Privacy and Cookies Policy

1. Introduction

This privacy and cookies policy sets out how Inspired Learning uses and protects any personal information that we obtain when you use our services, apps and websites (the “Services”).

We are committed to ensuring that your privacy is protected in accordance with all applicable privacy and data protection laws. Any personal information we collect or receive from you in connection with the Services will only be used in accordance with this privacy policy.

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are up to date with any changes.

We are registered in the UK with the Information Commissioner’s Office (ICO), under number ZB811964.

2. What Information we collect

Individual users creating accounts on the app and/or website must provide name, date of birth and a valid email address in order to set up the user account for the Services. The principal functions of the app and website may be used without providing any further personal information. For each app user we also provide usernames which each user may amend.

For paid accounts, where the billing contact information for an account is different from the student account information, we collect also the name and email address of the billing contact.

For the app and/or website, licenses for schools, academies, teachers, or other multiuser licensees (“Commercial Users”) additionally require the address and postcode of the entity signing the contract, plus telephone numbers of the administration contract, teachers and/or training staff. For students under Commercial User licenses we only require name and email address. For additional general business contact information requirements, see “Business Contacts” below.

In addition to the above information, we may collect the following information:

• demographic information such as age, gender, postcode, preferences and interests
• images that you upload and any image (e.g. photo of yourself) that you upload to be associated with your account
• your activities inside the app and/or website, including, inter alia, content that you have viewed, quizzes that you have taken, including the results of those, and interactions you have made with any third parties through the app
• your correspondence with us by email, webforms, chats or any other method
• survey results
• social media mentions, messages, and posts.

3. What we do with the information we gather

We require this information in particular for the following purposes and rely on the following legal bases to do so:

• To register your interest in products and services from us and be able to contact you in respect of these: legal basis: you have consented to this
• To deliver such products and services, including personalised learning suggestions, and social learning with other users, in which case they may see your username: legal basis: necessary for performance of our contract with you, or where this contract is with a Commercial User, for our and their legitimate interests in providing our products and services for your benefit, which have no negative impact on your privacy
• To connect with third party payment providers that we may use for paid versions of our products and services: legal basis: necessary for performance of the contract, or to take steps at your request prior to entering into the contract, with you and if applicable the student account holder; or, where this contract is with a Commercial User, our legitimate interests in collecting payment for our products and services, which have no negative impact on your privacy
• To improve such products and services: legal basis: our legitimate interests which have no negative impact on your privacy
• We may periodically send promotional emails, or push notifications (if turned on in the app or the device’s settings), about new products, special offers or other information, from us, and/or companies controlled by us, which we think you may find interesting (subject to your right to unsubscribe from emails, or turn off push notifications, when you create your account, or at any time): legal basis: you have consented to this or are an existing customer
• We may use your personal information to send you promotional information about third parties which we think you may find interesting (again, subject to your right to unsubscribe from emails, or turn off push notifications, at any time): legal basis: you have consented to this
• Internal record keeping: legal basis: necessary for compliance with our legal obligations
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, or mail: legal basis: our legitimate interests which have no negative impact on your privacy

4. Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure or use by third parties, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online in accordance with current industry standards. All student data is stored in the UK.

5. Links to other apps and websites

Our Services may contain links to other apps and websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other app or website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such apps and websites and such apps and websites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the app or website in question and in relation to any goods, services, or information from or other interactions with those apps and websites.

6. Other parties who access your information

We do not provide your personal information to third parties, except:

• Commercial Users, in relation to their own end users;
• where they are contracted to carry out certain processing activities on our behalf such as:
• providers of IT-related services (e.g. storage, hosting, maintenance, analytics, AI-based marking, teaching, and customer service);
• marketing, advertising, and communications service providers (e.g. a subscriptions manager for our mailing lists);
• payments or banking service providers (for paid products or services that we provide to you); or
• accounting, legal, compliance or insurance service providers.
• if we provide information to any of the above, we always do this on the basis of written contracts that require them to keep your information secure; or
• if required to do so by a regulator, court, police force, or by law.

All student data is stored in the UK. Some of our data processors may be based in the UK, the European Union and EEA or other places officially recognised by the UK or the European Commission as having equivalent data protection laws. If not, we provide information to them only on the basis of legal safeguards that require them to keep your data as secure as under European laws, such as standard UK or European Commission contractual clauses. If we receive a valid request, we may make available a copy of such safeguards.

In the event of a transfer of assets (if we sell or buy a business), your personal information may be disclosed, subject to appropriate confidentiality undertakings.

7. Children’s data

We strive not to collect any data of children under 13. If you are a parent/guardian and you believe that we may be processing data from someone under 13 that you have parental responsibility for, please contact us as set out below.

8. How long we keep your personal information

We will retain your personal information for the period necessary to fulfil the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law (e.g. for tax, accounting, and legal claims this may be at least 6 years).

9. Your control of your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

• whenever you are asked to fill in a form on the website or the app, look for any box that you can click to indicate how you want your information to be used;
• if you have consented to receive information as outlined in the “what we do with the information we gather” section above, you may change your mind at any time by writing to or emailing us at [email protected], or, in respect of emails received, you may click on the “unsubscribe” link at the bottom of the relevant email, or, in respect of push notifications, you may turn these off in app or device settings.

You also have additional rights under the GDPR and national laws and regulations including:

• to request details of personal information which we hold about you;
• to have any information we are holding on you corrected or completed;
• to exercise rights to personal data portability where applicable;
• to have personal Information we hold about you deleted by contacting us as set out below.

In order to provide the Services and to manage your account we require some personal information. Deleting personal information may require full deletion of your user account. In some cases, we may restrict processing but need to retain information for legal purposes. If you ask us to delete information, then some parts of our Services may not work correctly or at all. We will inform you about this if this applies.

Where we process any information based on consent that you have given in the past, then you are always allowed to withdraw that consent (although the processing that took place before withdrawal will still be legal).

Please contact us as indicated below to exercise any of your legal rights or to resolve any issues or doubts you may have in relation to processing of your personal information. If you believe that we have not acted correctly then you also have a right to complain to the Supervisory Authority in your country (e.g. in the UK the Information Commissioner’s Office) to ask them for a resolution.

10. Business contacts

If you are a business contact, e.g. if you are or work for one of our current or potential Commercial Users, suppliers, or other business partners, then we may process some personal information about you. We will need that information in order to communicate with you, invoice and collect payments, make payments, provide information, and manage contracts and products and services that we offer or obtain. That information may include your name, business email address, billing address, office address, business phone numbers, title, expertise, employer etc. We would only hold this information where it is necessary for the intended purpose; e.g. because you are a client (and we need to invoice you, communicate with you regarding our services, etc.) or you may be a prospect and we would have obtained that information from exchanging emails or business cards, from public sources, networking, or during meetings or events.

This data processing is necessary for our legitimate interests in performing, managing, improving, and marketing our Services or evaluating new services and supplies. As this information relates to your professional life, no negative impact is expected on your privacy. You can still exercise all your rights in relation to that personal information as set out in Section 8 and contact us with any enquiries as set out below.

App and Web analytics

We use third party products, such as Google Analytics, to do things such as keep track of the number of visitors to the app and website, the length of their stay, which screens and pages they visit, and actions they undertake from or within the app or website. This helps us analyse data about app traffic and web page traffic and improve our app and website in order to tailor it to customer needs. The metrics obtained through the use of cookies from e.g. Google Analytics, do not include any information that would allow us to personally identify visitors to the app or the website; the data is anonymous. The anonymised data that is collected is stored on the provider’s server. In respect of Google Analytics, full details on their cookies are published on the Google website. We also use Apple’s App Analytics.

Advertising

In respect of advertising on our app or website, third party vendors we may use, including Google, use cookies to serve ads based on a user’s prior visits to our app or website. Google’s use of the DART cookie enables it and its partners to serve ads to our users based on their visit to our app or website and/or other sites on the Internet. Users may opt out of the use of the DART cookie by visiting http://www.google.com/policies/technologies/ads/.

Other

We or our partners may also identify cookies which are placed on your device’s memory or computer’s hard drive by third parties other than our app or our website (“third party cookies”). By visiting the app and the website you agree that we or our partners may access these cookies. We are not responsible for any cookies which are placed on your device or computer by third parties – but you are generally free to disable these cookies at any time.

How to manage your COOKIES

In the settings of your browser or mobile phone you will be able to manage settings for, and clear, your cookies. For help on doing this, see your browser’s help section or your mobile phone manual. You can also visit www.AboutCookies.org which has information on controlling or deleting cookies. Please note that by deleting our cookies, or those of third parties, or disabling their future use, you may not be able to access certain areas or features of our app or website.

CONTACTING US

The “data controller” (the entity that decides why and how your personal information is processed) is:

Inspired Learning Solutions Limited, Flat 2, 118-120 Beaufort Street, London SW3 6BU, U.K., [email protected]