February 2019 / Private Beta Release

About this privacy policy

This privacy policy aims to explain how ThinkingHat collects, uses and transfers your personal data when you use our services and our related mobile application. Parents or Guardians who sign in to our app and create an account for a child will be referred to as “Subscriber” and the child who uses the application will be referred to as the “User”.

Types of Data we collect


By Personal data we mean any information about you by which may be used to identify you. We may collect information from the Subscriber such as your name, surname and email address. We will not collect information of this kind from the “User”.


Using our app, we collect information on the User’s navigation (or clickstream) data. This is simply the information about the pages the user visits on the app.


For surveys, we collect responses to help us improve various aspects of our product based on aggregate and individual feedback provided. These surveys are sent via opt-in marketing email campaigns or are made available on our application for you to participate if you so choose.

Why do we collect this data?

  • To provide the services you sign up for, like access to your ThinkingHat account.
  • For related internal administrative purposes -(like accounting and records) -and to advise of any changes taking place in our services.
  • To be able to send marketing communications when we have your permission, or when is permitted by law.
  • To personalise our services (for example, so you can sign in), to remember your settings and the accounts created in the app.
  • For internal research, analysis and reporting so that we can improve our navigation, page structure and page content to help users find information more quickly and provide more value by understanding their learning choices better.
  • To allow the User to return to a previous session (with their chosen settings and performance data).
  • To optimise our marketing communications. We use a technology (similar to cookies) to know whether you have opened one of our marketing emails or clicked on a link in the emails.
  • To resolve complaints and answer any question.
  • For security and fraud prevention purposes, and to ensure that our sites and apps are safe and secure and used in line with our terms of use.
  • To comply with applicable regulations and laws.

Our legal grounds for data collection

Shall we collect and use any data, it will be under these grounds:

  • Compliance with existing laws: On occasions, we may have a legal obligation to use or keep your personal data.
  • Our legitimate interests: When it is necessary for us to understand our Users and operate our app to ensure the adequacy and quality of our content. It is also in our legitimate interest to carry out marketing analysis to determine what content and services may be relevant to the Subscriber’s interest.
  • Consent: For example, if you have given your consent to receive marketing emails from ThinkingHat. You may withdraw your consent at any time. You can withdraw your consent to receiving marketing emails by clicking on the “unsubscribe” link at the bottom of the email.
If you have any questions or comments about this privacy policy, or the data collected, email

Data retention period

The personal data of the User will be treated actively while he holds the status of User of ThinkingHat Services; that is, as long as he does not exercise his right of suppression.

If you exercise your right to delete, your data will be blocked and kept in a restricted manner available to the competent authorities for a period of 5 years to meet the possible responsibilities arising from the treatment.