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Wordwall Privacy Notice

Wordwall updated the effective date and added a new 'Data Protection Complaints' section. The new section explains how to complain about data use, but also states that UK law now requires you to complain to Wordwall first before the Information Commissioner's Office (ICO) will investigate your complaint.

You must complain to Wordwall before the regulator will actPreviously the policy only pointed you to the ICO directly for complaints. Now it tells…

Previously the policy only pointed you to the ICO directly for complaints. Now it tells you that you're required to complain to Wordwall first, wait for them to respond (they give themselves 30 days), and that the ICO will typically expect you to have done this before they investigate. This adds an extra step and potential delay before an independent regulator will look into your complaint.

“However, the law now requires you to raise your complaint with us before complaining to the IC.”

What you can do — If you have a data complaint, contact Wordwall first using the contact details given in the Introduction section of this policy, and give them a chance to respond before escalating. If you're not satisfied or don't hear back, you can still contact the ICO at 0303 123 1113 or https://www.ico.org.uk.

USER OBLIGATIONS
20261006_rev01COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED
1Effective date: 15 April 2026
1Effective date: 6 October 2026
± CHANGEDEffective date updated

The date at the top of the policy changed from 15 April 2026 to 6 October 2026, showing when this version took effect.

22
33- * *
44
551. [Introduction]()
662. [Our Promises]()
773. [Your Rights]()
10106. [Children Under 13]()
11117. [Legal Basis for Processing your Data]()
12128. [What we use your Data for]()
13139. [How we Process your Data]()
141410. [Who we share your data with]()
151511. [Retaining your Data]()
1612. [Legal Compliance]()
1713. [California Privacy Rights (CCPA/CPRA)]()
1612. [Data Protection Complaints]()
1713. [Legal Compliance]()
1814. [California Privacy Rights (CCPA/CPRA)]()
1819
1920This privacy notice will help you understand how Wordwall uses and protects your personal data.
2021
2122We 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.
2223
2324Your 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.
189190## Retaining your Data
190191
191192Dependent 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.
192193
193194Data for students may be deleted at any time by account holders through the dashboard.
194195
196## Data Protection Complaints
197
198We always try to meet the highest standards of Data Privacy when collecting and using personal information. For this reason, we take any complaints we receive very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.
+ ADDEDNew 'Data Protection Complaints' section added

A new section was added explaining how to complain about Wordwall's handling of your data. It says you should contact Wordwall first (using the contact details given elsewhere in the policy), and that Wordwall will acknowledge your complaint within 30 days. It also gives the ICO's postal address, phone number, and website for complaints that go to the regulator. The table of contents was updated to list this new section, which shifted the numbers of the two sections after it.

199
200You have the right to complain about how we use your personal data. If you are unhappy or have concerns, please contact us first using the details in [our contact details]() above, so we can try to resolve the issue.
201
202You also have the right to make a complaint to the UK Information Commission (IC). However, the law now requires you to raise your complaint with us before complaining to the IC. If you do complain to us, we will acknowledge your complaint within 30 days, investigate it fairly and promptly, and write to you with our response.
+ ADDEDNew requirement to complain to Wordwall before the ICO

The new section states that, under a change in UK law, you must now raise your complaint with Wordwall before the ICO will investigate it, and that the ICO 'typically requires' proof you completed Wordwall's internal process first.

203
204You have the right to complain to the UK IC at any time, using the contact information below:
205
206Please ensure that you state 'Data Protection Complaint' in the subject field.
207
208The Information Commission's address:
209Information Commission
210Wycliffe House
211Water Lane
212Wilmslow
213Cheshire
214SK9 5AF
215
216Helpline number: 0303 123 1113
217ICO website: [https://www.ico.org.uk](https://www.ico.org.uk/)
218
219Under the UK Data (Use and Access) Act 2025, the IC typically requires you to have completed our internal complaints process, before they will investigate.
220
195221## Legal Compliance
196222
197223We 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.
198224
199225## California Privacy Rights (CCPA/CPRA)
200226