Welcome to the Babbu’s privacy policy.

Updated 18 January 2024

At Babbu, we are committed to protecting your privacy and that of your child. This privacy policy will inform you how we look after your personal data when you visit our website or use the Babbu Platform. It also tells you about your privacy rights and how the law protects you.

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

1                 WHO WE ARE

Babbu Limited is the data controller (collectively referred to as "we", "us" or "our" in this privacy policy) and responsible for the processing of your and your child’s personal data.

If you have any questions about this privacy policy or our privacy practices, please contact  us in the following ways:

Email address: hello@babbu.co.uk

Postal address: Senna Building, Gorsuch Pl, London E2 8JF

2                 HOW YOU CAN MAKE A COMPLAINT

You have the right to make a complaint about our processing of personal data at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.

3                 WHAT DATA WE COLLECT ABOUT YOU

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

We may process different kinds of personal data about you and your child which we have grouped together as follows:

·         Identity Data includes your name, the name of your child and the date of birth of your child.

·         Contact Data includes your name and email address.

·         Financial Data includes your payment card details (although this is handled pay a payment processor appointed on our behalf; we have no access to this data).

·         Transaction Data includes details about payments to and from you and other details of 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, and other technology on the devices you use to access this website.

·         Profile Data includes your username and password, your Facebook login details, purchases or orders made by you, your child’s abilities, information about your child’s learning goals, feedback and survey responses.

·         Usage Data includes information about how you use our website, the Babbu Platform or our products and services.

·         Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

·         Location Data includes information about where and when the device you used to access our services was located.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 personal data by law or to supply a service you requested, and you fail to provide that data, we may not be able to perform the service. 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.

Please inform us of changes in your data

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.

4                 HOW WE COLLECT YOUR PERSONAL DATA

Whenever you interact with us, we collect data.  Sometimes you provide us with data, sometimes data about you is collected automatically.

Here is when we collect personal data from you directly:

·         You enter personal data on our website

·         You sign up to our newsletter on our website

·         You contact us via email, telephone or postal mail

·         You purchase a product or service

·         You register with our Babbu Platform

·         You enter details about your or your child on the Babbu Platform

·         You opt in to your marketing communications

·         You interact with us on social media sites

·         You give us consent to collect location data

We may also receive personal data from the following third parties:

·         If you chose to login through Facebook, Facebook will provide us with specific data provided by Facebook to enable account and identity verification about you.

·         We receive analytical data from Google cookies that we ask Google to set.

5                 The Data of your child

Where you provide us with personal data of a child, you represent that you are the legal guardian of the child and have the right to share its data with us.  You must not share personal data of a child if you do not have the legal right to do so.

6                 HOW WE USE YOUR PERSONAL DATA

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

·         Where we need to perform a service or supply a product you requested.

·         Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights or those of your child do not override those interests.

·         Where we need to comply with a legal obligation.

·         Where you have given us consent.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways in which we plan to use your personal data, and which of 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.

Purpose/Activity

Lawful basis for processing

To register you on our website or Babbu platform

·       To perform a service or supply a product

To provide services or products to you

·       To perform a service or supply a product

To collect and recover money owed to us

·       To pursue our legitimate interest

To manage our relationship with you

·       To perform a service or supply a product

·       To pursue our legitimate interest

To administer and protect our business, this website and our Babbu Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

·       To pursue our legitimate interests

·       To comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

·       To pursue our legitimate interests

To make suggestions and recommendations to you about services or products or learning units from us that may be of interest to you

·         To perform a service or supply a product

·         To pursue our legitimate interests

Promotional offers from us

We may use your 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 (we call this marketing).

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

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time via hello@babbu.com.

Cookies

Our website uses cookies. Unless you make changes to your browser settings to turn them off, we will issue cookies whenever you interact with our website. Some cookies delete themselves when you leave our website, others will not delete themselves and help us recognise you when you return. This helps us show you information we think you might be interested in. Currently we only use the following cookies:

·         user session control cookies;

·         Google analytics cookies.

7                 WITH WHOM WE MAY SHARE YOUR PERSONAL DATA

We may share your personal data with the parties set out below :

·         Other users: Our Babbu Platform may allow you to share information about you or your child with other users, advisers. Any such sharing will be initiated by you.

·         Service providers: these are companies or persons who provide IT and system administration services to us.

·         Professional advisers: including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services to us.

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.

8                 WHERE YOUR DATA WILL BE LOCATED

We do not transfer any personal data about you or your child outside of the UK or EEA.

9                 HOW WE KEEP YOUR DATA SAFE

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.

10              FOR HOW LONG WE WILL USE YOUR DATA

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  keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes and to be able to respond to any legal claims that are served with the six year limitation.

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.

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

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.

11              YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

·         The right to access all personal data that we process about you, subject to legal exemptions and parameters.

·         The right to ask us to correct personal data that we process about you.

·         The right to request erasure of all personal data that we process about you, subject to legal exemptions and parameters.

·         The right to object to processing of personal data that we process about you or your child, subject to  legal exemptions and parameters.

·         The right in certain circumstances to request restriction of processing of personal data we process about you or your child, subject to legal exemptions and parameters.

·         The right to request the transfer of all personal data that we process about you, subject to legal exemptions and parameters.

·         The right to withdraw consent at any time where your personal data is processed using consent.

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.