Last updated and effective from 26 May 2020.
SuperAwesome Trading Limited (Company Number: 03885555) is a private limited company incorporated in England, having its registered office at 8 Duncannon Street, London, England WC2N 4JF, United Kingdom, (referred to herein as “SuperAwesome,” “us”, “our” or “we”).
Table of Contents
- Important information and who we are
- Contact details
- Children’s privacy and safeguarding
- The data we collect and process
- How is your personal data collected?
- How we use your personal data
- Sharing of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- Location specific rules
1. Important information and who we are
Publishers and Parents
2. Contact details
Legal entity: SuperAwesome Trading Limited
Mail: 8 Duncannon Street, London, England, WC2N 4JF, United Kingdom
Telephone: + 44 (0) 203 668 6677
3. Children’s privacy and safeguarding
KWS has been certified as compliant with the Children’s Online Privacy and Protection Act (“COPPA”) by two FTC-approved COPPA Safe Harbor Programs, the Entertainment Software Rating Board Privacy Certified Program and KidSAFE. KWS is subject to audits and other enforcement and accountability mechanisms as part of such certification.
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As with all of SuperAwesome’s products and services, KWS is subject to periodic technical and legal review through its Compliance Committee comprising our Chief Privacy Officer, Chief Technology Officer and its Information Security and Legal teams.
We may collect, use, store and disclose different types of personal data about you which we have set out below:
KWS Parent Portal
- KWS Parent Portal Access Data means the data provided by the Parent to register and access the KWS Parent Portal, which comprises: Parent email address and password (note for accounts registered post June 2019 no password is collected), and a system-generated parent ID number.
- Parent Contact Data includes: name, email address and telephone number of a Parent (to the extent that a Parent provides any such information as part of a general support query).
- Parent verification (any location) comprises credit card number, CVV, expiry date.
- Parent verification (US only) includes full name, last four digits of Social Security Number, date of birth, and mailing address.
- Parent verification (Brazil only) includes CPF number and date of birth.
- Technical Data means the data collected from devices of a Parent who has access to the KWS Parent Portal and which includes internet protocol (IP) address, login data, browser type and version, time zone setting country and language, browser plug-in types and versions.
- Verification Status comprises a combination of a one way hashed Parent email address, verified status and method, and the timestamp for the verification provided.
KWS Control Panel
- KWS Control Panel Access Data includes first name, last name, email address and password of the designated Publisher personnel accessing the KWS Control Panel to manage their Publisher Site activity.
- Standard Site User Data means the username, password and KWS system-generated user ID of a child who uses a Publisher Site.
- Bespoke Site User Data is non-Standard Data which a Publisher has specifically requested KWS to collect and process from a child who uses their Publisher Site. This may include the following data: display name, date of birth, email address, postal address – as permitted and controlled by the parent or guardian using the KWS Parent Portal.
- Technical Data means the data collected from devices of Publisher Personnel who have access to the KWS Control Panel and which includes internet protocol (IP) address, login data, browser type and version, time zone setting, country and language, browser plug-in types and versions, operating system and platform.
We do not collect any Special Categories of personal data (as defined in GDPR) about you – for example 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). KWS does not collect information about criminal convictions or offences.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your contact details by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- enquire about our products or services; subscribe to our service or publications, or give us feedback;
- if you work for a company and you create a KWS Control Panel account or are added to your company’s account; or
- if you are a Parent signing up to use the KWS Parent Portal.
Automated technologies or interactions. As you interact with KWS (such as using the KWS Parent Portal or KWS Control Panel), we will collect Technical Data about your equipment, browsing actions and usage patterns on KWS. We collect this personal data by using cookies, server logs and other similar technologies.
Other ways we process personal data
On behalf of our business customers who are Publishers and have access to the KWS Control Panel, SuperAwesome collects and processes certain personal data of children, see Standard Site User Data and Bespoke Site User Data above for more information. For the purposes of GDPR, the Publisher is the data controller of any personal data they submit to the KWS Control Panel and is responsible for informing SuperAwesome of any changes required should an employee’s access need to be added or revoked.
When a child signs up to use a Publisher Site that uses KWS they are asked to provide a Parent email address so that KWS can contact the Parent to request their participation in the applicable parent verification process. The KWS Parent Portal will then contact the Parent, usually via email, to inform them that their child wishes to use a Publisher Site which requires verified parental consent and to request that the Parent complete the parental consent verification process, which, when this process is successfully completed, will generate the Verification Status.
Where KWS has previously verified a Parent (based on checking our records of Verification Status for that Parent’s email address) it will notify the Parent that their child wishes to use a new Publisher Site without the need for the Parent to undertake additional verification actions. That notification will include a request for them to set or review permissions for their child using the KWS Parent Portal.
6. How we use your personal data
We will only use your personal data when we have a legal basis to do so. In most cases, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with a Publisher;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
- Where we need to comply with a legal obligation – e.g. a law or regulation.
Purposes for which we will use your personal data
We have set out below a description of the ways we may use 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. When we refer to our ‘legitimate interests’, we mean the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and on 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.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need more information.
KWS Parent Portal
|Purpose for collecting personal data||Type of personal data processed by KWS||Lawful basis for processing personal data|
|To facilitate parent registration and access to the KWS Parent Portal||KWS Parent Portal Access Data||Legitimate interests to provide Parents with access to the KWS Parent Portal|
|To respond to support queries from a Parent||Parent Contact Data ||Legitimate interests to provide information and assistance to a Parent|
|To obtain Parent Verification ||The personal data required from a Parent will vary by region. Generally it will comprise Parent credit card details, or information from a government-issued identity document – for example social security number||Consent to initiate the Parent verification process|
|To use data analytics to improve KWS, customer relationships and user experiences||Technical Data||Necessary for our legitimate interests to operate, maintain and improve KWS|
|To improve KWS Parent and site user experiences||Aggregated Verification Status ||Necessary for our legitimate interests to operate, maintain and improve KWS|
KWS Control Panel and Publisher Site
|Purpose for collecting personal data||Type of personal data processed by KWS||Lawful basis for processing personal data|
|To enable Publisher personnel to use the KWS Control Panel ||KWS Control Panel Access Data||The performance of our contractual obligations with Publishers|
|To enable Publisher Site user registration and age gate process||Standard Site User Data||The performance of our contractual obligations with Publishers|
|For Publisher Site functionality requirements||Bespoke Site User Data ||The performance of our contractual obligations with Publishers |
|To use data analytics to improve KWS Publisher relationships and Publisher Personnel experiences||Technical Data||Necessary for our legitimate interests to operate, maintain and improve KWS|
We do not normally send marketing materials to Parents. From time to time Parents may receive service information updates via the KWS Parent Portal.
If a Publisher sends you marketing materials that you do not wish to receive, you will need to contact them directly or change your preferences in the KWS Parent Portal if marketing preference options have been provided there.
Change of purpose
We will only use your personal data for the purposes for which we originally 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 us. 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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7. Sharing of your personal data
We may share your personal data with the parties set out below for the purposes set out above:
- Third parties contracted by SuperAwesome to process personal data on our behalf – see our current list here; and
The KWS Control Panel and KWS Parent Portal use third party data processors, some of whom may process personal data. For example, we use a third party to host the KWS platform and we use third party tools to help us better understand how customers and their employees navigate across the KWS Control Panel. You can learn more about how our third party data processors use data by reading their privacy policies.
We may disclose your personal idata: (a) in the good faith belief that we are required to do so by law; (b) if doing so is reasonably necessary to comply with legal process; (c) to permit us to pursue available remedies, including commencing or responding to any claims; (d) to enforce the terms and conditions of KWS; (e) to protect the rights, property, or personal safety of SuperAwesome or the public; (f) or other illegal activity, or (g) for risk management purposes.
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8. International transfers
We share your personal data within the SuperAwesome group of companies. This will involve transferring your data outside the European Economic Area (EEA). Some of our third party data processors are based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA. Whenever we authorise a transfer of your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by using specific contracting frameworks approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. Please contact us if you require further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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9. Data security
SuperAwesome values your trust and strives to maintain adequate security measures for all areas of our business and our services. Since KWS is a service that operates digitally, SuperAwesome is continuously reviewing and improving its security measures to prevent data breaches and security incidents. 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 strictly on a need to know basis. 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.
Some of the correspondence you receive from us may contain links to and from third party websites, online services or mobile applications that are not affiliated with or operated by us, including those of the customers who use KWS. While SuperAwesome tries to link only to websites that share our high standards and respect for privacy, we are not responsible and accept no liability for the content, security or privacy practices of those other websites. You should view the privacy and cookie policies displayed on those websites to find out how your personal data may be used.
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10. Data retention
We will only retain your personal data for as long as is 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.
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. We also take into account applicable legal, regulatory, tax or accounting requirements. If a parent deletes their KWS Parent Portal account, we will retain their Verification Status for future verification purposes involving KWS. As set out above, this eliminates the need to re-verify the parent’s identity and minimises personal data collection. Parents may exercise their rights in accordance with section 11.
In some circumstances we may use de-identified personal data (so that it can no longer be associated with you) on an aggregated basis for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
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11. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. For example you will have rights to:
Request access to your personal data (commonly known as a “data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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 as the legal basis upon which to process your personal 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.
If you wish to exercise any of the rights set out above, please contact us. If you are a California resident, please refer to our California Residents section below for more information on your legal rights.
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.
Do Not Track disclosure
Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. Currently, KWS does not support and does not act on DNT signal headers that we may receive.
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12. Location specific rules
Depending on where you are resident specific rules apply. See below for further info:
UK and EU Citizens
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact the Information Commissioner’s Office (www.ico.gov.uk) which is the regulator responsible for data protection in the United Kingdom, where SuperAwesome Trading Limited is located (Registration number Z8630714)
Alternatively, if you are located outside of the United Kingdom, you may contact your local data protection authority. You can find contact details here.
United States residents
If you are a resident of the United States and believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB Privacy Certified at firstname.lastname@example.org or by using their online contact form at: https://www.esrb.org/privacy/contact.
For the purposes of this section:
Personal Information and Service Provider have the meanings assigned to them under the California Consumer Privacy Act of 2018, (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations (CCPA).
In the past 12 months, SuperAwesome, or its third parties, have collected the following categories of Personal Information using the categories enumerated in the CCPA:
- IP address and device ID
- Name, email address or telephone number if you’ve contacted SuperAwesome with an inquiry
We use this Personal Information as disclosed above and share this personal information as disclosed above in the Disclosures of your personal data section of this policy.
In the preceding twelve months, we have not sold any California resident’s Personal Information.
Right to Know and Access. If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:
- The specific pieces of Personal Information we have collected about you during the last 12 months;
- The categories of Personal Information we collected, sold or disclosed for a business purpose about you within the last 12 months;
- The categories of sources from which the Personal Information was collected;
- The purposes for which the information was collected or sold; and
- The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared.
Because SuperAwesome is a Service Provider, we may not be able to respond directly to your request; in this case, we will direct you to contact the Provider for additional information. Where possible, we will provide this information to you in a readily usable format that allows transmission to another entity. To submit a request, click here to access our online web form or email us at email@example.com. We will confirm your request within 10 days of receipt.
Right to Delete. Because SuperAwesome is a Service Provider, we may not be able to respond directly to your request; in this case, we will direct you to contact the applicable third party for additional information. If you are a California resident, you may submit a verifiable request for us to delete any personal information we have collected about you. To submit a request, please email us at firstname.lastname@example.org or please use this webform.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. If we need additional information to verify your identity, we will contact you to request that information.
Right to be Free from Discrimination. We will not discriminate against you because you have chosen to exercise your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
Exercising Your Rights. To submit a verifiable request or to otherwise contact us for more information about how to exercise your rights, please follow the instructions above. If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent is able to (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
California residents “Shine the Light” Law
We do not share your personal information with any unaffiliated third parties for their own marketing purposes.
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