GDPR Compliance Statement
To the best of our knowledge, having sought legal advice and followed technical recommendations, we are compliant with UK GDPR and the ICO Age Appropriate Design Code. In order to remain so, we will continually monitor changes in legislation and make amendments, should we need to, in light of these.
Your data is safe with the Road to Health Group Ltd.
ICO Children's Code
Our MirrorMe Game has been carefully crafted with the utmost consideration for the child's welfare, aiming to assist and motivate children in attaining improved levels of health and overall well-being. By default, our privacy settings are set to the highest level, ensuring that any data collection is kept to a minimum. MirrorMe does not incorporate any geo-location services or advertisements that may compromise the child's privacy. Moreover, we provide a privacy notice specifically tailored to children, enabling them to comprehend how we handle their data.
Important information, and who we are;
Mirror Me, is a game created by the Roadtohealth Group (RTHG). RTHG assumes the role of the controller and holds the accountability for safeguarding your personal information (collectively referred to as the "Company," "we," "us," or "our" throughout this policy).
We have appointed a Data Protection Manager. If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
Our full details are:
- Full name of legal entity: Roadtohealth Group Ltd
- Name or title of Data Protection Manager: Adam Bates
- Email address: enquiries@roadtohealthgroup.com
- Postal address: 30-34 North Street, Hailsham, East Sussex, BN27 1DW
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
RTHG privacy notice for Parents, Teachers, Coaches, Carers and Tutors
About our Privacy Notice
RTHG Ltd ("we" or "us") is committed to protecting and respecting the privacy, safety and security of our registered (and prospective) users, including pupils, teachers, school administrators and parents (together "Users").
This notice (together with our terms of use) and any other documents referred to in it explains in plain language who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. Please read this notice carefully to understand how any personal information is used. If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated January 2024. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next use the App or Services. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or Services.
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 our relationship with you.
What Personal Information does RTHG Ltd collect?
We collect the following categories of personal information:
School Users
In the case of school/educational institution subscriptions (including on a trial basis) ("School Users") we may collect:
School's name, address (for billing purposes and account name)
Teachers' names, email addresses (so we can provide you with an account and contact you)
Pupils' names, year groups and classes (to administer accounts)
Home Users and Tutors In the case of home or family subscriptions ("Home Users"), or tutor subscriptions, we may collect:
Parents'/Tutors' names and email addresses (so we can provide you with an account and contact you)
Children's names (to administer accounts)
We may also collect details of other interactions that you and/or your users have with us, together with any other information that you and/or your users choose to provide us with, for example, through correspondence and interactions with our customer and technical support teams.
This information is required in order to fulfil our contractual obligations to you as it is necessary to correctly identify each registrant as a site user, manage their account and for other purposes identified below. It is impractical in most circumstances for users to remain anonymous, as we may not be able to interact with you, provide access to the Sites, or answer your enquiry if we are not able to identify users or collect your personal information.
Please note that by registering with MirrorMe and providing the requested personal information, whether on a trial, subscription or gifted basis, the School is deemed to have a lawful basis (pursuant to all applicable data protection laws) for supplying such data and information for and on behalf of all users (to include both teachers and pupils). It is the school's responsibility to ensure that they have a sufficient lawful basis for supplying all data to us. Where the lawful basis that the school is relying on is "consent", it is the School's responsibility to seek and confirm all necessary parental consent for all pupils. If a school does not have (or in the future no longer has) a sufficient lawful basis for supplying us with such personal data, any User to which this applies must not use the Sites, and the School must promptly inform us so any relevant data can be deleted from our Sites.
We do not collect any unnecessary personal information from users (for instance, information about religious beliefs, medical history etc).
Children signing up to our Sites and Consent
Please note that children (under the age of 18 years) cannot register to use the Sites themselves, as they are not lawfully able to agree to our Terms and Conditions. A teacher, tutor, parent or guardian must register for them (either as part of a school subscription, tutor subscription or home subscription) and it is the teacher, tutor, parent or guardian's responsibility to ensure that any consent to use the Sites has been collected (including on a trial basis).
Using Wonde - Wonde School Data Management
We use Wonde for onboarding pupils to the MirrorMe game.
Wonde School Data Management enables schools to securely share the data in their MIS with third party applications.
Wonde School Data Management supports schools and trusts with their data protection and supply chain management obligations, ensuring optimum data security and the smooth implementation and management of software across the school.
Wonde's Data Processing agreement can be viewed here Wonde DPA
How does MirrorMe (RTHG Ltd) collect Personal Information?
The personal information collected about users broadly falls into the following categories:
Information that you provide voluntarily
We may obtain personal information directly from you (unless it is unreasonable or impracticable to do so) or from our School Users or Home Users about you and/or other Users voluntarily by filling in forms on our Sites, or by corresponding, email or otherwise. This includes information that you provide when you register an account with us, enter a competition or survey, and/or to submit enquiries to us.
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to Users at the point we ask you to provide such personal information.
Information that we collect automatically
When Users visit our Sites, we may collect certain information automatically from their device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like a user's IP address, device type, unique device identification numbers and login information, browser-type and version, time zone setting, operating system and platform, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how a user's device has interacted with our sites, including the pages accessed and links clicked, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from any page.
Collecting this information enables us to better understand the users who come to our sites, where they come from, and what content on our sites is of particular interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our sites to our users.
We will also collect the answers provided by users to the questions raised on each programme and the length of time taken to respond in each case. This information is required to enable us to provide statistical feedback to teachers and parents on the performance and progress of pupils, a facility which is an integral part of our products.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading "Road to Health Group's" Cookie Policy"
Information that we obtain from third party sources
From time to time, we may receive information about you if you use any of the other Sites that we operate or the other services and products that we provide. In this case we will have informed you when we collected that personal information that it may be shared internally and combined with data collected on the relevant Sites.
From time to time, we may receive personal information about you from third party sources (including for example, distributors, business partners, affiliates, sub- contractors, payment and delivery services, analytics providers, search information providers), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
What does RTHG Ltd do with your Personal Information?
The personal information of users, including any prospective users, may be used for the following purposes:
To carry out our obligations arising from any contracts entered into between you and us and to provide access to our products and services including the Sites;
To send a confirmation notice to the user of the registration;
To administer and manage accounts, including username and password resetting, responding to enquiries raised by users, to contact users about any problems with their accounts, or the use of our products and services, or their conduct on the Sites;
To calculate the user's recall speeds;
To provide results data for each user, school class, or school as a whole, including the preparation of statistical reports and data analysis to assist us in enhancing the learning from our Sites;
To provide you with tips on how to use parts of the product or service, information about new features on our Sites;
To notify you about changes, improvements, and upgrades to our products and services and the Sites;
To ensure that content from our Sites is presented in the most effective manner for users and for their computers or devices;
To keep our Sites safe and secure;
To administer our Sites and for internal operations, including troubleshooting, data analysis, testing, research, product development, quality control, statistical and survey purposes;
To send out newsletters and emails about our products and services, including the Sites including information about upcoming events, competitions, and rules of the Sites; and/or
To send you information about third party services that we feel may be of interest to you, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. If you do not want to receive these updates, users may opt out at any time by following the specific opt out instructions within the communications that we send, or by updating their details on the "My Details" page of our Sites.
Please note that our Sites do not provide pupils with any means to communicate directly with each other. There are no chat rooms connected with our products and services.
Legal basis for Processing Personal Information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. Ordinarily, we collect personal information from users either because it is needed to enable us to fulfil and perform our contractual obligations with you as regards the provision of our products and services, and/or where we have the consent of the Users to do so. We may also process personal data where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
Who does RTHG Ltd share my personal information with?
We will keep personal information confidential and will not sell or knowingly divulge users' information to advertisers or any external third parties, however the following categories of recipients may access, process or be transferred your data:
- our group companies;
- our sub-contractors who assist us in making, improving and delivering the Sites;
- third parties who provide services on our behalf to help with our business activities.
These parties are authorised to process your personal information only as necessary to provide these services to us. Such services may include payment processing, providing customer service, sending marketing communications, those who help to enhance the security of our Sites, and those who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
Government education departments, universities, bodies managing or representing schools, or schools themselves, to help enhance the learning from our Sites through the preparation of statistical reports and analysis. Any data provided to such establishments for their own analysis will always be provided as aggregated (non-personal) or de-personalised data, in such a way that they are unable to identify any individual child directly or indirectly. It is lawful for us to de-personalise this data as we rely on legitimate interest as our lawful basis to do so and it is lawful for us to share this de-personalised data and any associated reports as we are not sharing any data that can be identified as personal;
any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, (iii) to enforce our terms and conditions, or (iv) to protect your vital interests or those of any other person;
a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; and/or
any other person with your consent to the disclosure.
How does RTHG Ltd keep my personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The data that we collect from you is stored on secure servers. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. All traffic and passwords are encrypted. As part of our privacy compliance processes we review these security procedures to consider appropriate new technology and methods.
You and your pupils/children are responsible for keeping your passwords confidential. We ask Users not to share their passwords with anyone. Users should be aware that unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We also expect all our employees and contractors to comply with this Privacy Notice, and we will take appropriate actions to address breaches by employees and contractors of the obligations imposed by this Privacy Notice
Data Retention
We retain personal information we collect from Users where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process User's personal information, or where you ask us to delete Users' information, we take reasonable steps to either delete or anonymise it. If this is not possible immediately (for example, because your personal information has been stored in backup archives), then we will securely store Users' personal information and isolate it from any further processing until deletion is possible, but will endeavor to do so as soon as reasonably practicable. We may have to retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our terms and conditions.
Our policy is to automatically delete all pupil/child data from school accounts, tutor accounts and family accounts 12 weeks after expiry of a free trial or expiry of a subscription, where no renewal or pending subscription has been requested by that school, tutor or family. Please note that subscriptions are not automatically renewed at expiry. The main contact will be notified by us of our deletion policy prior to expiry of the subscription, and again prior to deletion of the pupil data. Deleted pupil/child data cannot be retrieved following deletion.
Your Data Protection Rights
Users have the following data protection rights:
If a User wishes to access, correct, update or request deletion of their personal information, or that of their school (in the case of teachers), they can do so at any time by contacting us using the contact details provided under the "How to contact us" heading below. Users can also delete all of their personal data by navigating to "Subscription Details" and pressing "Delete".
In addition, Users can object to processing of their personal information, ask us to restrict processing of their personal information or request portability of their personal information. Again, Users can exercise these rights by contacting us using the contact details provided under the "How to contact us" heading below.
Users have the right to opt-out of marketing communications we send at any time. Users can exercise this right by either clicking on the "unsubscribe" or "opt-out" link in any marketing e-mails we send, or by updating their details on the "My Details" page of our Sites. Alternatively, Users can contact us using the contact details provided under the "How to contact us" heading below.
Similarly, if we have collected and process Users' personal information with their consent, then Users can withdraw their consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to withdrawal, nor will it affect processing of personal information conducted in reliance on lawful processing grounds other than consent.
Users have the right to complain to a data protection authority about our collection and use of their personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.)
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. Users will be deemed to have consented to any such changes by their continued use of the Sites following any changes being made.
You can see when this Privacy Notice was last updated by checking the "last updated" date displayed at the top of this Privacy Notice.
How to Contact Us
If you have any questions or concerns about our use of your personal information, please contact us using the following details: enquiries@roadtohealthgroup.com