Privacy Policy
Data controller
Wattsenglish Ltd., a company registered at Companies House, Cardiff, United Kingdom of Great Britain and Northern Ireland, under number 5934287, having its registered office at Manchester, Oldham Enterprise House, 2 Pass Street, United Kingdom of Great Britain and Northern Ireland, OL9 6Hz, acting through Wattsenglish Ltd., Czech Republic branch, organizační složka, entered in the Commercial Register maintained by the Regional Court in Ústí nad Labem, file no. A 19013, having its registered office at Liberec 14, Ruprechtická 749/117, Postcode 460 14, Czech Republic, which as a personal data controller processes the personal data of natural persons (individuals) who download the Steve and Maggie mobile application (hereinafter referred to as the "Application") and create a user account to use the Application, hereby provides you with information on the manner and scope of the processing of your personal data and the rights you have in connection with the processing of your personal data.
1. General information
1.1 Whose personal data do we process? We process the personal data of parents or legal guardians of children who download and create their own user account in the Application (hereinafter referred to as "Parent" or "you"). We process the personal data of children only to the extent reasonably necessary to use the Application and with the consent of the Parent.
1.2 What personal data do we process? When you visit our Application, we process your personal data depending on how you communicate with us and how you use the Application. You can find more information about what personal data we process in point 2.
1.3 Do we process any sensitive personal data? Sensitive personal data or special categories of personal data may include, for example, data on racial or ethnic origin, medical condition, biometric data, or data on religion. We do not process sensitive personal data.
1.4 For what purposes do we process your personal data? We process your personal data for the purpose of using, improving, and managing the Application, protecting the Application against misuse, communicating with you and providing customer support, and in order to comply with legal regulations. We only process your personal data if we have a valid legal reason to do so. With your consent, we may process your personal data for marketing purposes. You can find more information about the purposes for which we process your personal data in point 3.
1.5 How do we ensure the security of your personal data? We have appropriate organizational and technical processes and procedures in place to protect your personal data. In cases of security breaches, we strictly follow procedures relating to personal data breaches. You can find more information about ensuring the security of your personal data in point 6.
1.6 What rights do you have? The applicable data protection laws give you certain rights in relation to your personal data. You can find more information about your rights in point 8.
1.7 How can you exercise your rights? You can contact us at wattsenglishapp@gmail.com. We will assess and handle each request in accordance with the applicable data protection regulations.
2. What personal data do we process?
2.1 The personal data we collect depends on the context of your interaction with us and with the Application and on the functions you use. The personal data we collect about Parents may include:
2.1.1 e-mail addresses and IP addresses that we obtain when you open a user account and when you use the Application,
2.1.2 the unique user ID with each user account (both paid and unpaid versions),
2.1.3 technical information, such as the type of device on which you use the Application and the operating system of that device,
2.1.4 information relating to your contractual relationship with us (such as purchase history and the technical data of a purchase),
2.1.5 names, phone numbers, or other contact data collected when you contact us with your questions or suggestions about the Application or when you use our customer support.
2.2 We process personal data that you voluntarily provide to us when registering in the Application, when participating in activities in the Application, or when contacting us. Personal data may also be transferred to the Application from a user account created by the Parent on our website https://www.wowenglish.com/ in order to pair our physical teaching/learning materials with the Application.
2.3 We automatically generate a unique user ID using Firebase Authentication. We also collect the IP address of your device through this service. If you use the "Sign in with Google/Apple" function, we receive your e-mail address from providers Google or Apple. We then obtain purchase history data from providers Google or Apple through the RevenueCat platform.
2.4 All personal data that you provide to us must be true, complete, and accurate, and you are under obligation to inform us of any changes to such personal data.
2.5 We process the personal data of children only to the extent necessary to use the Application. These are data on children's game progress and activity in the Application.
2.6 We do not collect, store, or share any tracking or advertising identifiers of children using the Application. We only use analytical functions anonymously so that we can improve the stability of the Application.
3. For what purposes and on what legal grounds do we process your personal data?
3.1 To create a user account, to use the Application, and to purchase a subscription: the legal basis for processing is the contract we have concluded with you.
3.2 To improve and manage the Application and to protect the Application from misuse: the legal basis for processing is our legitimate interest in the good functioning and security of the Application.
3.3 To communicate with Parents and to provide customer support: the legal basis for processing is the contract we have concluded with you and our legitimate interest in the good functioning of the Application.
3.4 To fulfil legal obligations: the legal basis for processing is the fulfilment of a legal obligation imposed on us by law.
3.5 For marketing purposes: the legal basis for processing is your consent.
4. Who do we share these personal data with?
4.1 We use Firebase Authentication for logging in to the Application and allowing you to use the Application, to manage user accounts, to verify your identity, and to protect your data. The Firebase Authentication Service privacy policy can be found here: https://firebase.google.com/support/privacy.
4.2 We use the RevenueCat platform to manage subscriptions for the use of the paid version of the Application and share with it your unique user ID, technical data such as the type of device from which you use the Application and its operating system, or your purchase history and technical data about payments. The RevenueCat privacy policy can be found here: https://www.revenuecat.com/privacy.
4.3 Other external parties, such as platform providers and external suppliers of technical development and Application management, may have access to personal data.
5. Children's privacy – COPPA
5.1 Because the Application is designed for children under 13 years of age, we protect children's privacy and comply with child protection laws, including the U.S. Children's Online Privacy Protection Act ("COPPA").
5.2 We collect, use, and transfer the personal data of children under the age of 13 years only in accordance with COPPA and applicable laws. Before collecting any personal data from a child under the age of 13 years, we will seek verifiable parental consent, except where COPPA permits collection without consent for limited purposes.
5.3 We collect only those data that are reasonably necessary to use the Application and we do not require more personal data of children than is reasonably necessary to use the Application. These are personal data regarding children's game progress and activity in the Application.
5.4 Parents have the right to view the personal data we have collected about their child, to request rectification or erasure of the child's personal data, to withdraw consent and to request that we stop collecting or using their child's personal data, and to refuse further collection or use of their child's personal data.
5.5 We use children's personal data solely for the purposes described in this Privacy Policy.
5.6 We may share the personal data of children only with service providers, partners, or other third parties if it is necessary for the operation of the Application, and only if these parties are under obligation to comply with corresponding confidentiality and security measures. We do not allow third parties to use children's personal data for their own purposes. See point 4 for more information.
5.7 If you have questions about children's privacy or wish to exercise your Parent's rights, you can contact us at wattsenglishapp@gmail.com.
6. Personal data security
6.1 We have taken appropriate technical and organizational security measures to prevent unauthorised access, disclosure, alteration, or unauthorised destruction of personal data. The processing of personal data is undertaken using computers and/or IT tools in accordance with organizational procedures and methods that are strictly related to the stated purposes.
6.2 We ensure the security of personal data through the Google Firebase platform. Security measures are described in the platform's privacy policy, which can be found here: https://firebase.google.com/support/privacy.
6.3 We also provide training for persons through whom we ensure the processing of personal data.
7. Retention period for personal data
7.1 We process personal data for the period for which you use the Application. After this period, we process personal data if we are obliged to do so by law or if personal data are processed to protect our legitimate interest (for example, in the event of a complaint or a dispute with a Parent). After this period, we will destroy your personal data.
7.2 You can delete your user account at any time and thus erase your personal data. Deletion can be done in the Application or here: https://mywowenglish.com. The complete erasure of all personal data may take up to 100 days due to data backups.
8. Your rights
8.1 You have the following rights in connection with the use of the Application.
8.2 Right of access to personal data: you have the right to obtain from us confirmation as to whether or not your personal data are being processed, and you have the right to access your personal data and to a copy of those data. If you request additional copies, we may charge you a reasonable administration fee.
8.3 Right to rectification: you have the right to request that we rectify or complete inaccurate or outdated personal data concerning you without undue delay.
8.4 Right to erasure of personal data: you have the right to the erasure of personal data concerning you when the personal data are no longer necessary in relation to the purposes for which they were processed, when you have objected to the processing and your interests override our legitimate interests, when the personal data have been unlawfully processed, or when their erasure is necessary for compliance with a legal obligation which we have. The right to erasure does not apply if the processing of personal data is necessary for the fulfilment of a legal obligation which we have or for the exercise and protection of our legal claims, or for other reasons specified in law.
8.5 Right to restriction of processing: you have the right to restrict processing (i) for the period necessary to verify the accuracy of the personal data, if you have contested it, (ii) if the processing of personal data is undertaken unlawfully and you request the restriction of the processing of personal data instead of their erasure, (iii) if we no longer need the personal data for the purposes of processing, but you require them for the establishment, exercise, or defence of legal claims, or (iv) for the period necessary to verify whether our legitimate reasons override your legitimate reasons in connection with an objection to processing.
8.6 Right to object: you have the right to object, at any time, on grounds relating to your particular situation, to the processing of your personal data based on our legitimate interest. In this case, we will stop processing personal data if we do not prove compelling legitimate grounds for processing that override your own interests, or if we do not prove that processing is necessary for the establishment, exercise, or defence of legal claims.
8.7 Right to withdraw consent: You can withdraw consent to the processing of personal data at any time by sending an e-mail to wattsenglishapp@gmail.com. Withdrawal of consent shall not affect the lawfulness of processing based on such consent prior to its withdrawal.
8.8 Right to lodge a complaint: if you believe that the processing of your personal data is undertaken in violation of the law, you can lodge a complaint with the supervisory authority, which in the Czech Republic is Úřad pro ochranu osobních údajů (Office for Personal Data Protection), Pplk. Sochora 27, 170 00 Praha 7; https://uoou.gov.cz. The supervisory authorities in other EU countries can be found here: EU national data protection authorities.
9. How personal data subjects can exercise their rights
9.1 You can exercise your rights and lodge your complaints at wattsenglishapp@gmail.com.
9.2 We will respond to any request you make within one month of you submitting it. This period may be extended by up to two months in exceptional cases.
9.3 All actions which we undertake in connection with the exercise of your rights are undertaken free of charge. However, if your requests are manifestly unfounded or disproportionate, we may charge a reasonable fee that takes into account our administrative costs or may refuse to comply with the request.
Prague, 15 July 2026
Wattsenglish Ltd.
via
Wattsenglish Ltd., Czech Republic branch, organizační složka