We are Nuvay Private Ltd trading as “Phraze”. are an online educational content provider (the “Services”) to parents, and School Students (“you”) to assist the learning of students of school age.

For privacy queries, you can contact us at info@nuvay.co.uk.

It tells you what to expect when we collect personal information from users of our website/app. Please only use them if you are completely happy with this policy.

Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies. Nor does this policy apply to personal information that we collect as a “processor”.

Yes. We will give you notice of the new version by posting it on our service and communicating it otherwise if appropriate.

Information that you upload to our service or otherwise give us such as:

Student Learning Data includes student responses to activity questions, aggregate scores across subject and/or topic area and progress made over time

Automated browsing information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, the site from which you arrived at our service, details of your activity with date/time stamps including pages you visited and your searches/transactions.

We may receive limited information about you from our payment/authentication providers (for verification purposes). This information may include your name and contact details.

Other data types
Usage Data includes information about how you use our website, app(s) and services.
Marketing Data includes your preferences in receiving marketing from us and your engagement with our marketing activities.
Communications Data includes your communication preferences and email, voicemail and telephone records to customer support.

Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract. This applies to information such as initial enquiries and to account, contact and transaction information.

Because it’s in our “legitimate interests”, e.g., sending you marketing communications about our similar products/services, managing and improving our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to information such as contact details and automated browsing data.

Because you’ve specifically agreed on our service (e.g., by selecting a consent box). This may apply to contact or other information that you specifically agree to us using for certain kinds of marketing. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.

Because it’s necessary to comply with legal or regulatory obligations.

We will generally hold your information for our default standard retention period of six years after the end of our contract/relationship with you, but we may delete it earlier/later as set out below or in our terms and conditions.

We will keep your information that we use for email newsletters or other marketing until you tell us to stop sending you such messages.

We will generally keep automated browsing information for up to 14 months.

To other people who supply us with services, e.g., website/app hosting and management, app admin, payment, messaging, email distribution, e-commerce, online advertising, analytics, social media etc.

To other users of the relevant project.

To regulators, the police and other law enforcement or official authorities to help deal with fraud and abuse and/or comply with legal requirements and/or to protect us or others.

To (actual or potential) potential buyers so far as reasonably necessary in the case of a proposed or completed sale or merger or business combination involving all or the relevant part of our business.

Your personal information (e.g., name, username, contact details, IP address, browsing information) is transferred to our offshore companies outside the UK (generally to the Sri Lanka and India) that provide us with the services mentioned above. Where this happens, we will ensure that there is a legal basis to do so, for example in accordance with “adequacy regulations” applying to particular countries, or under contracts with standard contractual clauses sanctioned by the Information Commissioner that are designed to provide adequate safeguards for your personal information.

If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete it or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g., marketing).

You may also have the right to object to use of your personal information in certain circumstances.

If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).

For more information about your rights, visit the ICO’s website: www.ico.org.uk.

For information about our use of cookies and similar technologies, please see our Cookies Policy at www.phraze.com/cookies-policy.