URBrainy.com Privacy Policy

This is the privacy policy of Route One Network Ltd (T/A URBrainy).

We respect your privacy and are determined to protect your personal data. This Privacy Policy explains what information URBrainy.com and its related entities (“Route One Network Ltd”) collect about its users, what we do with that information and how we handle the content you place in our products and services. We’ll also tell you about your privacy rights and how the data protection law protects you.

Table Of Contents

1. Who We Are And Important Information
2. The Personal Data We Collect About You
3. How We Collect Your Personal Data
4. How We Use Your Personal Data
5. Who We Share Your Personal Data With
6. International Transfers.
7. Data Security
8. Data Retention
9. Your Legal Rights
10. Changes To This Policy And Your Duty To Inform Us Of Changes
11. Queries, Requests Or Concerns

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Who We Are And Important Information

What is the purpose of this privacy policy?

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you create an account, subscribe to our services or register for our newsletter.

This website is not intended for children to signup and subscribe to and we do not knowingly collect data relating to children.

You must read this privacy policy together with our cookie policy and any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.

Data controller(s)

Route One Network Ltd is the controller and responsible for your personal data (collectively referred to as "Route One Network", "we", "us" or "our" in this privacy policy). Our contact details are:

Address: Route One Network Limited, 86-90 Paul Street, London, EC2A 4NE, UK

Email Address: data-privacy@route1network.com

For all data matters contact our Data Representative using the above contact details.

Third-party links outside of our control

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy policy of every website you visit.

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The Personal Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Obtained using the URBrainy site

• First party cookies (see cookie policy)

Obtained from URBrainy Trial Accounts

• Identity: Name, Email address, IP address
• Contact: Email address

Obtained in addition when paid subscription is created

• Identity: Payment details, PayPal email address (If payment made by PayPal), Occasionally phone number for country verification
• Contact: Billing address

Obtained during Login and requesting resources

• Identity: IP address

Phone support

• Identity: Name, Email address, Phone number
• Contact: Email address, Phone number

Email support

• Identity: Name, Email address
• Contact: Email address

Subscribe to email newsletter

• Identity: Name, Email address
• Contact: Email address

Obtained in creation of School Trials

• Identity: Name, Email address, Job title, IP address
• Contact: Email address, School name, School postcode

Obtained in creation of School Orders

• Identity: Name, Email address, Job title, IP address, Finance name, Finance email address
• Contact: Email address, Finance email address, School name, School address, School postcode, School phone number

We also collect and use aggregated data for statistical purposes. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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How We Collect Your Personal Data

We use different methods to collect data from and about you including:

Directly. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Register for a trial
• Subscribe to our service
• Request our email newsletter.

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How We Use Your Personal Data

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

• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the above contact details.
• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to marketing communications via email. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by logging into the website and visiting https://urbrainy.com/my-account/newsletter and clicking Unsubscribe or by following the opt-out links on any marketing message sent to you or by email request to support@urbrainy.com.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact use using the above details.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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Who We Share Your Personal Data With

Subprocessors

We use a select number of trusted external service providers for certain technical data processing and/or service offerings. These service providers are carefully selected and meet high data protection and security standards. We only share information with them that is required for the services offered and we contractually bind them to keep any information we share with them as confidential and to process Personal Data only according to our instructions.

We use the following subprocessors to process the data collected by URBrainy customers:

Third Party Services We Use

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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International Transfers

Many of our external third parties are based outside the European economic area (EEA) so their processing of you personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by being sure the companies are part of the Privacy Shield framework.

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Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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Data Retention

We will retain your information as long as your account is active, as necessary to provide you with the services or as otherwise set forth in this Policy. We will also retain and use this information as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect our legal rights.

We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our site, improve our services or comply with legal obligations.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

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Your Legal Rights

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact us at data-privacy@route1network.com.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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Changes To This Policy And Your Duty To Inform Us Of Changes

This version was last updated on the date shown at the bottom of this policy and historical versions can be obtained by contracting us.

We reserve the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to us. It is strongly recommended to check this page often, referring to the date of the last modification listed above.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

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Queries, Requests Or Concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us on data-privacy@route1network.com.

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This version was last updated on 01 Nov 2023.