Privacy Policy

Last updated: 23 October 2023

 

We at NatWest Rooster Money care deeply about your privacy. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal data.

RoosterMoney is the trading name of World Learning Limited(“NatWest Rooster Money”, “we”, “us”, “our”) and corporate details are provided at the end of the policy. This policy applies to our website (RoosterMoney.com) and the NatWest Rooster Money app.

This policy forms part of the NatWest Rooster Money Tracker Conditions and NatWest Rooster Money Payment Conditions (together the “Service Terms”). It describes what information we collect in connection with the Service Terms in the course of providing the relevant services under those Service Terms (“Services”), as well as how we collect it, what we do with that information, the legal basis for processing and the rights and choices you have over how we use your data. This policy covers the personal data of both parents and their children. In order for us to be able to provide the Services to you, it is necessary for you to enter into the Service Terms, including the Privacy Policy, which then enable us to collect, process, share and store the personal data as described in this policy to operate those Services.

The following terms take the meaning given to them in the Data Protection Act 2018: controller, processor, data subject, personal data, personal data breach, data protection officer.

Any previous version(s) of this policy can be viewed here.

You can also view our Children’s privacy policy here.

• 1. Our Role as Controller
• 2. Information we collect
• 3. Your children's information
• 4. Cookies & Tracking
• 5. Choice and Control
• 6. International data transfers
• 7. Security of your personal information
• 8. Retention
• 9. Your Rights
• 10. Privacy policy changes
• 11. Third party websites
• 12. Our details
• 13. Annex A
• 14. Annex B

1. Our Role as Controller

We collect certain personal data described below when you and your family use our Services and through other interactions and communications you and they have with us.

We are the party responsible for deciding the means and purposes for processing this personal data, which makes us a ”controller” under the Data Protection Act 2018. If you have any questions or concerns at any time about your data or privacy, please email us at privacy@roostermoney.com

We are a member of NatWest Group plc. More information about the NatWest group can be found at NatWestGroup.com by clicking on ‘About Us’.

We may collect and/or share your data with the NatWest Group including where you have used the ‘sign in with bank’ feature to connect your NatWest status with NatWest Rooster Money. Where data is shared with NatWest, they will be classed as a Joint Controller.

Other service providers may also act as controllers in relation to your personal data:

• If you sign up for a subscription through our website or the paid Rooster Card subscription through the app, we use Adyen to process payments. In connection with this service that Adyen provides to NatWest Rooster Money, Adyen will collect your IP address, card details and billing information in order to securely process your subscription payment. If you make a direct payment to your Rooster Account using a debit or credit card, we use Adyen to process this direct payment. In connection with this service that Adyen provides to NatWest Rooster Money, Adyen will collect your billing address, and your first and last name to securely process your direct payment. The information that you provide through Adyen is subject to the Adyen Privacy Policy. You should read the Adyen Privacy Policy to learn about Adyen’s information collection, usage and your rights in that regard.
• If you ask us to, we will share information with any third party that provides you with payment services. If you ask a third-party provider to provide you with payment services, you’re allowing that third party to access information relating to your account. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.

2. Information we collect

We may collect, store and use the following kinds of personal data for processing on the basis specified in Annex A at the end of this Privacy Policy.

• Personal data to create your account
• Content you choose to upload to the app
• Email address and email preferences
• Usage information
• Log data and device information
• Cookies and similar technologies

3. Your children's information

Information collected 

When adding a child to your NatWest Rooster Money account, we ask for and collect the following personal data:

• Child’s first name
• Child’s date of birth
• Child’s gender

Optional Profile Information. You or your child may choose to provide us with additional personal data which includes:

• Profile photos
• Child’s email address (only a parent can add this)
• Child’s login details (username and password)
• Images and text they choose to upload to Goals or Chores

This information may be shared with two parents in the app.  In order for the child’s information to be shared with other family members we request prior full verifiable parental consent.  

We collect some information automatically when your child uses our app: 

• Location Information. We infer your child’s general approximate location down to a city level. 
• Device Information. For example operating system version and device identifiers.
• We collect usage information about your and your children’s interactions with NatWest Rooster Money services (e.g. Allowances, Boosts, Removes, Chores and Goals being saved for) as well as the pages or other content you view, length of visit and the date and time of your visits.

For a full list of passively collected data see Annex A 

Service Providers 

We work with third party service providers to better understand your child’s use of the service and to improve it. Our contracts with these companies prohibit them from (1) using data collected from our websites or apps for behavioral advertising and (2) sharing data collected from our websites or apps with third parties.  

We work with the following service providers in relation to children:

Google Analytics (click to read their privacy policy)

Firebase (click to read their Privacy Policy)

Intercom (click to read their Privacy Policy) – in app chat support via Intercom is only available to UK children who have access to the Rooster Card product

We do not ask for more personal data than is necessary for a child to participate in an activity.

• We take steps to prevent children from posting or publicly disclosing personal data.
• Parents can review, update or delete their children’s personal data within the app (this help article shows you how).
• Parents can revoke their consent and refuse the further use or collection of personal data from their child.
• Process for parents accessing, deleting or withdrawing consent:
  • Should a parent wish to access or delete the information we’ve collected about their children (subject to our record-keeping obligations under applicable law) they can do so by deleting their child’s profile from within the NatWest Rooster Money app (see how). Alternatively they can contact us by email at privacy@admin.test.rooster.money.
  • The email must contain all of the following:
    1. the parent and account holder’s email address
    2. the child’s username
    3. The parent’s relationship to the child.

How do we notify parents?

• When a parent creates a NatWest Rooster Money account, we obtain consent for the collection, use, or disclosure of any personal information  collected about or from the child (the “personal data”), and that we will not collect, use, or disclose any personal data from the child if the parent does not provide such consent;
• We set forth the additional items of personal data that we may collect from the child, or the potential opportunities for the disclosure of personal data;
• We offer a hyperlink to our privacy policy in the email.

4. Cookies & Tracking

When you visit any web site, it may store or retrieve information on your browser or device, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalised web experience.

Because we respect your right to privacy, you can choose not to allow some types of cookies. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer.

We may use the following types of Cookies:

• Necessary cookies: those required for the operation of the Service, which do not gather information about you that could be used for marketing or remembering where you have been on the internet.
• Analytical/performance cookies: these allow us to collect information about how you use the Service, such as, how you move around our website and if you experience any errors. These cookies do not collect personal data. The information collected is anonymous and is only used to help us improve the way the Service works, understand what interests our users generally and measure how effective our advertising is. Some of the performance cookies we use are issued as part of services provided by third parties, like Google Analytics.
• Functionality cookies: these are used to provide services or to recognise you when you return to our website. These would enable us to personalise our content for you, remember your preferences and improve your visit.
• Targeting cookies: these record your visit to the Service, the pages you have visited and the links you have followed. They are set by and linked to services provided by third parties, such as “Like” and “Share” buttons. The third party provides these services in return for recognising that you have visited our website. The third party may subsequently use information about your visit to target advertising to you on other websites and present you with advertisements that you may be interested in.

You are able to reject the use of cookies with browsers. Some browsers allow you to reject all cookies; others, only allow to reject third party cookies. You will be able to manage your cookie preferences for your browser by accessing your browser’s Tools section (here are instructions for some commonly used browsers: Chrome, Internet Explorer, Firefox).

The third party services we use are listed below may use Cookies to identify Users or they may use the behavioral retargeting techniques, i.e. displaying messages tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.

1. Google Analytics (Privacy Policy)
2. Firebase (Privacy Policy)
3. Facebook Advertising (Privacy Policy)
4. Google Advertising (Privacy Policy)
5. Intercom (Privacy Policy)
6. Impact (Privacy Policy)
7. Twitter (Privacy Policy)
8. Trustpilot (Privacy Policy)
9. Bing Advertising (Privacy Policy)
10. Amazon (Privacy Policy)
11. Mailchimp / Mandrill (Privacy Policy)
12. TVSquared (Privacy Policy)

Log file information will automatically be reported by your browser or mobile application each time you access our Sites or the NatWest Rooster Money app. For example, when you access our NatWest Rooster Money site, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, IP address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed and other such information.

Web beacons may be used via our third party email service providers Mandrill and Amazon SES, to help us understand whether users have read our email messages and clicked on the links contained within those messages. This allows us to measure the performance and impact of our messages.

5. Choice and Control

We know that our NatWest Rooster Money families value having control over their own information, so NatWest Rooster Money gives you the choice of providing, editing or removing certain information, as well as choices about how we contact you. You may change or correct your family’s account information through your account settings within the NatWest Rooster Money app. You can also request the deletion of the personal information in your account.

You may also control the receipt of certain types of communications from NatWest Rooster Money in your account settings. NatWest Rooster Money may send you messages about the Service or your activity. Some of these messages are required, service-related messages for members (such as major changes to the services that will significantly impact you or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by changing your account settings.

6. International data transfers

We may transfer your information to organisations in other countries (including to other NatWest group companies) on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws. 8.2. 

In the event that we transfer information to countries outside of the UK and European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where: 

1. a) the UK has decided that the country or the organisation we are sharing your information with will protect your information adequately;
2. b) the transfer has been authorised by the relevant data protection authority; and/or 
3. c) we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the UK) to ensure your information is adequately protected.

7. Security of your personal information

The security of your personal data is important to us. We take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of data collected.

We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal data. We will store all the personal data you provide on our secure (password- and firewall-protected) servers. You must use Access Codes to log-in to your own Parent Account.

Data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

Your account information is protected by the measures described above, which require you to use the Access Codes to log-in to your Parent Account. We will not ask you for your Access Codes (except when you log in to the Service). It is important that you protect against unauthorised access to your account and information by choosing your Access Codes carefully and by keeping your Access Codes and computer secure, such as by signing out after using the Service.

If you have any questions about the security of your personal data, you can contact us at privacy@admin.test.rooster.money. 

8. Retention

NatWest Rooster Money will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e. for the lifetime of your NatWest Rooster Money member account), as described in this policy. If a NatWest Rooster Money family account becomes inactive, data will be retained for no longer than 2 years from the date of last activity, except where we are legally obliged to do so. If you no longer want NatWest Rooster Money to use your information to provide the Service to you, you may close your account (see how). NatWest Rooster Money will retain and use your information to the extent necessary to comply with our legal obligations. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.

9. Your Rights

The table in Annex B at the end of this Privacy Policy explains the following rights you may have in relation to your personal data under the Data Protection Act 2018 (and any exceptions to those rights) and how you can exercise them:

• Right of access
• Right to rectification
• Right to erasure
• Right to request the restriction of processing concerning you
• Right to data portability
• Right to object to processing
• Right to ask us not to process your personal data for direct marketing purposes
• Right not to be subject to automated individual decision-making, including profiling

Please note that this Privacy Policy provides the confirmation referred to in relation to the Right of Access.

10. Privacy policy changes

We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by sending you an email message to the email address provided at registration about the changes. You should check this page occasionally to ensure you are happy with any changes. By using the site and apps, you agree to any amendments we make to this Privacy Policy.

11. Third party websites

The Service may contain links to other websites. We are not responsible for the privacy policies or practices of third party websites.

12. Our details

World Learning Limited (trading as “NatWest Rooster Money”), is a company incorporated in England and Wales (company number 06830114) with its registered office at 250 Bishopsgate, London, England EC2M 4AA and business offices NatWest Rooster Money, 1 Spinningfields Square, Manchester, M3 3AP. We are registered with the Office of the Information Commissioner (registration number: ZA374824).

Our phone number is +44 (0)203 984 8422.

If you have any questions about this privacy policy or our treatment of your personal information, please email us: privacy@admin.test.rooster.money.

13. Annex A

14. Annex B