Last updated: February 2024
Noun Town Language Learning is a series of video games and applications developed by Ratcliffe & Ratcliffe Ltd (UK company number: 12748439; trading as SUPER HYPER MEGA) and henceforth referred to as Noun Town. The series includes "Noun Town: VR Language Learning'' the virtual reality version of the game, "Noun Town Language Learning'' the PC / Mac / Chromebook version, and the Noun Town mobile application. Noun Town is intended to educate and entertain.
This policy (together with our terms and conditions of use) 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 policy 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 at the bottom of this Privacy Policy.
Each resource created by Noun Town, together with the https://noun.town site, is owned and operated by Noun Town. References to the “Sites” in this Privacy Policy therefore includes all Noun Town owned websites.
IN-GAME COLLECTION OF INFORMATION (ALL USERS)
We may collect anonymized information from your play of Noun Town to improve game performance, resolve bugs, and analyze user behavior. Please note, Noun Town does not collect the player’s name, physical address, contact information, or any geolocation information. At any time a user may contact us via email (contact@noun.town) to request that any data collected or stored is deleted. Noun Town records spoken words as part of the language learning process. These recordings are held in an anonymized way, with no personally identifiable information attached to recordings. Recordings are sent to a third-party interpretation services as part of the translation process, and the privacy policies for these services can be found at these locations:
USE OF IN-GAME INFORMATION (ALL USERS)
We use the information that we collect to analyze and improve our game and support the internal operations of Noun Town. We aggregate all information collected so that it cannot be used to identify any particular player. Information we collect may be passed to selected third parties to assist with the analysis of elements of the game (including https://mixpanel.com), however, the information passed to third parties is anonymized, and at no time is any personally identifiable information transmitted to any third parties
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SECTIONS A-I BELOW RELATE TO THE ADDITIONAL COLLECTION OF INFORMATION FOR NOUN TOWN ENTERPRISE USERS
In the case of school / educational institution / corporate subscription (including on a trial basis) (“Enterprise Users”) we may collect:
School / institution / corporation name (“Enterprise”), address (for billing purposes and account name)
Teachers’ / administrators’ names, email addresses (so we can provide you with an account and contact you)
Pupils’ / end user names (to administer accounts)
SECTION A - WHAT PERSONAL INFORMATION DOES NOUN TOWN COLLECT FOR ENTERPRISES?
We may also collect details of other interactions that Enterprises and/or your Enterprise Users have with us, together with any other information that you and/or your Enterprise 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 fulfill our contractual obligations to you as it is necessary to correctly identify each registrant as a site Enterprise User, manage their account and for other purposes identified below. It is impractical in most circumstances for Enterprise 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 Enterprise Users or collect your personal information.
Please note that by registering with any of the Sites and providing the requested personal information, whether on a trial, subscription or gifted basis, the Enterprise 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 Enterprise Users (to include teachers / pupils / users). It is the Enterprise’s responsibility to ensure that they have a sufficient lawful basis for supplying all data to us. Where the lawful basis that the Enterprise is relying on is “consent”, it is the Enterprise’s responsibility to seek and confirm all necessary consents for all pupils / users (including parental consent if appropriate). If an Enterprise does not have (or in the future no longer has) a sufficient lawful basis for supplying us with such personal data, any Enterprise User to which this applies must not use the Sites, and the Enterprise must promptly inform us so any relevant data can be deleted from our Sites.
We do not however collect any unnecessary personal information from Enterprise 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. An Enterprise User (teacher, tutor, parent or guardian) must register for them (as part of an Enterprise subscription) and it is the Enterprise User teacher, tutor, parent or guardian’s responsibility to ensure that any consent to use the Sites has been collected (including on a trial basis).
SECTION B - HOW DOES NOUN TOWN COLLECT PERSONAL INFORMATION?
The personal information collected about Enterprise 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 Enterprise Users about you and/or other Enterprise Users voluntarily by filling in forms on our Sites, or by corresponding with us via phone, email or otherwise. This includes information that you provide when you register an account with us, enter a competition or survey, subscribe to marketing communications from us, 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 Enterprise Users at the point we ask you to provide such personal information.
Information that we collect automatically
When Enterprise 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 Enterprise 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 Enterprise 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 Enterprise 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 Enterprise Users.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Noun Town Cookie Policy” below. 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, subcontractors, 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
SECTION C - WHAT DOES NOUN TOWN DO WITH YOUR PERSONAL INFORMATION?
The personal information of Enterprise Users, including any prospective Enterprise 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 Enterprise User of the registration;
To administer and manage accounts, including username and password resetting, responding to enquiries raised by Enterprise Users, to contact Enterprise Users about any problems with their accounts, or the use of our products and services, or their conduct on the Sites;
To provide quotes or offers for, and updates about, our products and services;
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 Enterprise 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, Enterprise Users may opt out at any time by following the specific opt out instructions within the communications that we send, or by emailing contact@noun.town to be removed.
Please note that our Sites do not provide users with any means to communicate directly with each other. There are no chat rooms connected with our products and services.
SECTION D - 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 Enterprise Users either because it is needed to enable us to fulfill 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 Enterprise 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.
SECTION E - WHO DOES NOUN TOWN SHARE MY PERSONAL INFORMATION WITH?
We will keep personal information confidential and will not sell or knowingly divulge Enterprise 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 Policy or notified to you when we collect your personal information.
Government education departments, universities, bodies managing or representing schools, schools themselves, or other institutions / corporations 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 (nonpersonal) 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 Policy; and/or
Any other person with your consent to the disclosure.
SECTION F - HOW DOES NOUN TOWN 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 located in Europe through Hetzner, Amazon Web Services and Heroku. 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.
We use a third party Merchant of Record & payment processor, Paddle, to process credit card payments made to us and collect subscriptions. As a merchant of record you may see the Paddle name on amounts debited from your bank account / cards for remittance back to Noun Town. Noun town uses Paddle to process payments and to ensure it is compliant with all tax frameworks in which it sells software. Transactions are encrypted using SSL technology. We do not retain any credit card numbers ourselves. Paddle's use of your personal information is governed by their privacy policy, which may be viewed here.
We use a third party customer service platform, Freshdesk, to handle all customer service queries sent to us either via email or via help pop ups within our Sites. Freshdesk’s use of your personal information is governed by their privacy policy, which may be viewed here.
You and your Enterprise Users are responsible for keeping your passwords confidential. We ask Enterprise Users not to share their passwords with anyone.
Enterprise 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 Policy, and we will take appropriate actions to address breaches by employees and contractors of the obligations imposed by this Privacy Policy.
SECTION G - INTERNATIONAL DATA TRANSFERS
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. Specifically, our Sites servers are located in the US through Firebase. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.
SECTION H - DATA RETENTION
We retain personal information we collect from Enterprise 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 Enterprise User’s personal information, or where you ask us to delete Enterprise 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 Enterprise 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. It will take up to 10 days to allow for the personal information to be deleted from all our back-up systems. 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.
SECTION I - YOUR DATA PROTECTION RIGHTS
All 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 Enterprise, they can do so at any time by contacting us via email to contact@noun.town.
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 via email to contact@noun.town
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 email to contact@noun.town
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.
Enterprise 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.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
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NOUN TOWN’S COOKIE POLICY
A cookie is a little piece of information handed to a web browser from a web server that contains information that can be retrieved from the server later. When you visit the Sites the server may attach a cookie to your computer’s memory. We use cookies only to enhance the user experience. You should be able to configure your browser so that it disables cookies.
So that you can make full use of the features on our websites and our apps you will need to accept cookies. Here you can see what types of cookies may be sent and what we use cookies for. You can
find out how to reject and/or manage cookies.
We use cookies to: make our website run as expected; improve the security and speed of our website; make improvements to our website by seeing how our users navigate around it; measure and shape the success of our own marketing campaigns.
We use the following types of cookies:
Essential cookies - cookies that are essential for us to provide our services to you in a secure manner e.g. cookies that store data to allow play offline etc;
Performance cookies - cookies that understand and analyse how visitors use our online services and look for ways to improve them;
Functionality cookies - cookies that remember your preferences and tailor the website to provide enhanced features e.g. recognising your Enterprise when you log in again;
Marketing cookies – cookies that help us measure the success of our own marketing campaigns by tracking trends, conversions, ad optimisation and retargeting.
If your browser is set to accept cookies, we take this, and your continued use of our site as acceptance of our cookie policy. If you would like to reject the use of cookies you can find out how below. Please bear in mind that some features on our website might not work correctly with cookies disabled.
To help us better understand your needs, we also use analytical software – Google Analytics and Meta Pixel. This software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the Sites, but will not store, save or collect personal information.
You can read Google’s privacy policy here regarding use of cookies.
You can read Meta Pixel’s privacy policy here regarding use of cookies.
If you want to, you can reject cookies from all sites or from a particular site. You can do this by navigating to the ‘preferences’ or ‘tools’ menu of your browser. Please note, as cookies are a standard part of most websites, if you prevent your browser from accepting cookies, this will probably limit the functionality of the site.
CHANGES TO THIS PRIVACY POLICY
We may revise this Privacy Policy, for example, to reflect changes in the law, our practices, or the features of Noun Town. These changes will be effective immediately upon posting. As a result, you should periodically review the Privacy Policy so that you are up to date on our most current policies and practices. By playing Noun Town, you agree to the terms and conditions of this Privacy Policy, and, by continuing to play Noun Town after changes have been made, you agree to the changes.
STILL HAVE QUESTIONS?
If you have any questions or concerns regarding this policy, please email us at contact@noun.town
