C4K Education Ltd – Privacy Notice

Our Privacy Policy has been created to help you understand how we collect and use the personal information you provide to us, and to demonstrate our firm commitment to privacy.

Effective Date: 24th May 2018

‘C4K Education’: C4K Education Ltd, a company registered in England and Wales number 09385154.

Registered address: 28 One Lusty Glaze, Lusty Glaze Road, Newquay, England TR7 3FH.

The purpose of this statement is to set out how we collect and use your personal information whether supplied to us at an event, online, by email, telephone or on an application form.

It is important that you read this Privacy Notice together with any other Privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

When you use C4K Educations resources and website, for example SATs Boot Camp, you signify that you accept this Privacy Policy, as well as C4K Education’s Terms of Use.

1. General information

Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

C4K Education is the controller and responsible for your personal data (referred to as “C4K Education”, “we”, “us” or “our” in this Privacy Notice).

Service

Service is satsbootcamp.co.uk, SATs Boot Camp and all other education resources operated by C4K Education Ltd.

Contact

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please email hello@satsbootcamp.co.uk.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes

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 your relationship with us.

Third-party links

This Privacy Notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

2. The data we collect 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).

To the extent that we are allowed to do so under relevant law, we collect, use, store and transfer different kinds of personal data about you as follows:

A. Information you give us

Teachers:

  • Identity Data – includes first name, last name and title
  • Contact Data – includes invoice email address, school name and address, email address and telephone number.

Parents:

  • Identity Data – includes first name, last name and title
  • Contact Data – includes billing address, email address and telephone number

Children’s accounts:

We don’t allow children to set up their own Student logins directly. C4K Education’s Student accounts must be created by a Teacher User or a Parent User (this includes guardians). Teacher’s are only able to add the first name and 2 letters from a surname, to keep children’s names anonymous to us.

B. Information we collect automatically

When you use C4K Education’s websites, we collect some information automatically. For example, we collect educational progress data as you answer questions.

If you’re a Student User, this information may be accessed by Parent Users or the Teacher Users linked to your C4K Education School.

To help us improve C4K Education, we also use analytics software to collect usage information.

We only ask teacher and parent users to provide us with their child’s first name and 2 letters of their surname. This is personal data as defined in the GDPR (EEA).

We do not ask student (children) users to enter any personal information.

C. Other Information we may collect

  • Transaction Data – includes details about payments to and from you and other details of products you have purchased from us.
  • Technical Data – includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data – includes your username and password, purchases or orders made by you, preferences, feedback and survey responses.
  • Usage Data – includes information about how you use our website and products.
  • Marketing and Communications Data – includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 Privacy Notice.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product you have with us but we will notify you if this is the case at the time.

3. How we collect data

We collect several different types of information for various purposes to provide and improve our Service to you.

We use different methods to collect data from and about you including through:

  • register to use our products (including free trials);
  • place an order using our websites or by phone or email;
  • complete a registration form and opt in to to receive marketing materials;
  • subscribe to our newsletter;
  • request that we send marketing materials to you by submitting your email address or telephone number face-to-face or on social media sites;
  • complete online forms, take part in surveys, enter any competitions or prize draws, download information such as white papers or other publications or participate in any other interactive areas of our websites or within our products;
  • interact with us using social media;
  • submit a product review;
  • contact us offline, for example by telephone, SMS, email or post.

We will also collect your information where you only partially complete and/or abandon any information entered into our websites and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.

We may add to the personal information we collect from you with information we obtain from third parties that are allowed to share that information. For example, information from the Department for Education, search information providers or public sources. In each case we will do only what is allowed by relevant laws.

If you intend to give us personal information about someone else, you are responsible for ensuring that you follow any responsibilities and consent responsibilities under relevant data protections laws. As required by relevant data protection laws, you must ensure that you have their clear agreement to do so and that you explain to them how we collect, use, share and keep their personal information or tell them to read our Privacy Notice.

4. How we use data

We collect personal data in order to deliver our products. Most commonly we will use your personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you, including account creation, saving tests and mark entry, product renewal notices, administration of accounts, payment validations, including taking and processing payments, statistical analysis, market research, marketing and support.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

The provision of C4K Education’s services are intended to help children and parents or guardians with their child’s education and development. It is in our legitimate business interests to collect and process your personal information so that we can continue to provide our services.

The data is used in the following ways:

  • The personal information we collect is used to identify and personalise the individual’s user account so that the individuals can use the platform effectively.
  • The personal information allows us to keep the individual posted on C4K Education’s latest announcements, updates and upcoming events. If you do not want to be part of this mailing list you can unsubscribe via emails.
  • We may use personal and or sensitive information to conduct internal research, used to maintain, improve and develop our system, including how it decides what content to present to users.
  • We will collect data on test performance. This will be used to provide student reporting and to track attaintment.
  • We will use the data from your linked accounts to provide information on the progress of the user’s account.
  • We will use the personal information to communicate about purchases and changes to subscriptions, terms and conditions, contracts, and policies.
  • This is vital to the effective operation of the platform, to provide evidence of purchases and to maintain clarity on the basis upon which services are being provided.
  • We may use your personal information for internal purposes such as auditing, data analysis, the design or delivery of services and customer communications.
  • We may collect information regarding customer activities, IP address, location and which version of the browser you’re using. This information is collected to help us provide more useful information to our customers and to understand which parts of our website or platform are of most interest. This will help us to improve the user experience of our website and platform (or any other service we may provide, whether paid for or not).
  • We may collect details of queries you have about our products. This will allow us to easily and effectively answer future questions or make improvements to our platform, following consumer feedback on our product and services. We may use your questions or queries for marketing, customer support, employee training or research but we will ensure that they are anonymised and cannot be used to identify any person individually if they are going to be made publicly available or released to a third party other than those that would already have access under a different provision of this agreement.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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

5. Controlling access to personal information

We may have to share your personal data with the parties set out below for the purposes set out in section 4 above.

  • Our third party suppliers which process information on our behalf so that they may help us to provide you with the applications, products and information you have requested or which we believe is of interest to you. These include: internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you.
  • Partners that may help us to provide you with the applications, products and information you have requested or which we believe is of interest to you. These include: system implementers, independent software vendors and developers
  • Third parties used to process payment transactions.
  • Our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

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.

We may share non-personally identifiable information about the use of our websites or products publicly or with third parties but this will not include information that can be used to identify you.

Under certain circumstances, C4K Education may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

C4K Education may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of C4K Education
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

6. Storing your personal information

We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is added to our websites or products or to other websites or products via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites or products, please keep this password safe; we will not share this password with anyone and we will never ask you to share your password under any circumstances.

We also expect our customers to adopt good security practices, such as ensuring that your computers are adequately protected from malware and potential misuse, and that login credentials and passwords are not shared.

If you believe your account has been compromised, please contact us at hello@satsbootcamp.co.uk.

We encrypt your information using SSL – while it’s being transferred between your computer and our servers. On your web browser, you’ll see a padlock beside the web address. Clicking the padlock gives you the details of our security certification. We store your data on secure servers in the Europeans Economic Area (EEA).

7. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, 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.

We employ policies regarding the retention of your data in order to:

  • Meet business continuity requirements to recover services and customer data in the event of business disruption
  • Retain customer and pupil data for the purposes of subscription renewal and statistical analysis
  • Retain personal information for ongoing subscriptions
  • Retain personal information for no longer than 2 years for lapsed or cancelled subscriptions
  • Retain anonymised statistical information for no more than 7 years

When a school terminates their subscription with us we will, unless requested otherwise, retain the data for the remainder of the academic year and the following academic year in order that any subsequent re-subscription will allow the customer to access their historical data. After one full academic year with no active subscription, a school’s personal data will become anonymised.

Backups of data are stored for up to 5 years, on a separate server.

8. Your information and your rights

We are registered with the information commissioner’s office, Registration Number: ZA404927

If you have had any dealings with us it is possible that we hold information about you as a ‘data subject’. Under certain circumstances (where the GDPR applies), by law you have the right to:

  • Request access – to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction – of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure – of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information – where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information – to another party.
  • If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the C4K Education in writing.

In each case, we will typically respond to you without delay and within one month of receipt. This can be extended by a further two months if the request is complex or where there are numerous requests. Please address your enquiry to “Data Officer” using the following address:

Data Officer
C4K Education
28, One Lusty Glaze
Lusty Glaze Road
Newquay
Cornwall, TR7 3FH

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Pleade note: It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

9. Transfers outside of the European Economic Area

We may use service providers based outside of the EEA to help us provide our websites and products (for example, marketing service providers). This means that we may transfer your information to service providers outside the EEA for the purpose of providing our applications, advertising and services to you.

We take steps to ensure that, where your information is transferred outside of the EEA by our service providers, appropriate measures and controls are in place to protect that information in accordance with relevant data protection laws and regulations. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.

By using our websites or products or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Notice. If you do not want your information to be transferred outside the EEA you should not use our websites or products.

10. Cookies

Cookies are small text files which are transferred from our websites or products and stored on your device. We use cookies to help us provide you with a personalised service and to help make our websites and products better for you.

11. Updating this Privacy Policy

We may change this Privacy Policy from time to time and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

12. Data Protection Supervisory Authority / The Information Commissioner’s Office

If you are an EU citizen or our use of your personal information is subject to the GDPR, you also have the right to lodge a complaint about how we handle your personal information with an EU data protection supervisory authority.

In the UK, the supervisory authority is the Information Commissioner’s Office / the ICO. You can call the ICO’s helpline on +44 (0)303 123 1113. See also https://ico.org.uk/global/contact-us/.

How to contact us

If you have any query regarding this Privacy Policy or your Personal Information on C4K Education, please e-mail hello@satsbootcamp.co.uk.

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