Privacy policy
Version 1.3 · Valid from
1. Who we are
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1.1
Wise Cow provides online mathematics learning and practice. Wise Cow is the data controller: we decide why and how the personal data described in this policy is used.
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1.2
This policy covers learners, purchasers and people who browse our website or contact us. Contact us about your data at hello@wisecow.co.uk.
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1.3
This policy explains our data use. It is not a request for consent to all processing; optional usage analytics has its own choice.
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1.4
Our postal contact address is Wise Cow, 3F1 Third floor, 3 Hill Street, Edinburgh, EH2 3JP.
2. The information we collect
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2.1
Account information: your email address, password in protected form, security settings and profile details you choose to provide. We also record your current privacy choices and when your analytics choice was last changed.
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2.2
Learning information: course access, progress, bookmarks, activity and study time, assigned work and any class membership or join requests, submitted answers, handwriting or answer images, text transcriptions, marks, feedback and reviewed results.
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2.3
Payment information: purchases, trials, subscription status, payment references, the adult purchaser’s declaration and its date and applicable terms version, and billing details supplied to us by our payment processor. Full payment-card numbers are handled by the payment processor rather than stored by Wise Cow.
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2.4
Support information: the name, email address, message and other information you send when you contact us, whether or not you have an account.
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2.5
Technical information: IP addresses, browser and device details, sign-in and security events, and records of errors, requests and performance needed to operate and protect the website. Security checks also exchange challenge information with an abuse-prevention provider.
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2.6
We receive information directly from you, automatically through your use of the service, and from providers handling payments, email delivery and security checks. Optional Google Analytics is explained separately below.
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2.7
An email address and password are required to create an account. Answers are needed to provide marking, and payment details are needed for a paid purchase. If you do not provide the necessary information, we cannot provide that part of the service. Other profile details and analytics permission are voluntary.
3. Why we use your information
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3.1
To create and manage your account, supply purchased access, save your work, provide learning activities and marking, and send necessary account or billing messages, we rely on performance of our contract with you or steps you ask us to take before entering it.
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3.2
Where an adult purchases access for a learner who is not the contracting customer, we use the learner’s necessary account and learning information for our legitimate interest in providing the learning service requested for them, subject to their rights and best interests.
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3.3
To prevent misuse, secure accounts, investigate faults, measure service reliability and answer enquiries, we rely on our legitimate interests in running a safe and reliable service and helping people who contact us. Operational error and performance records are separate from optional usage analytics.
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3.4
To review marking quality and test improvements using answer transcriptions as described below, we rely on our legitimate interest in improving the accuracy and reliability of learning feedback. This does not give us unrestricted permission to reuse your work.
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3.5
Legitimate interests means a necessary and proportionate use for an identified purpose. Your rights and interests, especially those of children, must not be overridden. You can object to these uses as explained in section 10.
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3.6
To meet tax, accounting and other legal duties, and respond to legally binding requests, we rely on compliance with a legal obligation. Handling payment disputes and establishing or defending legal claims may also involve our legitimate interests.
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3.7
Optional usage analytics relies on your consent. Agreeing to our terms or buying access does not give analytics permission.
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3.8
If you opt in to study tips, marketing updates or survey invitations, we use your email address and the relevant preference to send those messages on the basis of consent. Turn them off in Settings → Notifications or contact us; marketing and survey emails also contain unsubscribe links. Necessary account and billing messages continue while needed to provide the service.
4. Automatic marking and review
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4.1
When you request automatic marking, your answer text or images, the relevant question and marking instructions are sent to a third-party marking provider. It transcribes the answer where needed and compares it with the marking scheme to produce marks and feedback.
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4.2
We may review your work to help you, investigate errors and check marking quality. Automatic marking can make mistakes; contact us to ask us to review a result.
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4.3
We may use text transcriptions of your submitted answers to test and improve the accuracy of automatic marking in a restricted testing environment that students cannot access.
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4.4
For this testing, we import the saved transcription and question and source references. We do not import your original handwriting, answer images or pen strokes, or your name, email address or other student account details. The transcription may be sent to a third-party marking provider again during testing.
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4.5
A transcription can still contain personal information if you wrote it in your answer, and source references may allow us to link it to the original work. These copies are not treated as anonymous merely because account details are excluded.
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4.6
We do not intentionally include your account name or email in marking instructions. Please avoid including personal or sensitive information in answers unless it is needed to deal with a support request.
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4.7
Marks and progress summaries provide learning feedback. They do not award an official qualification or decide admission to a school, examination or course. We do not use them to make decisions about you with legal or similarly significant effects.
5. Cookies and information on your device
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5.1
Sign-in and security: we use session cookies (including wisecow_session and related session cookies), XSRF-TOKEN to protect form submissions, and a remember-me cookie if you request persistent sign-in. Session expiry depends on whether you ask to stay signed in. Security checks may use __cf_bm, which expires after 30 minutes of inactivity, and cf_clearance to remember a successful browser check. Their duration depends on the security configuration and may be up to one year. These technologies are used to provide and protect the service, not for optional usage analytics.
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5.2
Your work and service operation: local storage holds unsubmitted answer drafts and lesson-practice answers so that you can recover or continue your work. Browser storage also supports learning timers, pending marking, secure account changes, coordinating open tabs and detecting technical faults. Session storage normally ends when the tab is closed. Local drafts and other local learning state can remain until submitted, replaced, expired or cleared through the website or browser. Clearing site data may remove work that has not been submitted.
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5.3
Your interface preferences: when signed in, sidebar and lesson-panel states, Desk layout and grid choices, whiteboard appearance and tool defaults, answer-entry method, task-list choices and dismissed notices are saved to your account on our servers. Rejecting optional browser storage does not disable these account settings. Recently edited preferences are retained within a bounded account record. Signed-out presentation choices are kept in page memory rather than optional local storage.
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5.4
Time zone: UK time is the default for new accounts. If you select Auto in Settings, we ask you to enable browser preferences before detecting your device’s time zone. We store that zone in wc_browser_timezone for up to one year and your browser permission in wc_browser_preferences for one year. These cookies apply to the browser, not every device on your account. Choose UK in Settings to stop device detection and clear the time-zone cookie. Existing Auto settings use UK time when browser permission is absent or withdrawn. Essential storage and saved work continue.
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5.5
Older browsers may still hold local presentation preferences. Where browser preferences are allowed, we can import recognised preferences into the signed-in account when used. An existing browser objection prevents those reads and clears recognised old preference keys where browser access is available; drafts and essential state are preserved.
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5.6
Optional Google Analytics stays off unless you separately opt in. wc_analytics_permission remembers your browser permission for 180 days; the account choice is also checked. Google Analytics cookies (_ga and ga...) last up to 180 days and may be refreshed during use. Enabling automatic time-zone detection does not grant analytics permission. The next section explains collection and withdrawal.
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5.7
Other people using the same browser may be able to see locally saved work. Sign out and take care when using a shared device. Payment services may use security and payment cookies when you choose checkout or billing; our marking and email providers process service data on our servers rather than installing advertising trackers in your browser.
6. Optional usage analytics
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6.1
If you enable Allow analytics, we use Google Analytics to understand visits to broad areas of Wise Cow and improve the website. Google receives cookie identifiers, page categories, timestamps and browser and device information. Your browser also sends its IP address when connecting to Google. Read How Google uses data for more information.
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6.2
We do not send your account ID, name, email, answers, handwriting, actual page paths or actual page titles as analytics events. We send broad page categories instead. Advertising features and Google Signals are disabled by the application.
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6.3
Analytics is off unless you opt in, and your choice does not affect course access. You can withdraw permission in Account → Privacy. A new browser needs its own opt-in.
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6.4
Withdrawal stops further collection in the current browser and clears its analytics cookies. Other open pages recheck your saved choice while visible. It does not automatically erase information already collected or affect processing that was lawful before withdrawal.
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6.5
Google may process information outside the UK or EEA. Our Google Analytics properties are configured to retain event data for two months; aggregate reports may be kept longer. Cookie expiry is separate from the retention of information already received by Google.
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6.6
Contact us for help with analytics access or deletion requests. We do not connect analytics browser identifiers to your account, so we may need further information to locate the relevant records.
7. Who receives your information
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7.1
We use third-party providers for hosting and databases, file storage and recovery, automatic marking, payment processing, email delivery and security checks. Each receives the information needed for its service. Google Analytics receives the information described above only with your permission.
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7.2
Providers processing data on our behalf must follow our instructions and protect it under appropriate contractual terms. Payment and security providers may also process certain information for their own legal or fraud-prevention responsibilities, under their own privacy notices.
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7.3
People authorised to support and operate Wise Cow may access relevant records to help you, investigate problems and review marking. Your submitted work is not published for other learners to browse.
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7.4
We may share relevant information with professional advisers or public authorities where necessary to meet legal duties or establish, exercise or defend legal claims. Any disclosure must have a lawful basis and be limited to what is needed.
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7.5
We do not sell your personal data. If the business transfers to a new operator, we will explain any change of controller and how it affects your information before the change takes effect, where required.
8. Storage, overseas processing and security
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8.1
Our production application and database are hosted in the United Kingdom. The storage buckets Wise Cow uses for uploaded files and recovery archives are located within the European Economic Area (EEA). The EEA comprises the European Union, Iceland, Liechtenstein and Norway.
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8.2
Some processing, including automatic marking of answers and email delivery, may take place outside the UK or EEA. Our production database and these storage buckets remain within the UK or EEA; third-party processing may involve separate copies stored elsewhere.
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8.3
UK data-protection law requires a permitted basis for restricted international transfers. This may be UK adequacy regulations, recognising a destination’s protection, or appropriate contractual safeguards such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, with any required assessment and additional protections. You can request details of the arrangements relevant to your data and a copy of applicable safeguards.
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8.4
We use access controls and technical protections to reduce the risk of unauthorised access, loss or misuse. No online service can promise absolute security. If a personal-data breach requires notification, we will notify the regulator and affected people as the law requires.
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8.5
We keep recovery copies to help restore the service after loss or damage. Separate recovery archives containing account data are encrypted before upload and stored privately.
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8.6
Deleted information may remain in recovery copies until they expire or are replaced. Such copies are kept for recovery, not ordinary use. Completed deletions must be reapplied before restored data is brought back into live use.
9. How long we keep information
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9.1
We keep account and learning records while your account is in use and the records are needed to supply the service, preserve your work or resolve an outstanding request. If an account becomes inactive, we may email a warning with a deletion deadline. Signing in before that deadline stops the inactivity process; accounts with current paid access are excluded.
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9.2
To delete your account, open Account → Data → Delete your account and choose Delete account. Complete the password and, where enabled, two-factor checks and confirmation. Access closes immediately. The normal process allows 14 days to recover the account before erasure becomes due in a scheduled run.
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9.3
You can request earlier erasure or deletion of particular data without closing your account by emailing hello@wisecow.co.uk. The recovery period does not replace your legal rights or the deadlines for responding to a request.
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9.4
Account-data download archives are available for 24 hours after release, then expire. Delete archive in Account → Data removes that download copy; it does not delete your account or original learning records.
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9.5
For support correspondence, we consider whether the enquiry is resolved, whether follow-up is reasonably likely and whether a complaint or claim remains open. For security and diagnostic records, we consider the investigation, incident risk and the time needed to establish that a fault has been resolved.
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9.6
For billing and financial records, we consider applicable tax and accounting duties, refunds, payment disputes and legal limitation periods. We retain only the information needed for those purposes, which may continue after account deletion.
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9.7
Identifiable testing transcriptions are retained only while needed to investigate marking problems or evaluate relevant improvements. Deletion requests require review of separate testing copies and exports as well as the live account; deleting the account does not automatically remove every separate copy.
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9.8
Minimal records of deletion requests and their completion may remain while needed to honour your request, prevent deleted data being restored or handle delayed payment events. Recovery and provider copies have separate expiry and replacement arrangements. We must remove data when no longer needed, or put retained recovery copies beyond ordinary use; we do not claim that every copy disappears immediately.
10. Your choices and data-protection rights
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10.1
For a convenient copy of account and learning records, open Account → Data → Download your data and choose Prepare download. Complete the security checks. We email you when it is ready; preparation usually takes up to a day. Return and choose Download within the availability period shown. You can also request other personal data, including relevant support records, directly from us.
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10.2
You can update profile details in Account → Profile and withdraw analytics permission in Account → Privacy. You do not have to sign in or use a particular form to exercise your rights: contact hello@wisecow.co.uk.
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10.3
Under the UK GDPR and the Data Protection Act 2018, you can request access to your personal data and correction of inaccurate or incomplete information. In the circumstances set by law, you can request erasure (the right to be forgotten) or restriction of processing, and receive data you provided in a portable format where processing is automated and based on consent or a contract.
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10.4
Your right to object: you can object to processing based on legitimate interests, including use of identifiable answer transcriptions for marking-quality testing, for reasons relating to your situation. We must stop unless we can demonstrate compelling lawful grounds that override your interests and rights, or the processing is needed for legal claims. Any objection to direct marketing must be honoured.
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10.5
Where processing relies on consent, you can withdraw it at any time. Rights have legal limits; for example, information may need to be kept to comply with a legal duty or defend a claim. If we cannot fulfil a request, we will explain why and how you can challenge the decision.
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10.6
We normally respond without charge and within one month. If we reasonably need information to verify your identity or clarify an access request, we will explain this. Complex or multiple requests may allow up to two further months; we will tell you within the initial period and explain the reason. Any fee or refusal must be permitted by law.
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10.7
You can raise a privacy concern with us or complain directly to the Information Commissioner’s Office (ICO): Make a complaint to the ICO. You do not have to complain to us first, and this does not affect your right to seek a remedy through the courts.
11. Young learners
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11.1
Wise Cow accounts are for learners aged 13 or over. We ask you to confirm that you meet this minimum age when registering. We do not request a date of birth for this declaration.
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11.2
If you are aged 13 to 17, an adult must arrange and authorise any paid plan or trial for you. The purchaser must confirm that they are aged 18 or over and authorised to make the purchase. This confirmation is separate from your analytics and email choices.
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11.3
We give particular weight to children’s privacy and best interests, including learners aged 13 to 17. Ask us or a trusted adult if anything about our information use is unclear.
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11.4
A parent or guardian can help with a privacy request. A learner’s information is not automatically available to someone because they pay for access: we consider the learner’s rights, understanding and the person’s authority before sharing it.
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11.5
If you believe a child under 13 has created an account, contact hello@wisecow.co.uk so we can investigate and arrange appropriate closure or removal of their information. We do not offer under-13 accounts through parental consent.
12. Changes to this policy
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12.1
We will explain material changes to how we use your information before they take effect and seek fresh consent where required. A new policy does not by itself authorise a new use of your data.
Wise Cow