Privacy & Cookies Policy
Please read this Privacy & Cookies Policy carefully.
This Privacy & Cookies Policy (Policy) applies to personal data processed by Sounds-Write in connection with this Website, membership services, the Sounds-Write Members’ Portal and, where Sounds-Write acts as controller, the Progress Tracker. Where Sounds-Write processes Pupil Data solely on behalf of a school, trust or other controller, that controller’s privacy information also applies and Sounds-Write processes the data under the applicable Data Processing Terms.
Last updated: 28 August 2026.
Where Sounds-Write determines the purposes and essential means of processing described in this Policy, Sounds-Write Limited is the controller. Our data protection contact is enquiries@sounds-write.co.uk. You can also write to us at our registered office shown in section 1.
This Policy should be read alongside, and in addition to, our Terms and Conditions.
1. Definitions and interpretation
1.1. In this Policy, the following definitions are used:
| Cookies | a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the Cookies used by this Website are set out in the clause below “Cookies” and the “Cookie schedule”; |
| Data Protection Laws | any applicable law relating to the processing of Personal Data, including the UK GDPR, the Data Protection Act 2018 and any legislation amending, replacing or supplementing them and, where applicable to a particular processing activity, the EU GDPR or other applicable data-protection law; |
| GDPR | the General Personal Data Protection Regulation (EU) 2016/679; |
| Personal Data | collectively all personal information that you submit to Sounds-Write via the Website or otherwise. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws; |
| PECR | means the Privacy and Electronic Communications (“EC Directive”) Regulations 2003, as amended or replaced from time to time. |
| Pupil Data | means Personal Data relating to a pupil that is entered, uploaded, generated or otherwise processed in connection with the Progress Tracker. |
| Progress Tracker | means the phonics progress tracking functionality made available through the Sounds-Write Members’ Portal. |
| Sounds-Write, we or us | Sounds-Write Ltd., incorporated and registered in England, with company number 04655753 whose registered office is at Whiteleaf Business Centre, 11 Little Balmer, Buckingham, MK18 1TF; |
| User or you | any third-party that accesses the Website and is not either (i) employed by Sounds-Write and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Sounds-Write and accessing the Website in connection with the provision of such services. This includes visitors to our Website, our clients, subcontractors and employees and representatives of our clients where applicable. |
| Website | Our proprietary web domain https://www.Sounds-Write.co.uk/ and all associated sub-domains; |
1.2. In this Policy, unless the context requires a different interpretation:
1.2.1. the singular includes the plural and vice versa;
1.2.2. references to sub-clauses, clauses, schedules or appendices are to
sub-clauses, clauses, schedules or appendices of this Policy;
1.2.3. a reference to a person includes firms, companies, government
entities, trusts and partnerships;
1.2.4. “including” is understood to mean “including without limitation”;
1.2.5. reference to any statutory provision includes any modification or
amendment of it;
1.2.6. the headings and sub-headings do not form part of this Policy.
2. Scope of this Policy
2.1. This Policy applies to the actions of Sounds-Write in relation to the Website, membership services, the Members’ Portal and the Progress Tracker where Sounds-Write acts as controller. It does not replace the privacy information of a Member that acts as controller for Pupil Data processed by Sounds-Write on that Member’s instructions.
2.2. Throughout the Website, we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you or provide external services. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.
3. Personal Data collected
3.1. We may collect the following Personal Data, which includes personal data, from
you:
3.1.1. name;
3.1.2. role with your company or school (where applicable);
3.1.3. e-mail address;
3.1.4. IP address;
3.1.5. web browser type and version;
3.1.6. operating system;
3.1.7. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to; and
3.1.8. information about your interactions with the Website;
3.1.9. membership and account information, including organisation, role, membership plan, renewal and account status;
3.1.10. billing and transaction information, including invoice, payment-status and refund records (payment card details may be processed directly by our payment provider);
3.1.11. correspondence, support enquiries, complaints and information-rights requests; and
3.1.12. marketing preferences and records of consent, objection or opt-out. in each case, in accordance with this Policy.
3.2. In connection with the Progress Tracker, Pupil Data may include a pupil’s name, full date of birth, sex, EAL indicator, FSM indicator, SEND indicator and detailed phonics assessment information. The full date of birth is used to calculate chronological age in years and months so that phonics progress can be monitored and compared appropriately in relation to age. For organisational or professional Members, Sounds-Write generally processes this Pupil Data as processor on the Member’s documented instructions. The role applicable to individual personal or household use is described in section 7 below. 3.3. Where we ask you to provide information that is necessary to enter into or perform a contract, or to meet a legal requirement, we will make this clear. If required information is not provided, we may be unable to provide the relevant service or feature. Optional fields are voluntary.
4. How we collect Personal Data
4.1. We collect Personal Data in the following ways:
4.1.1. Personal Data is given to us by you; and
4.1.2. Personal Data is collected automatically.
4.2. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Policy.
4.3. We do not ordinarily seek Special Categories of Personal Data through general Website or membership administration. The Progress Tracker includes a SEND indicator. A binary SEND indicator does not necessarily disclose a diagnosis or health condition, but it may constitute or reveal data concerning health or disability depending on context. Where Sounds-Write processes such data as processor, the relevant Member/controller is responsible for identifying any applicable Article 9 condition. Where Sounds-Write acts as controller for any special category processing, Sounds-Write will identify and document the required Article 6 basis and Article 9 condition before that processing begins. We do not intentionally collect criminal offence data through the Progress Tracker.
4.4. Where we do not obtain Personal Data directly from the individual it relates to, we may receive it from a school, trust, educational organisation, employer, account administrator, parent or carer, payment provider, or authorised service provider. Where Sounds-Write acts as controller for such data, we will provide the privacy information required by applicable Data Protection Laws within the applicable timeframe unless an exemption applies.
5. Personal Data that is given to us by you
5.1. Sounds-Write will collect your Personal Data in a number of ways, for example:
5.1.1. when you contact us through the Website, by e-mail or through any other means;
5.1.2. when you register with us and set up an account to receive our products and services;
5.1.3. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
5.1.4. when you enter a competition or promotion through a social media channel;
5.1.5. when you elect to receive marketing communications from us;
5.1.6. when you use the Website; in each case, in accordance with this Policy.
6. Personal Data that is collected automatically
6.1. To the extent that you access the Website, we will collect your Personal Data automatically, for example:
6.1.1. we automatically collect some information about your use of the Website. This information helps us to make improvements to content and navigation and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
6.1.2. we will collect your Personal Data automatically using tracking technologies. For more information about these tracking technologies, and how we use them on the Website, see the section below, headed “Cookies“.
7. Our use of Personal Data
7.1. Any or all of the above Personal Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Personal Data may be used by us for the following reasons:
7.1.1. internal record keeping;
7.1.2. improvement of our Website;
7.1.3. transmission by email of marketing materials that may be of interest to you;
7.1.4. contact for market research purposes which may be done using email. Such information may be used to customise or update the Website; in each case, in accordance with this Policy.
7.2. Where we rely on legitimate interests, those interests may include operating and administering our Website and membership services, responding to enquiries and support requests, protecting our systems and users, preventing
misuse or fraud, maintaining records, managing relationships with organisational Members and improving our services using information that is not Pupil Data or has been appropriately anonymised. We will not rely on legitimate interests where our interests are overridden by your rights and freedoms.
7.3. We send direct marketing by electronic mail in accordance with PECR and applicable Data Protection Laws. We obtain consent where required and keep appropriate records of consent, objections and opt-outs.
7.3.1. Where the products-and-services soft opt-in applies, we may send marketing about our similar products or services without separate consent only where we obtained your contact details during a sale or negotiations for a sale, gave you a clear opportunity to opt out when we collected the details, and include a simple opt-out in every message. The soft opt-in is an exception to the consent requirement; it is not itself consent.
7.3.2. For other marketing to individual subscribers, including prospective customers where no soft opt-in applies, we will obtain valid consent before sending electronic marketing. Different rules may apply to corporate subscribers, but we will still comply with Data Protection Laws where the contact details identify an individual.
7.3.3. You can object to or unsubscribe from direct marketing at any time using the link in the message or by contacting us. We will keep a suppression record where necessary to respect your choice.
7.4. When you register with us to use our Website or order products and services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
7.5. Progress Tracker roles and purposes. Where a trust, school or other organisational/professional Member determines which Pupil Data is entered and why, the Member generally acts as controller and Sounds-Write acts as processor for the core tracking service and Member-specific support carried out on documented instructions. Sounds-Write does not use identifiable Pupil Data for product-wide improvement under that processor role. Product-wide
recommendation-quality monitoring should use aggregated or anonymised outputs that cannot reasonably be re-identified.
7.6. Where an individual Member uses the Progress Tracker solely for personal or household purposes, the UK GDPR household exemption may apply to that individual’s own processing. Sounds-Write’s role and lawful basis for any
controller processing connected with that use must be documented before launch to individual household users. This Policy will be updated if any additional controller purpose is introduced.
7.7. Summary of lawful bases where Sounds-Write acts as controller. Depending on the activity, we rely on:
7.7.1. contract or steps requested before entering a contract for data relating to an individual Member or customer;
7.7.2. legitimate interests for administering relationships with organisational Members and their staff, providing support, securing and improving our services, preventing misuse and managing our business;
7.7.3. legal obligation where processing is necessary to meet applicable legal, tax, accounting or regulatory requirements; and
7.7.4. consent where consent is required, including for certain direct marketing and non-essential storage or access technologies. Where special category data is processed, we will also identify an applicable Article 9 condition where required.
7.8. Automated analysis. The Progress Tracker uses fixed rules to analyse assessment information and generate teaching recommendations. It is intended to support, not replace, human judgement. Sounds-Write does not currently use the Progress Tracker to make decisions based solely on automated processing that produce legal or similarly significant effects on pupils. If the functionality changes materially, we will reassess the position and update the relevant DPIA and privacy information.
7.9. Children’s privacy. The Progress Tracker is intended for adult users and children do not directly use it. Where Sounds-Write acts as controller for children’s Personal Data, we will take reasonable steps to provide or make available privacy information in a concise, clear and age-appropriate form, directly or through the relevant parent or carer as appropriate.
7.10. We do not currently list any targeting cookies in the Cookie Schedule. If we introduce targeting or advertising technologies, we will update this Policy and our consent mechanism before using them and will obtain consent where
required.
8. Who we share Personal Data with
8.1. We may share your Personal Data with the following groups of people for the following reasons:
8.1.1. our authorised employees, contractors and professional advisers where access is necessary for their role and subject to appropriate confidentiality obligations;
8.1.2. our payment processing and billing partners in order to process payments and issue refunds; and
8.1.3. third-party service providers who process Personal Data to provide analytics which help us ensure the Website runs smoothly and optimise and customise the Website for you;
8.1.4. Amazon Web Services, which provides hosting and infrastructure for the Progress Tracker in the EU-West-2 (London) region; and
8.1.5. our UK-based external developer/consultant where production access is necessary for development, maintenance, troubleshooting, bug fixes or technical support. Where Sounds-Write is a processor, that developer/consultant is treated as an authorised sub-processor and is subject to written data-protection, confidentiality and information-security obligations.
8.2. Where a third party processes Personal Data on our behalf, we require appropriate contractual, confidentiality and security protections. Where we share Personal Data with an independent controller, that recipient is responsible for its own compliance with applicable law.
in each case, in accordance with this Policy.
9. Keeping Personal Data secure
9.1. We will use technical and organisational measures to safeguard your Personal Data, for example:
9.1.1. we store your Personal Data on secure servers; and
9.1.2. payment details are encrypted using SSL technology (typically you will
see a lock icon or green address bar (or both) in your browser when we use this technology.
9.1.3. Progress Tracker Pupil Data is encrypted in transit and at rest, access is segregated by Member account, privileged access is restricted and logged, AWS Console access and Sounds-Write admin accounts are protected by multi-factor authentication, and development/testing environments are separated from production. Any separate privileged developer or direct production-database access must be protected by multi-factor authentication or an equivalent strong authentication control in accordance with Sounds-Write’s security requirements.
9.2. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Personal Data, please let us know immediately by contacting us.
10. Personal Data retention
10.1. Unless a longer retention period is required or permitted by law, we will only hold your Personal Data on our systems for the period necessary to fulfil the purposes outlined in this Policy or until you request that the Personal Data be deleted.
10.2. However, please note that even if we delete your Personal Data, it may persist on backup or archival media for legal, tax or regulatory purposes or we may retain anonymised records of your historical use of the Website for analytics purposes.
10.3. The Progress Tracker default is to retain a pupil record for two years after the pupil’s last assessment, subject to the relevant Member/controller’s documented instructions and any earlier deletion request. Where a Member/controller asks Sounds-Write to retain a pupil record beyond the two-year default, Sounds-Write will ask the Member/controller at least every 12 months to confirm that continued retention remains necessary; if it is not confirmed, the Pupil Data will be deleted in accordance with the applicable retention workflow. Deleted Pupil Data may remain in backups for the applicable backup cycle, currently up to seven days, before permanent deletion.
10.4. For other Personal Data, we determine retention by reference to the purpose for which it was collected, the duration of the account, membership or business relationship, applicable legal, tax and accounting requirements, relevant limitation periods, security and fraud-prevention needs, and whether a suppression record is needed to respect a marketing objection. We review retention periodically and delete or anonymise Personal Data when it is no longer required.
11. Your rights
11.1. Depending on your location, you have the following rights in relation to your Personal Data:
11.1.1. Right of access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
11.1.2. Right of correction – the right to have your Personal Data rectified if it is inaccurate or incomplete.
11.1.3. Right to erase – the right to request that we delete or remove your Personal Data from our systems.
11.1.4. Right to restrict our use of your Personal Data – the right to “block” us from using your Personal Data or limit the way in which we can use it.
11.1.5. Right to data portability – the right to request that we move, copy or transfer your Personal Data.
11.1.6. Right to object – the right to object to our use of your Personal Data including where we use it for our legitimate interests.
11.1.7. Right to withdraw consent – where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.
11.1.8. Rights relating to significant automated decisions – where applicable, you have rights and safeguards in relation to decisions based solely on automated processing that have legal or similarly significant effects on you.
11.2. To make enquiries, exercise any of your rights set out above, or withdraw consent where consent is our legal basis, please contact us at enquiries@sounds-write.co.uk. We will respond without undue delay and normally within one month, subject to any lawful extension or exemption. We may ask for reasonable information to verify your identity or authority before acting on a request.
11.3. If your request concerns Pupil Data for which a school, trust or other Member is controller and Sounds-Write is processor, you should normally contact that Member/controller in the first instance. Sounds-Write will provide reasonable assistance to the controller in accordance with the applicable Data Processing Terms.
11.4. You have the right to complain to the Information Commissioner’s Office (“ICO”) about our processing of your Personal Data. If another supervisory authority is competent for processing subject to another applicable data-
protection law, you may also have the right to complain to that authority.
11.5. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during the period for which we hold it.
11.6. If you have any concerns about how Sounds-Write collects, uses or protects your personal information, we encourage you to contact us first so that we can investigate and resolve your concerns.
11.7. You can submit a data protection complaint by emailing enquiries@sounds-write.co.uk, by writing to us at our registered office address, or by using any electronic data-protection complaints form that we make available on our
Website.
11.8. We will acknowledge receipt of a data protection complaint within 30 days, take appropriate steps to investigate it without undue delay, keep you informed of progress where appropriate, and communicate the outcome without undue delay.
11.9. If you remain dissatisfied with our response, you have the right to complain to the Information Commissioner’s Office (“ICO”). Further information is available on the ICO’s website at ico.org.uk
12. Transfers to third countries
12.1. This clause applies where Data Protection Laws regulate an international transfer of Personal Data.
12.2. Progress Tracker production data and backups are currently hosted in the United Kingdom. Where Personal Data is transferred internationally, we will identify the applicable transfer rules by reference to the originating jurisdiction and the recipient location. Transfers from the EEA to the United Kingdom may rely on any applicable European Commission adequacy decision while it remains in force.
12.3. Where a restricted transfer requires additional safeguards, we will use an appropriate lawful transfer mechanism, such as applicable standard contractual clauses, the UK International Data Transfer Agreement or Addendum, or another mechanism permitted by applicable Data Protection Laws.
12.4. To ensure that your Personal Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Personal Data with. This ensures your Personal Data is treated by those third parties in a way that is consistent with the Data Protection Laws.
12.5. You may contact us to request further information about the safeguards used for a restricted international transfer and, where applicable, a copy of the relevant safeguard, subject to any appropriate redactions required to protect confidential information or the rights of others.
12.6. Identifiable or pseudonymised Progress Tracker Pupil Data will not be accessed by Sounds-Write staff or the external developer from outside the United Kingdom under the current operating model. Genuinely anonymised information, from which an individual cannot reasonably be re-identified, may be accessed by authorised team members while working abroad. If information remains identifiable or capable of re-identification, it will continue to be treated as Personal Data and any overseas access will be subject to this section and the applicable security and transfer safeguards.
13. Changes of business ownership and control
13.1. Sounds-Write may, from time to time, expand or reduce its business and this may involve the sale and/or the transfer of control of all or part of Sounds-Write. Personal Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Personal Data for the purposes for which it was originally supplied to us.
13.2. We may also disclose Personal Data to a prospective purchaser of our business or any part of it.
13.3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
14. Cookies
14.1. This Website may place and access certain Cookies on your computer. Sounds-Write uses Cookies to improve your experience of using the Website and to improve our range of products services. Sounds-Write has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
14.2. All Cookies used by the Website are used in accordance with the Data Protection Laws.
14.3. We will not use non-exempt Cookies or other storage and access technologies until you have given valid consent, unless an applicable PECR exception permits their use without consent. Strictly necessary technologies may be used without consent where legally permitted. Our consent mechanism will explain the technologies and purposes, identify relevant third parties where required, allow you to reject non-essential technologies as easily as you can accept them, and allow you to withdraw or change your preferences at any time.
14.4. This Website may place the following Cookies:
Type of Cookie Purpose
| Type of Cookie | Purpose |
| Strictly necessary Cookies | These are Cookies that are required for the operation of our Website. They include, for example, Cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services. |
| Analytical/performance Cookies | They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. |
| Functionality Cookies | These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). |
| Targeting Cookies | These Cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. |
14.5. You can find a list of Cookies that we use in the Cookie schedule.
14.6. You can manage or withdraw consent for non-essential Cookies and other storage and access technologies at any time using the cookie settings control on the Website. Your browser settings may also allow you to block or delete
Cookies, although doing so may affect the operation of some requested features.
14.7. You can choose to delete Cookies at any time, however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
14.8. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
15. Changes to this Policy
15.1. Sounds-Write may update this Policy to reflect changes in law or regulatory guidance, our services, or the way we process Personal Data.
15.2. We will post the updated Policy on the Website and update the “Last updated” date.
15.3. Where a change materially affects how we use Personal Data or your rights, we will take reasonable steps to bring it to your attention before the change takes effect where practicable. Any new processing purpose will be assessed under applicable Data Protection Laws and we will obtain consent where consent is required.
Cookie Schedule
Below is a list of the Cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a Cookie or there is any discrepancy, please contact us to let us know. We review the Cookie Schedule and our consent-management configuration periodically. The live schedule should accurately reflect the technologies in use, their purposes, relevant providers, applicable consent or exception status and retention/expiry periods, and will be updated where those details change.
Strictly necessary
We use the following strictly necessary cookies:
| Description of Cookie | Purpose |
| N/A |
Analytical/performance
We use the following analytical/performance Cookies:
| Description of Cookie | Purpose |
| Sbjs_migrations
Sbjs_first_add Sbjs_first Sbjs_current_add Sbjs_udata Duration before expiry – 6 months |
This is set by our shopping cart software Woocommerce to help identify where orders have come from. |
| Sbjs_session
Duration before expiry – session only |
This is set by our shopping cart software Woocommerce to help identify where orders
have come from. |
| _ga
Duration before expiry – 2 years |
Google Analytics – To store and count pageviews. |
| _ga_*
Duration before expiry – 1 year |
Google Analytics – To store and count pageviews. |
Functionality
We use the following functionality Cookies:
| Description of Cookie | Purpose |
| __stripe_mid
Duration before expiry – 1 year |
Stripe – to provide fraud prevention during online payments. |
| __stripe_sid
Duration before expiry – 30 minutes |
Stripe – to provide fraud prevention during online payments |
| cookieyes-consent
Duration before expiry – 1 year |
Functionality is to identify if a user has accepted or declined Cookies on the website. |
| Tk_ai
Duration before expiry – session only |
Used by our shopping cart software Woocommerce to store a unique user ID. |
| Wp_lang
Duration before expiry – session only |
Used by our website to understand the language you are using. |
| Woocommerce_item
s_in_cart Duration before expiry – session only |
Used by our shopping cart software Woocommerce to store items in shopping cart. |
| Woocommerce_cart
_hash Duration before expiry – 1 day |
Used by our shopping cart software Woocommerce to store items in shopping cart. |
| Wp_woocommerce_
session_* Duration before expiry – session only |
Used by our shopping cart software Woocommerce to store performed actions on the website. |
Targeting
We use the following targeting Cookies:
| Description of Cookie | Purpose |
| N/A |