Our Privacy Policy
BACKGROUND: Achieve Psychology for Learning Ltd (“TotalWords”, “we”, “us”, “our”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website (www.totalwords.com), uses our mobile or desktop applications (“Apps”), or interacts with our online services (“our Site and Apps”).
Total Words Website & App Privacy Notice
We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Notice carefully and ensure that you understand it.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
· “Account”: an account required to access and/or use certain areas and features of our Site or Apps.
· “Cookie”: a small text file placed on your computer or device by our Site or Apps when you visit certain parts or use certain features. Details of the Cookies used are set out in Part 14 below.
· “Cookie Law”: the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and as amended.
· “Data Protection Legislation”: the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Data Use and Access Act 2025 (DUAA 2025).
2. Information About Us
Our Site and Apps are owned and operated by Achieve Psychology for Learning Ltd, registered in England and Wales (company number 08909097). Registered address: C/O Chandler & Georges, 75 Westow Hill, London, England, SE19 1TX. VAT number: [Insert VAT number if applicable]. Data Protection lead: [Insert DPL name/contact if applicable]. Email address: info@totalwords.com We are registered as a data controller with the Information Commissioner’s Office (ICO) in the United Kingdom.
3. What Does This Policy Cover?
This Privacy Notice applies only to your use of our Site and Apps. Our Site and Apps may contain links to other websites or services. We have no control over how your
data is collected, stored, or used by other websites and advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier’. This includes obvious information such as your name and contact details, as well as less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. Your Rights
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
· The right to be informed about our collection and use of your personal data.
· The right to access the personal data we hold about you.
· The right to have your personal data rectified if any of it is inaccurate or incomplete.
· The right to be forgotten – to ask us to delete or otherwise dispose of any of your personal data that we hold.
· The right to restrict (i.e., prevent) the processing of your personal data.
· The right to object to us using your personal data for a particular purpose or purposes.
· The right to withdraw consent at any time where we are relying on your consent to process your personal data.
· The right to data portability.
· Rights relating to automated decision-making and profiling. We do not use your personal data in this way, but if this changes, we will update this notice and inform you of your rights.
You have an absolute right to object to the use of your personal data for direct marketing purposes at any time. If you wish to exercise this right, please use the opt-out mechanisms provided or contact us directly.
For more information about our use of your personal data or exercising your rights, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office (ICO) or your local Citizens Advice Bureau.
If you have any cause for complaint, you have the right to lodge a complaint with the ICO. We would welcome the opportunity to resolve your concerns ourselves, so please contact us first.
6. What Data Do We Collect and How?
Depending upon your use of our Site and Apps, we may collect and hold some or all of the following personal and non-personal data:
Data Collected How We Collect the Data Identity information (name, title) When creating an account or registering for services Contact information (email, address, phone) When creating an account, contacting us, or subscribing
Business information (company name, job title) When registering for business or educational services
Profile information (logins, purchase history) During use of your account
Technical information (device, browser, usage data, IP address) When you use our Site or Apps
Payment information Processed securely via Stripe; we do not store full card details
School, student, or staff data For educational users, processed in accordance with school contracts and Wonde API integration We do not knowingly collect special category or sensitive personal data, or data relating to children under 13 without appropriate consent and safeguards.
7. How Do We Use Your Personal Data?
We must always have a lawful basis for using personal data. The following table describes how we may use your personal data and our lawful bases for doing so:
What We Do What Data We Use Our Lawful Basis Registering you for services Name, contact details, job title, company/school Contractual necessity, legitimate interests
Providing and managing your Account Contact details, profile info Contractual necessity, legitimate interests
Administering our Site and Apps Technical and usage data Legitimate interests (improving services) Supplying our products/services Contact and payment info Contractual necessity, legitimate interests
Managing payments Payment and contact info Contractual necessity, legal obligation Communicating with you Contact info Contractual necessity, legitimate interests What We Do What Data We Use Our Lawful Basis
Marketing (with consent) Contact info Consent
Where we rely on legitimate interests, we carry out a balancing test to ensure our interests do not override your fundamental rights and freedoms.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes. You will not be sent any unlawful marketing or spam. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes, and you will be able to opt-out at any time.
We do not use automated decision-making or profiling. If this changes, we will update this notice and inform you of your rights. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s). If we need to use your personal data for a purpose that is unrelated or incompatible, we will inform you and explain the legal basis.
8. How Long Will We Keep Your Personal Data?
We will not keep your personal data for any longer than is necessary for the reason(s) for which it was first collected. Typically, we retain customer data for the period you are our customer and for up to 6 years after your last interaction, in line with statutory requirements. Technical data may be deleted sooner. Further details are available in our Records Management and Retention Schedules Policy, which you can request from us.
9. How and Where Do We Store or Transfer Your Personal Data?
We are committed to ensuring that your personal data remains secure, wherever it is processed. As a rule, your information is stored within the United Kingdom or in countries that the UK government recognises as providing an adequate level of protection for personal data. Should it ever be necessary to transfer your data to a country outside the UK that does not benefit from an adequacy decision, we will always ensure that robust safeguards are in place, such as Standard Contractual Clauses or International Data Transfer Agreements, so that your rights and protections travel with your data.
To further protect your information, we implement a range of technical and organisational measures. Access to your data is limited strictly to those who need it for legitimate purposes, and all staff and service providers are bound by confidentiality obligations. We maintain clear procedures for detecting, managing, and responding to any data breaches, and, where required by law, we will notify both you and the Information Commissioner’s Office (ICO) promptly should such an incident occur.
10. Do We Share Your Personal Data?
We will not share your personal data with any third parties for any purposes, except as follows:
· With trusted service providers (e.g., Stripe for payments, Wonde for school integrations, AWS for hosting, SendGrid for email)
· If we sell, transfer, or merge parts of our business, your data may be transferred to a new owner
· Where required by law, legal proceedings, or government authorities
If any personal data is transferred outside the UK, we will ensure it is treated as safely and securely as within the UK.
Statutory and Legal Data Sharing
In addition to the above, there may be circumstances where we are legally required to share your personal data. This includes situations where we must comply with statutory obligations, court orders, or requests from government authorities, regulators, or law enforcement agencies. For example, we may disclose your information to the Information Commissioner’s Office (ICO), HM Revenue & Customs, or other public bodies where required by law, or in connection with legal proceedings, the prevention or detection of crime, or to protect the rights, property, or safety of our business, our users, or others.
We will always ensure that any such disclosures are made in accordance with applicable data protection legislation and only to the extent necessary to fulfil our legal obligations.
11. How Can You Control Your Personal Data?
You may be given options to restrict our use of your personal data, especially for marketing. You can opt-out of marketing at any time using the links in our emails or by managing your Account. You may also sign up to preference services such as the Telephone Preference Service (TPS), Corporate TPS, or Mailing Preference Service (MPS).
12. Can You Withhold Information?
You may access certain areas of our Site and Apps without providing any personal data. However, to use all features and functions, you may be required to submit or allow for the collection of certain data. You may restrict our use of Cookies (see Part 14).
13. How Can You Access Your Personal Data?
You can ask us for details of your personal data and for a copy of it (a “subject access request”). All requests should be made in writing to info@totalwords.com or our postal address. There is not normally any charge, unless the request is manifestly unfounded or excessive. We will respond within one month, or up to three months for complex requests.
14. How Do We Use Cookies?
Our Site and Apps may place and access certain first-party Cookies on your device. By using our Site or Apps, you may also receive third-party Cookies (e.g., Google Analytics). You can manage your cookie preferences via our Cookie Policy and your browser settings. For more details, see our Cookie Policy.
15. How to Contact Us
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details: Email: info@totalwords.com Postal Address: Achieve Psychology for Learning Ltd, C/O Chandler & Georges, 75 Westow Hill, London, England, SE19 1TX.
16. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. Any changes will be posted on our Site and Apps, and you will be deemed to have accepted the terms on your first use following the alterations. We recommend that you check this page regularly to keep up to date.
This Privacy Notice was last updated in December 2025.
Cookie Policy
Last updated: December 16, 2025
What are cookies?
This Cookie Policy explains what cookies are, how we use them, the types of cookies we use (i.e., the information we collect using cookies and how that information is used), and how to manage your cookie settings.
Cookies are small text files used to store small pieces of information. They are stored on your device when a website loads in your browser. These cookies help ensure that the website functions properly, enhance security, provide a better user experience, and analyse performance to identify what works and where improvements are needed.
How do we use cookies?
Like most online services, our website uses both first-party and third-party cookies for various purposes. First-party cookies are primarily necessary for the website to function properly and do not collect any personally identifiable data.
The third-party cookies used on our website primarily help us understand how the website performs, track how you interact with it, keep our services secure, deliver relevant advertisements, and enhance your overall user experience while improving the speed of your future interactions with our website.
Types of cookies we use
Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.
Cookie Duration Description
ssr-caching Less than a minute The ssr-caching cookie is set by WIX and indicates how a site was rendered.
XSRF-TOKEN session This cookie enhances visitor browsing security by preventing cross-site request forgery.
hs. session Wix platform sets this cookie for security purposes.
svSession. 1 year 1 month 4 days Wix platform sets this cookie to identify unique visitors and track a visitor’s session on a site. bSession 1 hour Wix set this cookie in context with load balancing to improve user experience.
Uncategorised
Other uncategorised cookies are those that are being analysed and have not been classified into a category as yet.
Cookie Duration Description
client-session-bind session Description is currently not available.
server-session-bind session Description is currently not available.
sec-fetch-unsupported session Description is currently not available.
Manage cookie preferences
Consent Preferences. You can modify your cookie settings anytime by [insert option to change i.e. button on the website]. This will allow you to revisit the cookie consent banner and update your preferences or withdraw your consent immediately. Additionally, different browsers offer various methods to block and delete cookies used by websites. You can adjust your browser settings to block or delete cookies. Below are links to support documents on how to manage and delete cookies in major web browsers.
Chrome: https://support.google.com/accounts/answer/32050
Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac
Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc
If you are using a different web browser, please refer to its official support documentation.
TotalWords Terms and Conditions
1. Introduction
These Terms and Conditions (“Terms”) govern your access to and use of the TotalWords platform, including our website (www.totalwords.com), mobile and desktop applications (“Apps”), and any related services, including integrations provided via Wonde for school customers. By using TotalWords, whether via our website or any App, you agree to be bound by these Terms, our Privacy Policy, and (where applicable) our Cookie Policy. If you do not agree, please do not use the service.
TotalWords is operated by Achieve Psychology for Learning Ltd, a company registered in England and Wales (company number 08909097). Registered address: C/O Chandler & Georges, 75 Westow Hill, London, England, SE19 1TX.
Principal contact email: info@totalwords.com
Achieve Psychology for Learning Ltd is registered as a data controller with the Information Commissioner’s Office (ICO) in the United Kingdom.
2. Definitions and Interpretation
In these Terms:
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“Site” means the TotalWords website and any mobile or desktop applications (“Apps”) operated by us.
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“Account” means a user account required to access certain features of the Site or Apps.
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“Content” means text, images, audio, video, code, software, databases, and other information appearing on or forming part of our Site or Apps.
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“User” means any person using TotalWords via the Site or Apps.
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“User Content” means any content submitted by Users (for example, reviews, comments, uploaded files, or prompts) via the Site or Apps.
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“We”, “Us”, “Our” refers to Achieve Psychology for Learning Ltd.
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“Data Protection Legislation” means the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, The Data Use and Access Act 2025 (DUAA 2025) and any related regulations.
Unless the context otherwise requires, words importing one gender shall include the other; words in the singular shall include the plural and vice versa. References to “website” shall also include “app”.
3. Access to the Site and Apps
Access to our Site and Apps is provided on an “as is” and “as available” basis. We may change, suspend, or discontinue any part of the Site, Apps, or services without notice. We will not be liable if the Site, Apps, or any part are unavailable at any time. Some features require a paid subscription; details are set out on our pricing page and during checkout.
4. Accounts, Eligibility and Closure
Certain features (including purchase of services) require an Account. You must provide accurate and current information and keep your credentials secure. You are responsible for activity under your Account and must notify us promptly of suspected unauthorised use.
Eligibility: Teacher and student Accounts may be provisioned by schools. If you are under 18, you may only use TotalWords with the consent and oversight of a parent/guardian or your school. If you are under 13, use must be facilitated by your school or parent/guardian in line with the UK ICO’s Children’s Code (Age Appropriate Design Code).
Closure: You may close your Account at any time. Closing your Account removes access to Account-only areas. We will retain and/or delete your personal data in accordance with our Privacy Policy and applicable law. Where you have submitted User Content, we may delete or anonymise it; caching or references may persist beyond our reasonable control.
5. Security, Viruses and Malware
We implement industry-standard measures designed to protect your information across our Site and Apps, including JWT authentication, role-based access control, secure password hashing, validated requests, logging, and encrypted cloud storage. We also work with trusted providers such as Stripe (payments), SendGrid (email), AWS S3 (storage), and Wonde (school data synchronisation).
You must not introduce viruses or other malware, attempt unauthorised access, or attack our Site or Apps (including denial of service). Breaches may constitute criminal offences under the Computer Misuse Act 1990. If we become aware of a data breach affecting your personal information, we will notify you and, where required, the Information Commissioner’s Office (ICO).
6. Privacy and Data Protection
TotalWords complies with all applicable Data Protection Legislation, including the UK GDPR under the Data Protection Act 2018 and the Data Use and Access Act 2025. Achieve Psychology for Learning Ltd is registered as a data controller with the Information Commissioner’s Office (ICO) in the United Kingdom. Our registration number is [insert ICO registration number]. Personal data is processed in accordance with our Privacy Policy and Application Data Privacy Policy. By using our website or app, you consent to such processing.
You have the right to access, correct, or request deletion of your personal data, and to object to or restrict certain types of processing. You may also have the right to data portability. If you wish to exercise any of these rights, please contact us at info@totalwords.com . If you are not satisfied with our response, you have the right to lodge a complaint with the ICO.
7. Communications from Us
If you have provided contact details (for example by creating an Account), we may send important service notices by email, including changes to these Terms or to your Account. We will only send marketing communications with your consent. You can withdraw consent at any time via the unsubscribe link in our emails or within your Account preferences. We will comply with the Privacy and Electronic Communications Regulations (PECR) and applicable data protection laws.
8. User Content and Indemnity
If you submit User Content, you warrant that you have the right to do so and that it complies with these Terms and applicable law. You grant us a non-exclusive, transferable, royalty-free, worldwide licence to use, store, archive, publish, adapt, edit, reproduce, distribute, display, and sub-licence your User Content for operating and promoting TotalWords. We may remove or reclassify User Content that, in our reasonable opinion, breaches these Terms. You will indemnify us for losses arising from your breach of these warranties, to the fullest extent permitted by law. You retain ownership of your User Content and intellectual property rights subsisting in it.
9. Intellectual Property Rights
Except for User Content, all Content and the intellectual property rights subsisting in it are owned by or licensed to us and are protected by UK and international laws. You may access and view our Site and Apps, download for caching, print pages, and save pages for offline viewing. Our status (and that of our licensors) as the owner/author must be acknowledged. You must not reproduce, distribute, modify, create derivative works from, or commercially exploit any Content without a licence from us or our licensors. Nothing in these Terms limits fair dealing under the Copyright, Designs and Patents Act 1988 (for example, for research and private study, quotation, or news reporting).
10. No Scraping, Text or Data Mining and AI Use
You must not undertake, enable, or facilitate scraping, text or data mining, or automated collection from any part of our Site or Apps, nor use any Content or data for developing or training artificial intelligence models or systems. This prohibition applies to bots, spiders, and any automated techniques designed to analyse digital text or data.
11. Linking to Our Site and Apps
You may link to our Site and Apps provided you do so fairly and legally, without suggesting any association, endorsement, or approval where none exists, and without using our logos or trade marks without permission. You must not frame or embed our Site or Apps without permission and must not link from any site with content that is unlawful, hateful, defamatory, discriminatory, or otherwise inappropriate, or that infringes third-party rights.
12. Links to Other Sites
Our Site and Apps may include links to third-party websites. Unless stated otherwise, those sites are not under our control. We do not endorse, and are not responsible for, their content or practices. Accessing any third-party site is at your own risk.
13. Disclaimers
Content on our Site and Apps is provided for general information only and does not constitute advice. We make reasonable efforts to ensure that Content is complete, accurate, and up to date, but we make no representations, warranties, or guarantees (express or implied) that it is complete, accurate, or current. Information about services offered for sale is governed by our Service Terms of Sale below.
14. Service Terms of Sale
Ordering and Contract Formation: By placing an order or subscribing, you offer to purchase services from us. We will confirm receipt and acceptance by email or within the product interface; at that point a contract is formed.
Descriptions and Pricing: We take reasonable care to ensure service descriptions and prices are accurate. If we discover an error in pricing, we will contact you before processing the order. Prices are in GBP and exclusive of VAT unless stated.
Payment: All payments are processed securely via Stripe. By submitting payment details, you authorise Stripe to process your payment in accordance with its terms.
Subscriptions and Renewal: Subscriptions renew automatically unless cancelled. You can manage or cancel renewal at any time before the renewal date in your Account.
Cooling-off and Cancellations (Consumers): Under the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, you have 14 days from the date of contract to cancel. If you ask us to begin providing services during the cancellation period and then cancel, you may be charged a proportionate amount for services supplied up to the time of cancellation. Where digital content or services are fully performed during the cooling-off period with your express consent and acknowledgment of losing the right to cancel, the right to cancel may not apply.
Consumer Rights: Services will be provided with reasonable care and skill as required by the Consumer Rights Act 2015. If services are not performed to this standard, you may be entitled to repeat performance or a price reduction.
Refunds: Where refunds are due, we will process them to your original payment method, subject to Stripe’s processing rules.
School Purchases via Wonde: Where a school purchases access via Wonde, the Wonde API Licence Agreement applies to the integration, data access, support, and service levels. Fees for Wonde integrations may be subject to Wonde’s pricing and billing terms.
15. Wonde API Integration (Schools)
For school customers, access to the TotalWords API via Wonde is subject to the Wonde API Licence Agreement and associated schedules, including data protection and service level provisions. Schools must ensure they have lawful authority to share data and that appropriate agreements are in place.
16. Acceptable Use Policy
You must use TotalWords lawfully, whether via our Site or Apps. You must not use the service to transmit or store material that is unlawful, harmful, threatening, defamatory, obscene, infringing, or otherwise objectionable; to promote violence or unlawful activity; to discriminate against or defame any person or group; to mislead or impersonate others; to infringe privacy or intellectual property rights; or to introduce malware. We may suspend or terminate access, remove User Content, issue warnings, disclose information to law enforcement, and take appropriate legal action in response to material breaches of this Acceptable Use Policy.
17. Limitation of Liability
While we strive to provide a reliable and high-quality service, to the fullest extent permitted by law, we do not accept liability for loss or damage arising from your use of TotalWords, except where such liability cannot be excluded or limited. Nothing in these Terms excludes or limits liability for death or personal injury caused by our negligence, fraud or fraudulent misrepresentation, or any other liability which cannot be excluded or limited under the laws of England and Wales, including your statutory rights under the Consumer Rights Act 2015 and the Unfair Contract Terms Act 1977.
Except as expressly stated, and to the maximum extent permitted by law, we are not responsible for indirect, incidental, special, or consequential loss or damage, or for loss of profits, revenue, business, goodwill, or data, whether arising in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable. Our total aggregate liability to you for any claim or series of connected claims arising out of or in connection with your use of TotalWords (including any API or integration via Wonde) shall not exceed the total amount paid by you for the services in the twelve months preceding the event giving rise to the claim.
Where you access TotalWords via a school using the Wonde API, the Wonde API Licence Agreement’s limitation provisions apply and take precedence for matters relating to that integration. Services are provided on an “as is” and “as available” basis. Except as expressly set out in these Terms, all warranties, conditions, and other terms implied by statute or common law are excluded to the fullest extent permitted by law.
18. Changes to These Terms
We may update these Terms to reflect changes in services, law, or business practices. Updates will be posted on our website and, where material, notified to you. Continued use after changes take effect constitutes acceptance.
19. Governing Law
These Terms and any dispute or claim arising out of or in connection with them (including non-contractual disputes or claims) are governed by the laws of England and Wales. If you are a consumer resident in another UK jurisdiction, you will benefit from any mandatory provisions of local law and may bring proceedings in your local courts. If you are a business, the courts of England and Wales have exclusive jurisdiction, subject to applicable consumer protections.
20. Contact Us and Complaints
For questions or complaints about these Terms, the services, or our handling of personal data, please contact info@totalwords.com or use the contact details published on our website. We will work to resolve concerns promptly and, where appropriate, with the relevant authorities.
Terms Created on 16 December 2025