights

 

Under certain circumstances, you have rights under Data Protection Laws, including:

 

- Access: Request access to your personal data.

- Correction: Request correction of incomplete or inaccurate data.

- Erasure: Request deletion of personal data.

- Objection: Object to processing based on legitimate interests.

- Restriction: Request suspension of processing.

- Data Portability: Request transfer of your data.

- Withdrawal of Consent: Withdraw consent where we rely on it for processing.

 

 15. Keeping Personal Information Accurate and Current

 

Please keep us informed of any changes to your personal data by contacting us at hello@trivelagame.com.

 

 16. Exercising Your Data Subject Rights

 

To exercise any of your rights, please contact us at hello@trivelagame.com. We may need to verify your identity before fulfilling your request.

 

 17. Concerns and Complaints

 

We aim to address your concerns promptly. If you're unsatisfied, you have the right to complain to the Information Commissioner's Office (ICO) at www.ico.org.uk.

 

 18. Security

 

We implement appropriate security measures to protect personal information, especially for children under 13. While we strive to protect data, we cannot guarantee absolute security.

 

 19. Changes to This Privacy Policy

 

We may update this Privacy Policy periodically. We will notify parents or guardians of any material changes by updating the effective date and posting the new policy on our website. Please review this Privacy Policy regularly.