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TempoReading Privacy Policy

 

Last Updated: June 30, 2025

 

1. Introduction

 

Tempo Reading Global Limited ("we," "us," or "our") operates the TempoReading application and website (collectively, the "Service"). We are committed to protecting the privacy of all our users, especially children. This Privacy Policy explains how we collect, use, store, and share information through our Service.

By using TempoReading, you agree to the collection and use of information in accordance with this Privacy Policy. This Policy should be read in conjunction with our Terms and Conditions, which outline the rules for using our Service.

Our Commitment to Children's Privacy: TempoReading is designed with the safety and privacy of children as our absolute highest priority. We comply with all applicable data protection laws, including the UK GDPR, EU GDPR, the Children's Online Privacy Protection Act (COPPA) in the US, the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, the Privacy Act 1988 in Australia, and other relevant jurisdictional requirements globally.

 

2. Who We Are and How to Contact Us

 

Tempo Reading Global Limited is a company registered in England and Wales under company number 14582726, with our registered office at 20-22 Wenlock Road, London, England, N1 7GU, UK.

For general privacy inquiries, please contact us at:

Email: connect@temporeading.com

For specific data protection inquiries, or to exercise your rights, please contact our Data Protection Officer (DPO):

DPO: Christopher Wilson

Email: connect@temporeading.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.1

 

 

3. The Information We Collect

 

We only collect information that is strictly necessary to provide and improve the TempoReading Service and to help users, especially children, improve their reading skills.

 

3.1 Personal Data You Provide Directly to Us

 

• Account Information: When you create an account, we may collect your name (or a pseudonym), email address, age/date of birth, and role (e.g., student, parent, teacher). For school or institutional accounts, we may also collect school name and class details.

• Profile Information: Any additional information you choose to add to your profile, such as a profile picture or preferred reading level.

• Communications: Information you provide when you contact us for support, send feedback, or participate in surveys.

 

3.2 Information We Collect Automatically (Usage Data)

 

When you use our Service, we automatically collect certain information to understand how the app is being used and to enhance the learning experience. This includes:

• Reading Progress Data: This is core to our Service and includes data on reading speed, comprehension scores, completed exercises, and learning achievements.

• App Usage Details: Information about how you interact with the Service, such as features accessed, content viewed, time spent in the app, and navigation paths.

• Device Information: Information about the device you use to access the Service, including IP address, operating system, browser type, device type, and unique device identifiers.

• Eye Movement Patterns (NOT Biometric Data): Our technology analyzes eye movement patterns solely to help with reading focus and fluency. This data allows the app to adapt the text display (e.g., flow-state text reveal) and provides insights into reading challenges to inform personalized learning paths. This is NOT biometric data that can be used to identify your child personally. It is a technical measure to enhance the reading experience, not for identification or surveillance.

Crucial Child Safety Promise: We unequivocally DO NOT collect any biometric data that could identify your child, such as facial recognition, fingerprints, retina scans, or any other unique biological identifiers. Our eye movement analysis is a technical measure to assist reading, not a tool for identification or surveillance.

 

3.3 Information We Do NOT Collect

 

• We do not collect sensitive categories of personal data (e.g., health data, racial or ethnic origin, political opinions, religious beliefs) beyond what is necessary for the core educational purpose of the app and explicitly disclosed (e.g., if you choose to include a disability for neurodiverse learning features, this would be based on your explicit consent).

• We do not use third-party advertising trackers within the Service that could collect information about children.

 

4. How We Use Your Information and Our Lawful Basis for Processing

 

We use the information we collect for the following purposes and rely on specific lawful bases under UK GDPR for this processing:

 

4.1 For Individual/Family Accounts (Direct-to-Consumer)

 

When you use TempoReading directly as an individual or family, Tempo Reading Global Limited acts as the Data Controller.

• To Provide and Maintain the Service (Contractual Necessity): We use your information to operate the Service, deliver personalised reading experiences, track progress, provide educational content, and respond to your requests.

• To Improve and Develop the Service (Legitimate Interests): We analyse usage data (including aggregated and anonymised eye movement patterns) to understand how our Service is used, identify areas for improvement, troubleshoot issues, and develop new features. Our legitimate interests are to provide a high-quality, effective, and user-friendly educational tool, and we balance these interests against the privacy rights of our users, particularly children.

• To Personalise Your Experience (Contractual Necessity / Legitimate Interests): We use reading progress and usage data to tailor the content and features to individual learning needs.

• To Communicate with You (Contractual Necessity / Legitimate Interests / Consent): We may send you service-related announcements, updates, and support messages. We may also send marketing communications where we have your consent or a legitimate interest (e.g., informing you about new features relevant to your use). You can opt-out of marketing communications at any time.

• To Ensure Security and Compliance (Legal Obligation / Legitimate Interests): We process data to ensure the security of our Service, prevent fraud, and comply with legal obligations (e.g., responding to lawful requests from authorities).

• For Users Under 13 (Consent): For individual/family accounts where the user is under 13, we obtain verifiable parental consent before collecting personal information. This consent also serves as our lawful basis for processing the child's data for the purposes outlined above.

 

4.2 For School and Educational Institution Accounts

 

When TempoReading is used by a school or educational institution as part of their educational provision, Tempo Reading Global Limited primarily acts as a Data Processor on behalf of the school (the Data Controller).

• Processing on School's Instructions (Contractual Necessity for the School's Public Task): We process student data strictly on the instructions of the school to facilitate their educational functions and public tasks, providing the agreed-upon Service (e.g., personalised learning, progress tracking for teachers).

• School's Lawful Basis: The school, as the Data Controller, is responsible for determining the lawful basis for processing student data (e.g., public task under education law or legitimate interests) and for providing the necessary privacy information to parents and students through their own privacy notices.

• No Independent Commercial Use of School Data: We do not use student data collected via school accounts for any independent commercial purposes, product development not directly related to the service provided to the school, or marketing to students. Our use of such data is strictly confined to delivering and maintaining the educational service for the school.

• Data Processing Agreements (DPAs): Our agreements with schools include robust Data Processing Agreements that detail our responsibilities as a processor under UK GDPR and other applicable laws, ensuring appropriate safeguards for student data.

 

5. How We Share Information

 

We never share, sell, rent, or give away any user's personal information to any third parties, advertisers, or other companies for their own independent commercial purposes. Your data stays with us and is used exclusively to provide and improve the TempoReading Service.

We may share information in the following limited circumstances:

• With Educational Institutions (for School Accounts): Student progress and usage data is accessible by authorized teachers and administrators within the relevant school or educational institution to support teaching and learning.

• With Parents/Guardians (for Linked Accounts): Parents/guardians with linked accounts can view their child's progress and usage data as described in the Service.

• With Our Service Providers: We may use trusted third-party service providers to help us operate, provide, and improve the Service (e.g., cloud hosting, analytics tools for aggregated data, customer support platforms). These providers are bound by strict contractual obligations to keep data confidential and to use it only for the purposes for which we disclose it to them. They are not permitted to use data for their own commercial purposes.

• For Legal Reasons: We may disclose information if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency request).

• In Case of Business Transfer: If we are involved in a merger, acquisition, or sale of assets, your personal information may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

• Aggregated or Anonymised Data: We may share aggregated or anonymised data that cannot be linked back to individual users. For example, we might share general trends about reading progress across all users with researchers or the public.

 

6. International Data Transfers

 

As an international service, your data may be transferred to, and stored at, a destination outside the UK or European Economic Area (EEA).

• For transfers to countries not deemed to provide an adequate level of data protection by the UK government or European Commission, we implement appropriate safeguards such as Standard Contractual Clauses (SCCs) to ensure your personal data is protected to the same standard as within the UK/EEA.

• For US users, our compliance with COPPA and FERPA (where applicable for school use) ensures appropriate protections for data transferred to our servers in the UK or other locations.

 

7. Data Security

 

We are committed to protecting the security of your personal data. We implement robust, industry-standard technical and organisational measures to protect against unauthorised access, alteration, disclosure, or destruction of your information. These measures include:

• Encryption: Data is encrypted both in transit (using SSL/TLS) and at rest (using industry-standard encryption protocols).

• Access Controls: Strict internal policies and procedures limit access to personal data to authorised personnel only, on a "need-to-know" basis.

• Regular Audits & DPIAs: We conduct regular security audits, vulnerability assessments, and Data Protection Impact Assessments (DPIAs) to identify and mitigate risks, embedding 'privacy by design and default' into our service development.

• Physical Security: Our data centres employ physical security measures to protect against unauthorised access.

• Employee Training: Our staff receive regular training on data protection and privacy best practices.

 

8. Data Retention

 

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, to provide the Service, or as required by applicable legal, accounting, or reporting requirements.

• Active Accounts: We keep your data as long as your account is active to provide ongoing Service and progress tracking.

• Inactive Accounts (Direct-to-Consumer): For individual/family accounts, we may implement a policy to delete accounts and associated data after a reasonable period of continuous inactivity (e.g., 24 months), with prior notification to the user or parent.

• Account Deletion Requests: When you or your parent/guardian requests account deletion, we will permanently remove all associated personal data promptly, unless retention is legally required (e.g., for financial records).

• Aggregated/Anonymised Data: We may retain aggregated or anonymised data indefinitely for analytical and service improvement purposes, as this data can no longer identify individuals.

 

9. Your Data Protection Rights

 

Under UK GDPR and other applicable data protection laws, you have certain rights regarding your personal data.

• The Right to Access: You have the right to request copies of your personal data.

• The Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or incomplete.

• The Right to Erasure (Right to Be Forgotten): You have the right to request that we erase your personal data, under certain conditions.

• The Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.

• The Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions.

• The Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

• The Right to Withdraw Consent: Where we rely on your consent for processing, you have the right to withdraw that consent at any time.

Exercising Your Rights:

• For Individual/Family Accounts: Please contact our DPO at connect@temporeading.com to exercise any of these rights. We will respond to your request within one month.

• For School Accounts: If your child uses TempoReading through a school, the school is the Data Controller. Please contact your child's school directly to exercise your data protection rights. We will fully cooperate with the school to fulfil valid requests.

 

10. Children's Online Privacy Protection Act (COPPA) Compliance (For US Users)

 

TempoReading complies with COPPA. Our practices ensure:

• Verifiable Parental Consent: For users under 13 in the US accessing individual/family accounts, we obtain verifiable parental consent before collecting personal information.

• Parental Control: Parents have the right to review their child's personal information, direct us to delete it, and refuse further collection or use of the information.

• School Consent Exception: For school accounts, COPPA allows schools to act as the parent's agent and provide consent for the collection of student information directly for educational purposes. We work under these agreements with schools.

• Data Minimisation: We only collect information reasonably necessary for the child's participation in the Service.

 

11. Specific Jurisdictional Information

 

• United States: In addition to COPPA, we comply with the Family Educational Rights and Privacy Act (FERPA) for data processed on behalf of educational institutions. We also consider state-specific privacy laws (e.g., California CCPA/CPRA) where applicable.

• European Union: We are fully compliant with the EU General Data Protection Regulation (GDPR). Our Data Protection Officer (DPO) can be contacted for all GDPR-related inquiries.

• Canada: We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws, including principles of accountability, identifying purposes, consent, limiting collection, use, disclosure, and retention, accuracy, safeguards, and openness.

• Australia: We comply with the Privacy Act 1988 and the Australian Privacy Principles (APPs), ensuring transparent data handling, purpose limitation, data quality, and security.

 

12. Changes to This Privacy Policy

 

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. We will also inform you via email or a prominent notice on our Service prior to the change becoming effective, in accordance with applicable legal requirements.

We encourage you to review this Privacy Policy periodically for any changes.

By using TempoReading, you signify your acceptance of this Privacy Policy.