What personal information do we collect from the people that visit our website?
When registering a new member account, we ask for the name and age of the student who will be using the site, we also require the details of a legal guardian who has consented to the student using Think Big Coding and all of its features (Parents consent). These details include name, address, email address, school name (if required), billing information and contact information. The information is used for verification and to ensure all required features are available to the user. When purchasing a subscription, we securely ask for (but do not store on our servers) your credit card information.
When do we collect information?
We collect information from you when you register on our site, place an order, fill out a form, or enter information on our site.
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to an email, use the portal, or use certain other site features in the following ways:
- To personalise your experience.
- To improve our website.
- To respond to your customer service requests.
- To send periodic emails about Think Big Coding features and services (optional).
- To contact you about your interest in Think Big Coding for a school.
- To assist with third party licensing. (third party licenses and add on subscriptions are covered by the third parties company policies and Think Big Coding holds no responsibility over their company conduct).
- To quickly process your transactions.
How do we protect visitor information?
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. All financial transactions are processed through a secure gateway provider (Stripe), with no sensitive financial information stored or processed on our servers.
Think Big Coding takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of your personal information. These measures include but are not limited to SSL, strong encryption, de-identification, pseudonymization, limited access controls, regular testing, and minimal data collection and data retention.
Do we use ‘cookies’?
- Understand and save your preferences for future visits.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If users disable cookies in their browser:
If you disable cookies, it will turn off some of the features that make your site experience more efficient and some of our services will not function properly.
Third Party Disclosure
We work with selected third parties and will only share your data when purchasing as a reseller for a carefully selected Third Parties at your request for their service. We do not sell or trade to outside parties your personally identifiable information, and do not otherwise transfer it except as described in this privacy notice. Third Party Suppliers who may require user data for monitoring, processing and communication purposes are (Code Combat & Scratch). Their privacy policies are listed on their own website’s and are also where possible covered in this document. Think Big Coding will use due care and attention when using Third Parties, Think Big Coding cannot be held liable in anyway to any indifferences applied in law with the misrepresentation of data held by a Third Party.
How does our site handle not track signals?
We avoid tracking as many non-required analytics and cookies as possible, but cannot guarantee 100% coverage.
Does our site allow third party behavioural tracking?
Yes, for example, via Google Analytics. Please see Third party policies for applications sold via Think Big Web
Think Big Coding takes the protection of childrens’ data and their safeguarding very seriously compliant with GDPR, meeting, among others, these requirements. We:
- do not use any data collected via the service to target ads to students;
- do not create advertising profiles on students;
- do not sell student information;
- do not disclose personal information, unless required by law or as part of the maintenance and development of the service;
- do use sound information security, including encryption of data and other industry-standard practices;
- will delete data that we have collected from students in a school when the school or authorities requests it;
- share information only with educational researchers or with educational agencies performing a function for the school with permission from the school and or legal guardians,;
- innovate safely without compromising student privacy by only using de-identified and aggregated data to develop and improve the service for example student accounts with Scratch, Python, CodeCombat and other tools that may require a logon account..
Think Big Coding uses best practice for the protection of pupil data linked to third party accounts. Pupil details are kept by Think Big Coding for registration and linking to educational accounts on the learning portal and with third party programs. Accounts are also linked to a pupil for safeguarding, billing and reporting.
For Coding Clubs provided by a school, pupil records continue to be the property of and under the control of the local educational agency. For activities and membership provided by Think Big Coding, control of data is handled by Think Big Coding. Pupils may retain possession and control of their own pupil-generated content by editing or deleting their content from our servers themselves via the website or by emailing email@example.com. Pupils may also request to transfer their pupil-generated content to a personal account, with permission from their legal guardians. Third parties will not have access to any personally identifiable information in the pupil record for any purpose. Parents, legal guardians, and eligible pupils may review their information and request corrections to erroneous information through account settings on our website or by emailing firstname.lastname@example.org.
We will not require a child to disclose more information than is reasonably necessary to participate in our service.
Teachers and legal guardian can agree to the collection and use of their students’ information, but still not allow disclosure to third parties.
Teachers and legal guardians can review, delete, and manage their students’ information through account settings on our website or by emailing email@example.com.
We follow similar children’s privacy laws applying to children under the age of 18 to coincide with laws in other countries, we follow similar consent and information security policies to protect the personal data of children.
Fair Information Practices
The Fair Information Practices Principles form represent privacy law in line with GDPR and privacy laws governed by other countries. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices, should a data breach occur, we will notify the affected users via email within 7 business days (or within 72 hours for certain categories of breach).
CAN-SPAM Act USA
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Authenticate your user account.
- Send information, respond to inquiries, and/or other requests or questions.
- Process orders and to send information and updates pertaining to orders
- We may also send you additional information related to your product and/or service (optional).
- To be in accordance with CAN-SPAM we agree to the following:
- NOT use false, or misleading subjects or email addresses
- Identify the message as an advertisement in some reasonable way
- Include the physical address of our business or site headquarters
- Monitor third party email marketing services for compliance, if used
- opt-out/unsubscribe requests quickly
- Allow users to unsubscribe by using the link at the bottom of each email
If at any time you would like to unsubscribe from receiving future emails, you can change your email settings in your account preferences, email us, or follow the instructions at the bottom of each email, and we will promptly remove you from all correspondence.
General Data Protection Regulation (GDPR) for EU users
GDPR is a Regulation by which the European Commission intends to strengthen and unify data protection for individuals within the European Union. For users within the EU, we comply with GDPR and the Privacy by Design principles that guide it, including minimal collection of personal data, deletion of personal data that are no longer necessary, securely restricted access to personal data, privacy as the default, and visibility and transparency.
Legal basis of processing
Think Big Coding may process personal data relating to EU users if one of the following applies:
- EU users have given their consent for one or more specific purposes.
- provision of personal data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which Think Big Coding is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Think Big Coding;
- processing is necessary for the purposes of the legitimate interests pursued by Think Big Coding or by a third party.
In any case, Think Big Coding will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Third Party Place of processing
EU users’ personal data via third party providers are processed on US-based servers and at offices in other countyries. This necessitates a cross-border data transfer to the United States, a country whose privacy laws the EU does not consider as providing adequate data safeguards. As some of the Third Party services we resell do not yet have the Privacy Shield certification necessary to ensure adequacy, EU users may either explicitly consent to such a transfer or refrain from granting Think Big Coding Third Parties consent while creating a Third Party account. At any time, this consent may be withdrawn by deleting your Third Party account or contacting the third party provider directly to request deletion. All of the data processors that might receive personal data do have adequate data protection safeguards in place, such as Privacy Shield certification or EU-approved standard contractual clauses.
Data retention time limits
Personal data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
Personal data collected for purposes related to the performance of a contract between a non EU third party EU provider and an EU user shall be retained until such contract has been fully performed and the user has determined that no further contract will be needed.
Personal data collected for the purposes of a third parties legitimate interests shall be retained as long as needed to fulfil such purposes. EU users may find specific information regarding the legitimate interests pursued by a third party within the relevant sections of this document or by contacting the third party directly.
Third Party suppliers may be allowed to retain personal data for a longer period whenever an EU user has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Third Party Suppliers may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
More specifically, Third Party suppliers may retain server log files for no more than 30 days, and will retain inactive, unpaid EU user accounts for no more than 2 years.
Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Detailed information on the processing of personal data
Third Party suppliers are assisted by the following GDPR-compliant data processors and data controllers, some of which will be disabled by setting the Do Not Track option in your browser or, in the EU, opting out of cookies:
|Data Processor||User types||Data||Purpose||Safeguards|
Usage data is defined as information collected automatically through Think Big Coding (or third-party services employed by Think Big Coding), which can include: the IP addresses or domain names of the computers utilised by the users who use Think Big Coding and Third Parties , the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by a user, the various time details per visit (e.g., the time spent on each page within Think Big Coding or Third Party) and the details about the path followed within Think Big Coding and Third Party platform with special reference to the sequence of pages visited, and other parameters about the device operating system and/or a user’s IT environment.
In addition to the data processed by our Suppliers , Think Big Coding and Third Party Suppliers also directly processes the following categories of personal data for all users:
|Name||To personalise your experience, communicate with you, and fulfil any purchases||Legitimate interest|
|Username||To authenticate you and to identify you across platforms||Legitimate interest|
|Email address||To authenticate you, communicate with you, and fulfil any purchases||Legitimate interest|
|Telephone number||If optionally provided when requesting licenses or a quote, to contact you regarding your purchase interest||Legitimate interest|
|Pre-purchase information||To provide quotes, proposals, and pricing information for Think Big Coding and Third Party licenses prior to a purchase||Performance of a contract|
|Think Big Coding and Third Party purchase history||To provide paid licenses or subscriptions after a purchase||Performance of a contract|
|Year and month of birth (without specific day)||To ensure we are complying with regulations, to personalize your learning experience, and to understand our users||Legal necessity, legitimate interest|
|Country and region location information (without specific address or fine-grained location)||To ensure we are complying with regulations, to personalize your learning experience, and to understand our users||Legitimate interest|
|IP addresses||To serve web requests and initially identify the country of origin, after which the IP not stored associated with the user||Legitimate interest|
|Essential cookies||To provide authentication and ensure functionality of the site||Legitimate interest|
|Optional cookies||To enable services from our data processor partners, including understanding usage patterns and providing additional functionality||Consent|
|Web and email usage data||To understand usage patterns and improve our products, services, and communications||Legitimate interest|
|Google or Facebook identifiers||To provide the option to use Google or Facebook authentication||Legitimate interest|
|GitHub username||To allow you to sign our Contributor License Agreement and make open-source contributions||Performance of a contract|
|Password hash||To authenticate you, we store securely hashed passwords–to protect you, Think Big Coding and Third Parties do not store your original password||Legitimate interest|
|Think Big Coding and Third Party data you create by using the product||To remember your progress through the game, save the code you write, allow you to create classrooms, etc.||Legitimate interest|
The rights of EU users
EU users may exercise certain rights regarding their personal data processed by Think Big Coding and Third Party providers used by Think Big Coding. In particular, EU users have the right to do the following:
Withdraw their consent at any time. EU users have the right to withdraw consent where they have previously given their consent to the processing of their personal data.
Object to processing of their personal data. EU users have the right to object to the processing of their personal data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their personal data. EU users have the right to learn if personal data are being processed by Think Big Coding or a Third Party Supplier, obtain disclosure regarding certain aspects of the processing and obtain a copy of the personal data undergoing processing.
Verify and seek rectification. EU users have the right to verify the accuracy of their personal data and ask for data to be updated or corrected.
Restrict the processing of their personal data. EU users have the right, under certain circumstances, to restrict the processing of their personal data. In this case, Think Big Coding and Third Party suppliers used by us will not process their personal data for any purpose other than storage.
Have their personal data deleted or otherwise removed. EU users have the right, under certain circumstances, to obtain the erasure of their personal data from Think Big Coding.
Receive their personal data and have data transferred to another controller. EU users have the right to receive their personal data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the personal data are processed by automated means and that the processing is based on an EU user’s consent, on a contract which an EU user is part of or on pre-contractual obligations thereof.
Lodge a complaint. EU users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where personal data are processed for a public interest, in the exercise of an official authority vested in Think Big Coding or for the purposes of the legitimate interests pursued by Think Big Coding, EU users may object to such processing by providing a ground related to their particular situation to justify the objection. EU users should know that, however, should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.
How to exercise these rights
Any requests to exercise user rights can be directed to Think Big Coding through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Think Big Coding as early as possible and always within one month. For the right to deletion, users can also simply use the Delete Account functionality in their account settings. Various consents can also be withdrawn in the account settings.
Applicability of broader protection standards
While most provisions of this document concern all users, some GDPR-specific provisions expressly only apply to users located within the EU. We are happy to provide many of these rights to all users when appropriate.
- Think Big Coding Ltd.
- 1 Northwood Rd, Ramsgate CT12 6RR, Kent, England, UK
Last Edited on 13.11.2019