Wordwall Privacy Notice

DATED 2026-04-15 · VERSION 20260729_rev01 · COMPARED WITH 20251128_rev01

Full text changes — 20251128_rev01 to 20260729_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

+Effective date: 12 December 2025
+Effective date: 15 April 2026
 - * *
+## Introduction
+. [Introduction]()
+. [Our Promises]()
+. [Your Rights]()
+. [How we Collect your Data]()
+. [What Data we Collect]()
+. [Children Under 13]()
+. [Legal Basis for Processing your Data]()
+. [What we use your Data for]()
+. [How we Process your Data]()
+. [Who we share your data with]()
+. [Retaining your Data]()
+. [Legal Compliance]()
+. [California Privacy Rights (CCPA/CPRA)]()
+This privacy and cookie policy sets out how VISUAL EDUCATION LIMITED T/A Wordwall uses and protects your personal data and uses cookies. This policy is provided in a layered format so you can click through to the specific areas set out below.
+This privacy notice will help you understand how Wordwall uses and protects your personal data.
+. [Important information and who we are]()
+. [The types of personal data we collect about you]()
+. [How is your personal data collected?]()
+. [How we use your personal data]()
+. [Disclosures of your personal data]()
+. [International transfers]()
+. [Data security]()
+. [Data retention]()
+. [Your legal rights]()
+. [Cookie Policy]()
+. [Contact details]()
+. [Complaints]()
+. [Changes to the privacy and cookie policy and your duty to inform us of changes]()
+. [Third party links]()
+. [Artificial Intelligence Features]()
+We are part of the Harbour Topco (UK) Limited Group. For the purposes of data processing this includes VISUAL EDUCATION LIMITED T/A Wordwall registered at 33 Glasshouse Street, London, England, W1B 5DG and Wordwall Inc, registered at 1521 Concord Pike, ste 201 Wilmington, DE 19803.
+## 1\. Important information and who we are
+Your privacy is protected by law, and it is also protected by our data security and protection policies. This page gives you an idea of how we use your data and the safeguards we put in place to protect it.
+### Privacy Policy
+You can contact our voluntarily appointed Data Protection Officer at [dpo@wordwall.net](mailto:dpo@wordwall.net) or by phone on 01509 438404, if you have any concerns or wish to exercise your rights.
+This policy gives you information about how VISUAL EDUCATION LIMITED T/A Wordwall collects and uses your personal data through your use of this website, including any data you may provide when you create and set up an account with us.
+If you are an EU Data Subject you can contact our EU Representative, Rune Peterson, at [eurep@fifthsquare.eu](mailto:eurep@fifthsquare.eu). Our EU Representative complies with our obligations under GDPR Article 27 and is established in the Republic of Ireland. Please note that our EU Representative is a Third Party. They will process your personal data in accordance with this Privacy Policy.
+We do not intend that children should create an account with us. However, children may use our website.
+## Our Promises
+### Controller / Processor
+To help you on your journey with us, we need data about you. We make the following promises about how we will treat this data:
+VISUAL EDUCATION LIMITED T/A Wordwall (CN: 05900439) (collectively referred to as "COMPANY", "we", "us" or "our" in this policy) acts in two capacities concerning your personal data:
+- We will only collect data about you that is relevant and necessary.
+- Your data will only be held on systems that meet high compliance standards.
+- Your data will only be accessed by those who need it, and we will minimise the amount of data that is processed, wherever possible.
+- We won't share or sell your data to any third party, except, if permitted, for the marketing of our own services to you, unless either you have agreed, we are required to share it by law, or we need to fulfil our service commitments.
+- We will always remember that it is your personal data, not ours. As such, we will ensure complete transparency and openness with you wherever possible.
+- We respect your rights as outlined in the next section and will respond to all requests promptly.
+. We control the personal data which we collect from you to facilitate your use of the website.
+. We process the personal data that you upload as part of your interaction with the services provided on the website.
+## Your Rights
+If you have any questions about this policy, including any requests to exercise your [legal rights](), please contact the us using the information set out in the [contact details]() paragraph.
+You have certain rights over any data we hold about you:
+## 2\. The types of personal data we collect about you
+- **Your right of access** - You have the right to ask us for copies of your personal information.
+- **Your right to rectification** - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
+- **Your right to erasure** - You have the right to ask us to erase your personal information in certain circumstances.
+- **Your right to restriction of processing** - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
+- **Your right to object to processing** - You have the right to object to the processing of your personal information in certain circumstances.
+- **Your right to data portability** - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
+Personal data means any information about an individual from which that person can be identified.
+Where we use or store your personal data, because you have given your consent, you have the right to withdraw your consent at any time. For example, if you have subscribed to our mailing list you have an opportunity to unsubscribe at any time.
+We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
+You can read more about your rights at [http://knowyourprivacyrights.org/](http://knowyourprivacyrights.org/).
+- Identity Data includes first name, last name, any previous names, username, password or similar identifier, title, date of birth, gender, school name, role, subject interests and school year.
+- Contact Data includes address (i.e. billing address and delivery address), country, email address and telephone numbers.
+- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
+- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
+- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
+- Usage Data includes information about how you interact with and use our website, adverts, products and services.
+- AI Interaction Data includes user inputs submitted to AI-powered features, AI-generated responses, and usage patterns of AI functionality within our platform.
+- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
+If you would like to uphold your rights, then please contact our Data Protection Officer at [dpo@wordwall.net](mailto:dpo@wordwall.net)
+We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
+If you are dissatisfied with our response you also have the right to lodge a complaint with the Data Protection Authority. This can be done at [https://ico.org.uk/concerns/](https://ico.org.uk/concerns/).
+Please note that if as part of your interaction with the website you collect and upload any information as listed above relating to your students for activities including assignments and leaderboards you must have the appropriate grounds.
+Wordwall also participates in the iKeepSafe COPPA Safe Harbor program. If you believe we have not resolved your privacy concern relating to children's data, you may contact iKeepSafe directly at [COPPAPrivacy@ikeepsafe.org](mailto:COPPAPrivacy@ikeepsafe.org).
+## 3\. How is your personal data collected?
+## How we Collect your Data
+We use different methods to collect data from and about you including through:
+Typically, the data we process comes from the following sources:
+- **Your interactions with us**. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
+    - sign up for our mailing list
+    - request support
+    - apply for our products or services;
+    - create an account on our website;
+    - set assignments, add to leaderboards and share resources
+    - subscribe to our service or publications;
+    - request marketing to be sent to you;
+    - enter a competition, promotion or survey; or
+    - give us feedback or contact us.
+- **Automated technologies or interactions**. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy at paragraph [10]() for further details.
+- Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe Payments UK Ltd based inside the UK, Microsoft Azure which may be based outside the UK.
+- You are a school, education provider or teacher and have signed up to the service and engaged with us to create accounts, raise a support ticket, set assignments
+- You are a pupil that has been assigned an activity and you add your name to the leaderboard.
+- On behalf of an organisation or as an individual, you have enquired about our service or signed up to our mailing lists.
+- Other engagement with us through social media, email, phone or at events or by entering competitions and promotions or undertaken surveys.
+## 4\. How we use your personal data
+If you belong to an organisation, we may source your information from public databases and other sources for our Legitimate Interests. If you ask for us to send information about our services to someone else, you warrant you have the consent from them to share their data with us.
+### Legal basis
+## What Data we Collect
+The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
+We try to minimise the data held and the exact data elements we hold will be dependent on your journey with us. Typically, data elements we collect are detailed in the table below:
+- **Performance of a contract with you:** Where we need to perform the contract we are about to enter into or have entered into with you.
+- **Legitimate interests:** We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
+- **Legal obligation:** We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
+- **Consent:** We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
+### 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 the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
 | Purpose/Use | Type of data | Legal basis |
 | --- | --- | --- |
 | To register you as a new customer | (a) Identity
+(b) Contact | Performance of a contract with you. This will enable you to create and set up your own resources, share them with other teachers, and assign them to students. |
+(b) Contact | Performance of a contract |
 | To process and deliver your subscription including:
 (a) Manage payments, fees, and charges
 (b) Collect and recover money owed to us | (a) Identity
 (b) Contact
 (c) Transaction
 (d) Marketing and Communications | (a) Performance of a contract with you
 (b) Necessary for our legitimate interests (to process subscriptions and recover debts due to us) |
 | To manage our relationship with you which will include:
+(a) Notifying you about changes to our terms or privacy / cookie policy | (a) Identity
+(a) Notifying you about changes to our terms or privacy / cookie policy
+(b) Dealing with your requests, complaints and queries | (a) Identity
 (b) Contact
+(c) Profile | (a) Performance of a contract with you
+(b) Necessary to comply with a legal obligation |
+| (b) Dealing with your requests, complaints and queries | (d) Marketing and Communications | (c) Necessary for our legitimate interests (to keep our records updated, manage our relationship with you and offer you support in using our services if required) |
+(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 (to keep our records updated, manage our relationship with you and offer you support in using our services if required) |
 | To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
 (b) Contact
 (c) Technical | (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 deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity
 (b) Contact
 (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). |
 | To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data | (a) Identity
 (b) Contact
 (c) Technical
 (d) Usage
 (e) Profile
+(f) Marketing and Communications | Consent, having obtained your prior consent to receiving direct marketing communications such as from the mailing list. |
+(f) Marketing and Communications | Consent, having obtained your prior consent to receiving direct marketing communications such as from the mailing list if you're an individual or by Legitimate Interest if you are working on behalf of an organisation. |
+### Children's data
+Our website contains content created by us or others. These may include external links, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We don't provide any warranty or accept any liability for this content. If personal data or inappropriate material is found, please report it to us immediately at [dpo@wordwall.net](mailto:dpo@wordwall.net).
+Our collection of children's data is limited to the child's name, the score they achieved in a game and their progress through an assignment. It is possible further information may be inferred about a child from the way in which a teacher names the resources that the teacher creates. The activities of a child on our website are tracked but the child's data arising from this tracking is completely anonymous provided that the child is not accessing our services through a signed-up account.
+## Children Under 13
+If, as a teacher or school, you require (or allow) children to add their personal data while accessing the content that you upload, you will likely be a data controller for the purposes of GDPR and you must ensure that you have the appropriate grounds to collect this personal data from children and keep this data confidential. As a teacher or school, you are solely liable and responsible for ensuring your compliance with GDPR.
+We do not knowingly collect personal data directly from children. Each registered account holder determines whether to collect or input student personal data into the platform and is responsible for ensuring that they have the appropriate legal basis and required permissions under applicable laws and regulations.
+### Direct marketing
+In such cases our collection of children's data will be limited to what may be reasonably necessary to participate in the relevant activity or to create accounts or log in. This may include the child's name, the score they achieved in a game, and their progress through an assignment. We do not demand real names are used for this purpose, and any entry is accepted on the basis that consent of the parent or guardian has been obtained in all cases.
+During the registration process on our website when you create and set up your own account and when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email: [help@wordwall.net](mailto:help@wordwall.net).
+It is also possible further information may be inferred about a child from the way in which a teacher names the resources that the teacher creates.
+We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
+When an account holder inputs personal data Wordwall acts as Data Processor and the Account Holder is the Controller.
+### Third-party marketing
+If a bulk or institutional subscription ends, the individual account holder retains access to and control of their account and associated data, subject to this Privacy Policy and our [Terms of Use](https://wordwall.net/terms).
+We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
+If we become aware that we have collected such information without appropriate consent, we will delete it promptly. If you believe we may have collected personal information from a child under 13, please contact us using the details provided in this Privacy Policy.
+### Opting out of marketing
+The activities of a child on our website are tracked but the child's data arising from this tracking is completely anonymous provided that the child is not accessing our services through a signed-up account.
+You can ask us to stop sending you marketing communications at any time by following the opt-out links within any email communication sent to you or by contacting us via email at [help@wordwall.net](mailto:help@wordwall.net).
+## Legal Basis for Processing your Data
+If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to confirmation of a subscription, updates to our Terms and Conditions, checking that your contact details are correct.
+We use a specific legal basis to process your personal data, detailed in the above table. The legal basis we use depends on the nature of the processing activity we undertake on your personal data.
+### Cookies
+If we use the lawful basis of legitimate interests, we ensure that our processing is not overridden by your data protection interests or fundamental rights and freedoms. In these cases, we act as a Data Controller.
+For more information about the cookies we use and how to change your cookie preferences, please see paragraph [10]().
+When our clients provide us information, we process this data on the basis that the provider of that data has the right legal basis to share that information with us, and we accept no liability for omissions on their part. In these cases, we act as a Data Processor.
+## 5\. Disclosures of your personal data
+## What we use your Data for
+We may share your personal data where necessary with the parties set out below for the purposes set out in the table within paragraph [4]().
+We process information about you to provide you with the services for which you, your employee or our clients enter when signing up for our services.
+For details of the subprocessors we engage to process personal data on our behalf, together with the categories of data they process, their processing locations, and the contractual and transfer safeguards in place, please see our [Subprocessors](https://wordwall.net/subprocessors) page.
+Further information is provided in the table above, which details the purposes or reasons we process your personal data. All our processes are mapped and are subject to various internal policies, procedures and governance, ensuring your data privacy and security remains central to all we do.
+- Each subprocessor agreement requires that subprocessors (a) process personal data only on our documented instructions; (b) implement technical and organisational measures equivalent to those described in this Privacy Policy; and (c) comply with all applicable data-protection laws. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.
+We also collect, use, and share de-identified aggregated data such as statistical or demographic data. For example, we may aggregate individuals' usage data to calculate the percentage of users accessing a specific website feature to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
+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.
+## How we Process your Data
+We may share your personal data provided that we have your explicit instruction to do so for the purposes of, for example, integrating with a Virtual Learning Environment VLE provider or the purposes of Single Sign On SSO.
+Data is processed/stored locally and on encrypted third party hosted cloud services such as Google Business Suite and Azure.
+Please note that if your subscription has been purchased by a corporate body who have contracted with us for the provision of the service (e.g. under a whole-school site subscription service) then your data may be accessed by the particular corporate body.
+In addition, we use Large Language Models (LLM) often referred to as "AI" to power automated content generation features within our platform and enhance the user experience. We may also use your input data to improve the way we design and configure prompts for our AI service providers, to enhance the quality and relevance of AI‑generated content. This data is not used to train the underlying AI models operated by those providers.
+## 6\. International transfers
+Users remain liable for all inputs and assume responsibility to ensure that no personal, copyrighted or intellectual property is used in content. AI-generated content is automated and may contain inaccuracies. We do not guarantee the accuracy, completeness, or reliability of AI outputs. You remain responsible for verifying AI-generated educational content before use with students.
+We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.
+A full list of the processors used can be found [here](https://wordwall.net/subprocessors). These services all have strong data security at the heart of their systems including ISO27001 and SOC2 certification. We ensure that access to these services is strictly controlled and include strong authentication processes like Multi Factor Authentication.
+Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
+Data is processed in either the UK, EEA/EU data centres or on US based servers that have demonstrated strong Data Security. We may also process your data in countries outside the UK or European Union from time to time in other aspects of our business.
+We will only transfer your personal data to countries or entities that have been deemed by the UK to provide an adequate level of protection for personal data, namely, countries or entities in Europe and the United States of America
+Further to Section 119A of the Data Protection Act 2018 and noting Case C-311/18 in the European Court of Justice, if your data is transferred or processed outside of the UK or EEA we ensure the safeguards of International Data Transfer Agreements (IDTAs) or Addendums are enforced. Where this is not possible, we ensure that European Standard Contractual Clauses are entered.
+## 7\. Data security
+We regularly review suppliers for data security compliance to ensure your data is safe and track where your data is held.
+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 will never ask you for your username or password for your account or ask you for any credentials for other applications or websites.**
+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.
+## Who we share your data with
+All remote access to this website is conducted over HTTPS, an encrypted web link secured using Secure Sockets Layer (SSL). This is the same method used by banks and commercial entities to secure sensitive data from interception. We encrypt user data.
+We will not share your information with third party organisations (known as sub-processors) except as part of providing a product or service to our clients and/or when legally obliged to. It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process your personal information only as instructed by us, and to flow those same obligations down to their sub-processors.
+We store data on our secure database servers. Physical access to our servers is strictly limited. Access to the servers in the data centre requires proof of identify (photo ID) and is controlled by magnetic card readers and keys to both the cages and individual cabinets that surround the server racks, all of which are monitored by the data centre security staff using CCTV. Remote access to the data is limited to the tools needed by the IT support staff to maintain and operate the servers and is restricted to known users (identified by usernames and secure keys) connecting from known locations (IP addresses).
+We may also disclose your personal information to those within our group of companies, law enforcement, regulatory and other government agencies, as required by and/or in accordance with applicable law or regulation.
+## 8\. Data retention
+When you ask us to connect your account with a third-party service (for example a Virtual Learning Environment or Single Sign-On provider), we will share the data needed to enable that integration. If your subscription was purchased by an organisation (e.g. a whole-school subscription), that organisation may also access data associated with accounts under its subscription for administration purposes.
+### How long will you use my personal data for?
+We may use marketing services from third parties. These may rely on the use of cookies. You can read more about these in our [Cookie Policy](https://wordwall.net/cookie-policy).
+We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
+Wordwall uses a Fractional Data Protection Officer (DPO) for compliance purposes. Should you have a data protection query or complaint your details may be passed to them to assist us. In all other cases our DPO does not have access to your data.
+To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
+If Wordwall is involved in a merger, acquisition or asset sale, personal data may be transferred between parties, but we will provide notice before personal data is transferred and becomes subject to a different privacy notice.
+By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
+## Retaining your Data
+Personal data stored in a user account will be deleted if the account is left inactive for seven years. However, resources which a user has created, and which have been shared with the Wordwall community may be retained in accordance with our [Terms of Use](https://wordwall.net/terms).
+Dependent on the data you provide us and for what purpose it is provided we may need to retain your data for up to 7 years following the end of engagement with you or our client. If you wish to find out more about your specific data retention, please contact us.
+In some circumstances you can ask us to delete your data: see paragraph [9]() below for further information. Please note that data for students may be deleted at any time by users through the dashboard.
+Data for students may be deleted at any time by account holders through the dashboard.
+In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
+## Legal Compliance
+## 9\. Your legal rights
+We seek to uphold our legal obligations as covered by the Data Protection Act 2018, Data Use and Access Act 2025 and the General Data Protection Regulation 2016. Our Data Protection Authority is designated as the Information Commission (IC) formally the Information Commissioners Office (ICO). This Privacy Policy is reviewed on a regular basis and was last reviewed in March 2026. We retain the right to update this notice at any time and the latest version will always be displayed on our website. If we make material changes to this Privacy Policy, we will notify affected users before the changes take effect.
+You have a number of rights under data protection laws in relation to your personal data.
+## California Privacy Rights (CCPA/CPRA)
+You have the right to:
+- Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
+- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
+- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
+- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
+- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph [4]() for details of how to object to receiving direct marketing communications).
+- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
+- Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph [4]() for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
+- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
+    - If you want us to establish the data's accuracy;
+    - Where our use of the data is unlawful but you do not want us to erase it;
+    - Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
+    - You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
+If you wish to exercise any of the rights set out above, please contact us see Contact details (paragraph [11]()).
+### No fee usually required
+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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 could 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.
+## 10\. Cookie policy
+Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You can find our most recent Cookie Policy here: [https://wordwall.net/cookie-policy](https://wordwall.net/cookie-policy)
+## 11\. Contact details
+If you have any questions about this Privacy Policy, the [Cookie Policy](https://wordwall.net/cookie-policy), the [Subprocessors](https://wordwall.net/subprocessors) page, or about the use of your personal data or cookies or you want to exercise your privacy rights, please contact us in the following ways:
+- Email address: [privacy@wordwall.net](mailto:privacy@wordwall.net)
+- Postal address: Visual Education Ltd, Lytchett House, 13 Freeland Park, Wareham Road, Poole, Dorset, BH16 6FA, United Kingdom.
+## 12\. Complaints
+You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
+## 13\. Changes to the Privacy Policy and your duty to inform us of changes
+We keep our Privacy Policy under regular review.
+It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
+## 14\. Third party links
+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 and cookie policy of every website you visit.
+## 15\. Artificial intelligence features
+We use third-party artificial intelligence services to power automated content generation features within our platform, and enhance the user experience. When you use these AI-powered features, your input data is processed by our AI service providers to generate educational content, resources and games.
+We may store your input data to improve the way we design and configure prompts for our AI service providers, to enhance the quality and relevance of AI-generated content. This data is not used to train the underlying AI models operated by those providers.
+### Third-party AI providers
+For information on our AI service providers (subprocessors) please see our [Subprocessors](https://wordwall.net/subprocessors) page.
+### User guidance
+Please do not submit sensitive personal information, confidential data, or student personal details when using AI-powered features. You are responsible for reviewing and validating all AI-generated content before use.
+### Your rights regarding AI data
+You have the same rights regarding your AI interaction data as described in paragraph [9](), including the right to access, correct, delete, or withdraw consent for AI data processing.
+### AI content disclaimer
+AI-generated content is automated and may contain inaccuracies. We do not guarantee the accuracy, completeness, or reliability of AI outputs. You remain responsible for verifying AI-generated educational content before use with students.
+If you are a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These rights include the right to know what personal information we collect, use, and disclose; the right to request deletion or correction of your personal information; the right to opt out of the sale or sharing of personal information; and the right to limit the use of sensitive personal information. We will not discriminate against you for exercising these rights. You may submit a request using the contact details provided in this Privacy Policy.