Our Privacy and Cookie Policy

We urge you to read the Skwibble privacy policy, which contains details on how we collect, use, process and store all personal information across our app and website (“The Service”). If you have questions regarding this policy, we invite you to get in touch. If you do not agree to your personal data being used as outlined in this Privacy Policy, please refrain from providing Skwibble with personal information. Please note, this policy may be updated periodically, without advance warning and any changes will be posted on this page. Therefore, it’s recommended that you check back regularly to review the policy and any updates. By continuing to use the Skwibble service following any changes to the Privacy Policy, you’re acknowledging that you consent to any alterations made.

Skwibble | Company Information

Skwibble, as 'data controller', is owned and operated by Skwibble Limited. Our official website address is www.skwibble.com – we are not affiliated with any websites or companies of a similar name.

Skwibble Ltd is a registered company incorporated in the UK, with a registered address at Flat 45 Attenborough Court, Owen Square, Watford, Hertfordshire WD19 4FN. Our company number is 09876421.

Contact Details:

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

Full name of legal entity: Skwibble Ltd

Email address: hello@skwibble.com

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 (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.

Privacy Policy Updates

Although no advance notice is given in respect of potential changes to Skwibble’s Privacy Policy, we do conduct regular reviews to ensure continued compliance with data protection laws. We carry out reviews:

1. On an annual basis.

2. As part of the process for introducing new products, services or functionalities to The Service.

3. In response to feedback provided by customers.

4. As advised by the UK’s Information Commissioner’s Office. As a result of changes to UK legislation.

Information Gathered by Skwibble and what it’s used for

Skwibble takes the management and security of your personal data very seriously. Please be assured that data we acquire is never sold, shared or rented unless specified in the details of this Privacy Policy. Please also note that we don't identify individuals to advertisers or sell user data to any third parties without explicit written consent from user.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, relationship to child, and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
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, 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, a photograph, your interests, preferences, playpen name, list of visitors, feedback, playpen photo and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: - apply for our products or services - create an account on our website - 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. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google;

(b) advertising networks; and

We gather Personally Identifiable Information (PII) for the following purposes:

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, 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 you.
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.
Where we need to comply with a legal obligation.

Please see the table below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 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.

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	Type of data	Lawful basis for processing including basis of legitimate interest
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts due to us
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (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 and to study how customers use our products/services
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
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 advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
To build your user profile	(a) Profile (b) Identity	Performance of a contract with you
To add a second user to your account	(a) Identity (b) Contact	Performance of a contract with you
To build your playpen account	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Performance of a contract with you
Building a child profile	(a) Identity (b) Contact (e) Profile	Performance of a contract with you
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests to develop our products/services and grow our business

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile 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 goods or 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 logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

1. Your account

As Account Creator, you will be designated as the Account Owner, which will allow you to create child profiles within the confines of your account.

Your email address, along with a secure password, will form the login details to your account.

2. Building a User Profile

Following your account registration, which must include your contact details, you can build and edit a user profile. The user profile allows you to specify your relationship to the child i.e. Mum, Dad, Primary Carer and provide a photo of yourself.

3. 2nd User Login Details

Those persons assigned the role of Account Owner will soon be permitted to invite a 2nd person to sign-up with editing rights. Please note that this feature is not yet available but will be introduced to the Service in the near feature.

4. Building a Playpen

The concept behind building a Playpen is to encourage grouping of friends, family, etc in order to allow the User to have better control of how the information they upload is shared. In this instance, Skwibble gathers a small amount of information, which can be used to identify a specific Playpen.

5. Building a Child Profile

The primary purpose of Skwibble is to give Users a platform to blog and build a memory bank of experiences and media on behalf of their children.

In addition to gathering PII information, Skwibble collects Non-Personally Identifiable Information (Non-PII) for system administration and to report aggregate information to our advertisers. This includes, but is not limited to:

Your computer’s IP address. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.

Your IP type. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
Your Internet Service Provider (ISP) Address. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
Cookie IDs. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
Segment IDs (associated with Cookie IDs). Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
Pages viewed and search terms used (for internal research purposes).
Your Internet browser type (i.e. Google Chrome, Internet Explorer or Firefox). Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
The operating system you use. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
The duration and frequency of your visits to www.skwibble.com. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
Anonymous usage statistics, including how frequently you message and interact with other Skwibble users. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
Clickstream and other log file data. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
Social analytics and tracking measurements, which do not identify the user. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.

If you’re accessing the Skwibble service via a mobile device, such as a smartphone or tablet, we may collect the following information:

The type of device you’re using.
The make and model of your device
The operating system of your device
The carrier on your device
User IDs
Information about the services you use (i.e. apps)

Please note:Skwibble is likely to use third-party services to assist in our business operations. Those connected and affiliated third-party service providers may collect Non-PII information from the Skwibble service too. By continuing to use our site and app you agree for third party services to have access to your non-PII information.

Other Information Collected

We may additionally collect and process the following data about you:

Information you provide on any forms or in relation to any surveys on the Service;
A record of any correspondence between us;
Details of any transactions you carry out through our Service (e.g. when purchasing a book or an e-book).

How We Use What We Collect

We use the information we collect about you to:

Present content effectively to you;

Provide information, products and services that you request, or (with your consent) which we think may interest you;

Carry out our contracts with you;

Allow you to use our interactive services if you want to;

Tell you about changes to our service;

Provide, improve, test, and monitor the effectiveness of our service, develop and test new products and features, monitor metrics such as total number of visitors, traffic, and demographic patterns, and diagnose or fix technology problems.

If you are already a member, we will only contact you electronically about things similar to anything that was previously sold to you. If you are a new member (and where we permit selected third parties to use your data), you will only be contacted if you agree to it. If you don't want to be contacted for marketing purposes, or you do not wish us to pass your details on to third parties for marketing purposes, please tick the relevant box that you will find on screen when we collect your data.

Cookie Policy

What are cookies? Cookies are small files that are stored on your computer or mobile device when you visit our website and app, if you agree. They hold a minimal amount of data and are sent to your web browser from a web server. Our affiliates and any of our advertisers could potentially use cookies to gather information from users of the service.

We also use cookies to distinguish users and recognise you and your preferences, to improve our service, to collect analytical information for ourselves and our business partners and for the purposes of measuring website visits and to monitor visitor patterns. The information does not identify you personally and is used to improve service user experience. Cookies do not extract PII information from any computer or device.

'Session cookies' allow us to track your actions during a single browsing session, but they do not remain on your device afterwards. ‘Persistent cookies’ remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our website and app. Session and persistent cookies can either be first or third party cookies. A first party cookie is set by the site being visited; a third-party cookie is set by a different website. Both types of cookies may be used by us or our business partners.

Please note: Skwibble reserves the right to share or utilise any cookie information in collective form, for purposes of our own discretion. Third-party advertisers who use the Skwibble service to display advertisements may also deploy their own cookies.

To prevent cookies on your computer or to remove them from your browser completely, refer to your web browser settings and preferences. However, please be advised that restricting cookies may affect some features of the Skwibble service in terms of functionality and may mean that you will not be able to use certain important features of our service.

Additionally, opt-out features for cookies on mobile devices are ineffective, but you can restrict mobile tracking activities via your device settings.

Web-Based Advertising

It’s possible that advertisements in relation to Skwibble’s products and services will appear on third-party websites across the internet. Some of our affiliate third-party ad networks and selected third parties may present advertisements that they believe will be of most interest to you, based upon information we may share with them about your online history.

For instance, by viewing websites about childcare or parenting, it's possible that you may be delivered an advert about Skwibble’s services. This form of target-specific advertising is often referred to as interest-based or online behavioural advertising.

However, we don’t identify individuals to our advertisers, but rather we give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience. Please note: We assume no control over such third-party websites or services on which any of our advertisements may appear.

Additionally, we have no influence on how they collect or use information in relation to your web/app-based activities. However, it’s possible to avoid being tracked online by certain companies by heading over to aboutads.info

You won’t stop receiving adverts by opting out, but you will cease to receive ads based on your online activities. However, the opt-out process relies on an opt-out cookie. If you decide to delete your cookies, or use an alternative computer, you will have to repeat the opt-out process each time.

Clickstream

What is clickstream analysis? Clickstream analysis refers to data that is collected about which pages you visit on a website/app and in what order you visit them. Every time you access a website or app, you leave an ‘electronic fingerprint.

Clickstream data is collected and stored by a website/app’s server and informs Skwibble of the type of computer and browsing software that you’re using, plus it gives us the address of the website (if any) from which you linked to the Skwibble service.

We’ll potentially use clickstream data to establish, anonymously, how much time our website/app visitors are spending on each page of the service. We’ll also use the data to analyse how visitors navigate the site and what this tells us about how we can improve the user experience.

Where We Store Your Data

We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA. By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure and in accordance with this Privacy Policy, however we cannot guarantee its security.

Any payment transactions will be encrypted. If we give you a password, you must keep it confidential. Please don't share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Skwibble Security

The security of the Skwibble service and your personal information is one of our top priorities. We’ve invested heavily to ensure that all reasonable and practical steps have been taken to stop improper access to user data stored across our servers.

However, due to the Internet’s open access, we are unable to guarantee the security of information presented online against improper use. As a result, by using the service, you acknowledge that you’re doing so at your own risk.

It’s possible that Skwibble will amass Non-PII information and retain it for the purposes of analysis. Additionally, we or our service-providers may retain PII data (including your profile information) that has been supplied by you when using the service for backup, archival and/or audit purposes, for a commercially reasonable time following termination or deactivation of your account.

In the event of any disputes or disagreements, or in accordance with our legal obligations, we reserve the right to retain PII information for a longer duration. Please be advised that Skwibble accepts no liability for disclosures of your data due to errors or unauthorised acts of third-parties, including third-party host providers.

Social Media and Third-Party Links

The Skwibble service, plus any advertisements, could feature links to and from other websites or platforms. It’s possible that other websites and platforms link to the Skwibble service. Some of our third-party affiliates could use their own cookies or other information gathering applications.

Please note that our terms and policies will not apply to other websites that you get to via a link from our Service. Separate domains, websites, platforms or services are not under our control, and we recommend that you refer to the privacy policies and T&Cs of any other service you interact with. We do not accept any responsibility of liability for their terms or policies.

We do not screen the activities of other websites or platforms, nor do we endorse, approve or take responsibility for the privacy policies of other sites or platforms that you interact with. You visit websites and platforms outside of Skwibble at your own risk.

Social media platforms - such as Facebook, Twitter, Google+, LinkedIn, Instagram, Pinterest and others - may link to the Skwibble service. Equally, the Skwibble service may link out to several social media platforms.

If you choose to connect to social media channels from the Skwibble platform, then in accordance with your social media privacy settings, the personal information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of these sites and we will have no control over such viewing and use and cannot prevent further use of such information by third parties. When you interact with Skwibble through social media networks, you acknowledge that we may access your information that is held by that account, solely in accordance with your social media privacy settings.

Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any information posted via social media through the Skwibble service, or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that information visible to third-parties who can use that information at their discretion.

Child Protection

In the interests of child protection, the Skwibble Users must be persons aged 18 or over; this does not extend to visitors or ‘Buddies’ that the User allows access to view their Child’s profile. Skwibble’s service is not intended for, nor is information knowingly gathered or solicited from, persons under the age of 18.

If we’re informed or learn that we’re in receipt of such information, or data that breaches our policies, reasonable steps will be taken to identify and delete such information from our records as quickly as possible.

Parties With Whom You May Share Your Content

Any information or content that you voluntarily disclose for posting to the Service becomes available to other members of your secure Playpen network, as controlled by any applicable privacy controls that you set. Once you have shared your content in this way, that content may be re-shared by members of your Playpen network among members of other Playpen networks to which they may belong.

We encourage you to exercise caution when deciding to disclose your personal information in chat rooms, forums, message boards, groups, and other community areas. We do not control the contents of communications made between users of the Service. Always think carefully before disclosing your information to other users or otherwise posting sensitive data on the Service. You must respect the privacy of others and you should not disclose any personal details about other people that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior permission in respect of any mention or image of them or their child where relevant.

Skwibble’s Terms and Conditions (T&Cs)

The conditions of use for Skwibble are outlined in our Terms and Conditions (T&Cs), which may be found here, in accordance with all laws applicable to our service. Using or accessing the service is deemed as an agreement, by you, to adhere to Skwibble’s conditions of service.

Opting Out

You can opt-out of having your information used for marketing by ticking the relevant boxes on our forms, or by contacting us at any time at feedback@skwibble.com. For instance, any mailing lists which you subscribe to via the Skwibble service will allow you to unsubscribe at any time.

Equally, except where communication is required with account holders to ensure operation of the Skwibble website and service, you can refuse to receive communications from the Skwibble site at any time.

Disclosing Your Information

We are allowed to disclose your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) in the following cases:

If we want to sell or buy any business, or assets, we can disclose your personal data to the potential buyer (including investors) or seller of such business or assets;

We can disclose it to any other businesses in our group;

We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights; and

We can exchange information with others to protect against fraud or credit risks.

We may also share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.

We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

Data Retention

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.

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.

Accessing data held about you

You have the right 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 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.

To enquire about processing, copies of personal data or data deletion or any other of your rights under GDPR, contact Skwibble direct at feedback@skwibble.com, specifying your enquiry in the subject line i.e. ‘I want to know if you’re processing information about me.’

For any of the enquiries above, you will be contacted by a Skwibble representative to verify your identity and to discuss your enquiry. If you’re unable to confirm your identity any requests will be rejected.

In respect of copies of data, in accordance with Information Commissioner’s Office guidelines, we may charge a reasonable fee (currently £10) to provide this information if:

The request is manifestly unfounded or excessive; or
You request further copies of your data following a request

If a fee is charged to your request this must be paid before we comply with the request.

Feedback on our Privacy Policy

It’s important to Skwibble that we earn your trust in respect of your personal information and storing your treasured content. We invite you to provide any suggestions concerning the functionality of Skwibble and the services we provide.