Introduction

Ocado Innovation Limited (as “Ocado Technology”), the division that powers Ocado.com, the world’s largest online-only grocery retailer, has launched Code for Life. Code for Life is a nationwide corporate social responsibility initiative to help support primary and secondary school teachers deliver the new computer science curriculum. The aim of the initiative is to equip every child in the country with the “coding survival skills” that will enable them to flourish in an increasingly digital world.

Ocado Innovation Limited is committed to protecting any data that we collect concerning you. By using our services on this website you are agreeing to the use of the data that we collect in accordance with the Privacy Policy and the Terms of Use (together, the “Terms & Conditions”), so please read these carefully. Ocado Innovation Limited is committed to providing a valuable source of supporting materials for teachers to deliver the current primary school curriculum, as well as a fun, educational web application from which students can learn. The Terms & Conditions form a legal document which sets out your rights and obligations, and those of Ocado Innovation Limited, a company registered in England under registered company number 08813912 with its registered office at Buildings One & Two Trident Place, Mosquito Way, Hatfield, Hertfordshire, United Kingdom, AL10 9UL (“Ocado Innovation Limited”, “we”, “our” or “us” as appropriate in the context), in relation to the entire contents of the Code for Life website and the games, platforms and other products or services offered by Ocado Technology from time to time (collectively, “Code for Life”).

Terms of Use

Important: If you are under 13 years of age you must have your parent, guardian or carer’s consent to register for a Code for Life account, and to use their email address. If you are using this at school, you must first have your teacher’s permission to use this site. These Terms of Use were most recently updated on 27 December 2018.

Code for Life includes all versions of “Rapid Router”, “AI:MMO” and any other games, platforms and other products or services released by us (whether online or otherwise), from time to time, including all Code for Life websites used to play the games, platforms and any other products or services that we make available. “Code for Life” and “Rapid Router” are registered UK trade marks of Ocado Innovation Limited.

You must take the time to read and understand the Terms of Use and the Privacy Policy before registering for Code for Life. By registering, you accept that you are entering into a contract with us in accordance with the Terms & Conditions and the Privacy Policy. Visitors to the Code for Life portal who do not register to become a User, similarly affirm that they are bound by the Terms & Conditions and the Privacy Policy each time they access the Code for Life site. We reserve the right to update the Terms of Use at any time, so please check them periodically, as all changes will be binding on you provided that you use the website after they have been made. To assist you in determining whether the Terms & Conditions have changed since your most recent visit to the website, we will display the date when the Terms of Use and Privacy Policy were most recently updated.

Important: You must ensure that any email address we hold for you is kept up-to-date and that you have full access to it. Important notifications are sent to the email address you provide. Failure to keep this information updated can result in your Code for Life account being deleted and/or restricted.

Registration and Types of Membership

Membership falls into the following categories under the Agreement outlined in this policy:

  • Administrators: person or persons assigned responsibility for the management and security of membership by other Users;

  • Users: any person using the Code for Life website, Rapid Router, AI:MMO or any other game, application or platform of ours regardless of membership;

  • Students: Users who are provided with login information for Code for Life by a teacher, parent, guardian or carer;

  • Teachers; and

  • Guardian, parents, carers.

Many features of Code for Life require you to register as a User. Access to certain resources will be restricted from non-registered Users and Users who are not part of a participating school. Parents, guardians or carers of students registered through their school or club, should contact the child’s teacher directly to request copies of the teaching resources, to assist with homework or progression in learning how to program. Teachers should provide a valid and professional email address when registering on the Code for Life site.

If you register a school or club, you will automatically become the responsible ‘Administrator’. You should provide a valid and professional email address when registering as a teacher. If you create a school on the Code for Life site, you, by default become an ‘Administrator’ for your school.

As an Administrator, you warrant that:

  • you are responsible and accountable for ensuring the online safety of the school or club for whom you are acting and that only legitimate institutional addresses should be accepted at sign up;

  • all registration information you submit is accurate, complete and truthful;

  • you will maintain the accuracy of such information; and

  • if you are accepting the Terms & Conditions on behalf of a school or club, you have the authority to bind that institution, company or legal entity to the Terms & Conditions.

As a User, you further warrant that you will only grant access codes to teachers, staff members and students who are current employees or students known to your school or club. Upon termination of a teacher or other staff member’s employment with you, you will ensure they assign over all existing classes and/or students to another teacher within your school or club. If at any time you become aware of a User who falsely claims to be affiliated with your school or club, you are obliged to notify the Code for Life team immediately.

A Code for Life User must not choose a username or institution name that could potentially infringe anyone’s rights, which is intended to confuse, or which is offensive, hurtful or otherwise inappropriate, as reasonably determined by us. We reserve the right to change a username if we think it offends the Terms & Conditions. Users who are provided with login information for Code for Life by your teacher, parent, guardian or carer, are “Students”. Students are divided between those who are registered by a teacher through a school or club, or set up as an independent student using a parent, guardian, or carer email address.

Please note that we are not an internet service provider. All Users of Code for Life must have internet access and the necessary software for email and web usage.

Code for Life’s Privacy Policy forms part of the Terms & Conditions, and your acceptance of the Terms & Conditions constitutes consent to the way we may handle your personal data as detailed in that policy.

Misuse of Code for Life site

We reserve the right (a) to suspend or terminate any User’s access to Code for Life, or parts of it, and/or (b) to remove, or require the User to remove, material posted on Code for Life, if the User or material appears to us, or to someone who has complained to us, to be in breach of any provision of the Terms & Conditions.

Any person whose access has been suspended or terminated may not re-register for, or re-access, the Code for Life portal without our prior written consent. You are responsible for everything which is done on or through the Code for Life portal through your registered email address(es) or whilst your Users account is logged on to the Code for Life site. In addition, we reserve the right to suspend or terminate any User’s access to Code for Life, or parts of it, if the relevant User is abusive, discriminatory or threatening, or harasses or communicates offensive messages or images to another User; irrespective of whether this is done through the Code for Life site.

We endeavour to ensure that the Code for Life website and access to your account and our games, platforms and other products or services are available 24 hours a day, but occasionally your access to the Code for Life website or to your account (including any old or live games or avatars) may be restricted to allow for repairs, maintenance or the introduction of new features or services. We aim to provide the best service possible, but we do not warrant that the Code for Life website, access to your account or any of the games, platforms or any of our other products or services (whether online or otherwise) will be fault, virus or error free. If you detect a problem or fault, please contact us using the contact us form at https://www.codeforlife.education/help/#contact and we will endeavour to correct the fault as quickly as we can.

Notwithstanding any of the above, we reserve the right to decline any new registrations or suspend or cancel a User’s account at any time and at our sole discretion (and without telling you beforehand), and we reserve the right to terminate your access to all or part of the games, platforms and other products or services that we make available from time to time (whether online or otherwise) which shall include any old or live games or avatar(s) you have created.

The Code for Life portal is intended to be used by its Users and Students for the purposes we describe in the Terms & Conditions and not for any other purposes. Accordingly, Users and Students must not:

  • place material on, or otherwise use, the Code for Life for any business or commercial purpose; or

  • use their access to the Code for Life, or information gathered from it, in connection with the sending of unsolicited bulk email (sometimes known as spam).

Prohibitions

You must ensure that any activity and or communication through the Code for Life site, is not capable of (a) infringing the intellectual property or other rights of any person or entity, (b) breaching any applicable laws, regulations or codes of practice, whether criminal, tortuous or otherwise, (c) appearing to be offensive, harassing, threatening, harmful, vulgar, abusive, discriminatory, obscene, pornographic, false, libellous, defamatory, unreliable or misleading, (d) being perceived as antisocial or disruptive, (e) gaining unauthorised access to other computer systems, (f) interfering with any other person’s use or enjoyment of the Code for Life website or their account(s), or (g) engaging in any technically harmful behaviour, which includes but is not limited to, computer viruses, logic bombs, Trojan horses, worms, harmful components, corrupted data and other malicious software or harmful data.

Alerting Cofe for Life

If you see anything on the Code for Life portal which appears to infringe any part of the Terms & Conditions, then please inform us via the Contact Us section of this site.

We do not endorse or take responsibility for the content of any third party sites that link to or from Code for Life.

Intellectual Property

You acknowledge that all copyright, trademarks, and other intellectual property rights in and relating to Code for Life (including all content of the Code for Life website, the Rapid Router application, the AI:MMO application, related software (including any drawn and/or animated avatars, whether or not such avatars have any modifications) and any other games, applications or any other content that we make available from time to time) are owned by Ocado Innovation Limited. These rights protect all of the applications, games, products and services you see on the Code for Life website from time to time, including the graphics of those games, their structure, gameplay and their “look and feel”. It is easy to copy material which appears on websites, but this does not mean it is legal. Therefore, no-one may copy, modify, distribute, show in public or create any derivative work from the Code for Life portal, or any part of the games or other material which is found on the Code for Life unless properly licensed to do so by us.

Our Liability

The website, use of the application and games, and access to any accounts is provided by us on an “as is” basis without any warranties or guarantees. We do not accept responsibility for any errors, omissions, or for the results obtained from the use of such information or for any technical problems you may experience with the website.

We shall not be liable for:

  • any viruses or other disabling features that affect your access to or use of the website (including your account);

  • incompatibility of the Code for Life website with any of your equipment, software or telecommunications links;

  • delays or failures which you may experience whilst conducting any activity on the Code for Life website;

  • technical problems including errors or interruptions of the Code for Life website;

  • unsuitability, unreliability or inaccuracy of the Code for Life website, or the inadequacy of the Code for Life website to meet your requirements; or

  • consequential or incidental damages (including but not limited to loss of revenue, loss of profits, loss of anticipated savings, wasted expenditure and loss of data) or any other indirect, special or punitive damages whatsoever that arise out of or are related to the Code for Life website.

Nothing in the Terms & Conditions shall exclude or limit our liability for:

  • death or personal injury caused by our negligence;

  • fraud or fraudulent misrepresentation by us; or

  • any liability which we cannot exclude or limit by law.

Miscellaneous

The delay or failure of any party to exercise its rights provided for in these Terms & Conditions shall not be deemed a waiver of any further rights hereunder. If any provision of the Terms & Conditions is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary to enable the Terms & Conditions to remain in full force and effect. The Terms & Conditions shall be governed by and construed in accordance with the laws of England and Wales and the parties shall submit to the exclusive jurisdiction of the English courts.

Code for Life Privacy Policy

Last Updated: 27 December 2018

We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share your personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

We’re deeply committed to creating a safe and secure online learning environment for you as teachers, parents, guardians, carers and young people.

  1. We will never sell or share your personal information to third parties.

  2. We strive to provide you with access to and control over the personal information that you give us, and we take the protection of your information very seriously.

  3. We take extra precautions for the safety and privacy of our younger learners by moderating online communications and not allowing a child to post or disclose personal information.

  4. We do not accept third party advertisements on our website or within our lessons. We use your personal information only to communicate with you and to provide you with a better learning experience.

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.

  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

  3. Relevant to the purposes we have told you about and limited only to those purposes.

  4. Accurate and kept up to date.

  5. Kept only as long as necessary for the purposes we have told you about.

  6. Kept securely.

Who we are

Ocado Innovation Limited (trading as Ocado Technology and owners of the Code for Life website), with our registered office address at Buildings 1 & 2 Trident Place, Hatfield Business Park, Mosquito Way, Hatfield, AL10 9UL ; collects, uses and is responsible for certain personal information about you. When we do so we comply with the relevant data protection regulation in the territories in which we operate, including the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

The Kind of Information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

In the course of your use of the Code for Life portal and our services we may collect the following personal information when you provide it to us:

  • Name/Title

  • Email Address

  • School/Teaching or Education Institution

  • Performance information

  • Date/Time individuals register and last log in

  • Names of children registered in each class

  • Information about your use of our information and communication systems

  • Your IP address

  • Coding you create when using an application, game (including any avatars you create) or other product.

How is personal data collected?

We collect personal information about you i.e. your full name, title, email address, username, school/teaching or education institution at the time of registration. We may collect additional personal information i.e. performance information, any coding you create when using an application, game (including any avatar(s) you create) or other product, school/teaching or education institution and information about your use of our information and communication systems in the course of your use of Code for Life.

Indirect Data Collection

Your Internet browser has the in-built facility for storing small files or ‘cookies’ that hold information such as your IP address or the web browser being used, which allows a website to recognize your account. Our website employs this facility to enhance your experience and help us improve the effectiveness of our site. You should consult the “Help” section of your browser to learn how to change your cookie preferences. You may also find instructions on how to do this at www.allaboutcookies.org/manage-cookies/. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you first access the Code for Life website (not when you log on). However, you should be aware that the Code for Life website (in common with most other websites) will not work without cookies and therefore we recommend you leave them turned on.

We have enabled Google Analytics Data Collection and Mouseflow. This provides us with, amongst other things, a summary (i.e. at an aggregate and anonymised level) as to how you use our site and enables us to improve your experience.

How we will use information about you

We need all the categories of information in the list above, primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. The purpose for us processing your personal information is to identify you as a particular user in our system. This identifier gives teachers access to course material, class and individual student management features, and customer support, while giving students access to the web app in order to learn how to code within a supported environment (classroom), or independently (at home). We use the email address to notify the user of their registration status and login information, as well as updates to our privacy practices, our app and portal features, upcoming events and maintenance impacting User or Student accounts and for such other purposes as described in this Privacy Policy.

Messages may be sent periodically to a user profile with these communications and to offer support. Users can also use the Contact Us form to contact Code for Life staff directly for customer support. We strongly encourage users not to disclose personal information (other than name, email address and contact phone number where applicable) through any communication to Ocado Innovation Limited. If you use the Contact Us form on the Code for Life portal and decide to disclose personally identifiable information, this information can be stored by Ocado Innovation Limited. Ocado Innovation Limited staff will never ask for personal information other than what is required to locate a user in our system. Ocado Innovation Limited will never disclose user’s personal information to a third party organisation. The Contact Us form is strictly for the purpose of user support. User initiated communication concerning topics other than those relating directly to the Code for Life portal, including web apps, resources or user experience may not be answered.

Change of purpose

We will only use your personal information for the purposes for which we collected it or for other compatible purposes. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the basis on which we do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Additional use of Information Collected

In addition to the purposes described above, we may use collected email addresses and usernames to track and analyse site usage and to ensure users are following the site’s Terms of Use. We may also use an email address and username to limit a user temporarily or permanently from the Code for Life portal if that user engages in inappropriate use of the site (e.g. giving other people access to their user account, malicious misuse of the portal, including spam).

Who we share your personal information with

We will share personal information with law enforcement or other authorities if required by applicable law.

Third Parties

Ocado Innovation Limited does not allow third party advertising, or affiliation on our site. We will not share collected personally identifiable information with any third party.

We share your name and email address details with our third party processors, including MailChimp, dotmailer and SalesForce. MailChimp and dotmailer are used for the purposes of sending the newsletter or any important service related emails. SalesForce is used for our data base which is an intermediary between us and MailChimp. This data sharing enables us to send you emails, view when they are opened and view which links are clicked. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Security of Financial Information

Code for Life (including Rapid Router, AI:MMO and all related teaching materials) is a free online resource designed and managed by Ocado Innovation Limited. At no time will we ask for payment for the use of the service. You should contact the Code for Life team should you ever be asked for billing information while accessing our services.

How long will your personal information will be kept?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights

Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information;

  • access to your personal information and to certain other extra information that this Privacy Notice is already designed to address;

  • require us to correct any mistakes in your information which we hold;

  • require the erasure of personal information concerning you in certain situations;

  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;

  • object at any time to processing of personal information concerning you for direct marketing;

  • object in certain other situations to our continued processing of your personal information;

  • otherwise restrict our processing of your personal information in certain circumstances; and

  • claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email our Data Protection Officer at privacy_codeforlife@ocado.com;

  • let us have enough information to identify you (eg username, full name and email address); and

  • let us know (if possible) the information to which your request relates.

If you would like to unsubscribe from any email newsletter you can click on the unsubscribe button to be removed. It could take up to 72 hours to process the update through our systems.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We have introduced two-factor authentication to the portal to further reinforce the safety of Teachers’ accounts, details of which are available at https://www.getsafeonline.org/protecting-your-computer/passwords/

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that we or our Data Protection Officer can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: +44 303 123 1113.

Changes to this Privacy Policy

This Privacy Policy was last updated on 27 December 2018.

We may change this Privacy Policy from time to time and you should check it regularly. If we make any material changes to this notice we will inform you via email.

How to contact Us

Please contact our Data Protection Officer or us at privacy_codeforlife@ocado.com if you have any questions about this Privacy Policy or the information we hold about you.

Do you need extra help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).