About
1.1. We are committed to protecting the privacy and personal data of our website visitors and users, including our service providers and parents. This policy sets out how we look after your personal data and tells you about your privacy rights and how the law protects you.
1.2. If you have any questions about this privacy policy or our treatment of your personal data, please contact us:
by email at: [email protected]
1.3. We keep our policies under regular review and may update this policy from time-to-time by posting a new version on our website. You should check this page periodically to ensure you are happy with any changes. It is also 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.
What personal data do we collect
2.1. Personal data 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). We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
a) Identity Data includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, sex, gender and other similar information.
b) Contact Data includes your billing address, home address, previous addresses, email address, telephone numbers and other similar information.
c) Financial Data includes your bank account details, payment card details and transactions, credit checks and other similar information.
d) Transaction Data includes details about transactions carried out between you and us and payments to and from you and other similar information.
e) 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, other technology on the devices you use to access this website, and other similar information.
f) Usage Data includes information about how you use our website and services.
g) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.2. 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. In this case, we may have to cancel a service you have with us and we will notify you if this is the case at the time.
How we collect your personal data
3.1. We use different methods to collect data from and about you including through:
a) Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us. This includes personal data you provide when you: apply for our services; create an account on our website; subscribe to our service or publications; request marketing to be sent to you; or give us feedback or contact us.
b) Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
c) Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as follows:
Technical Data from the following parties: analytics providers such as Google; advertising networks; and search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and other services.
Identity and Contact Data from publicly available sources.
How we use your personal data
4.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
a) Where we need to perform the contract we are about to enter into or have entered into with you and to enable us to provide you with the services which you have requested.
b) 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. This means that we process your personal data for purposes such as: for the provision of our services; for due diligence processes; to onboard new business relationships; to manage our relationship with you efficiently; to allow us to effectively and efficiently manage and administer the operation of our business; for the prevention of fraud; and for managing risks to which our business is exposed.
c) Where we need to comply with a legal or regulatory obligation.
4.2. More specifically, we may process your personal data in the following situations (please note that not all process will be relevant to you and your relationship with us and some of these purposes may overlap):
a) Provision of services to you: To enable us to provide services you have requested; to provide you with any information relating to such services; and to respond to any comments you may send us.
b) Relationship management: To enable us to efficiently manage our relationship with you or your business; to keep our records up to date; to maintain records of services provided and our interactions with you; and to respond to any complaints we may receive from you and to seek to resolve these.
c) Manage service provider relationships: To enable us to manage how we work with other companies that provide services to us and to you under your contract with us.
d) Product development: To assist in the development of new products and services.
e) Research: To conduct market or client research; and to engage with you for the purpose of obtaining your views on our services.
f) Business and financial management: To run our business in an efficient and proper manner, including managing our financial position, business capability, planning, communications, corporate governance (such as company registers and other company secretarial functions), audit, insurance, sales, event organisation and vendor management; to enable third parties to provide us (or our clients or prospective clients) with services; to respond to client due diligence requests; to investigate and respond to client complaints; and to manage the performance and security of our equipment, IT systems and electronic platforms, including administering access rights.
g) Legal, regulatory and compliance: To operate effectively our legal, regulatory and compliance processes.
h) Investigations: To detect, investigate and prevent breaches of legal obligations or internal and regulatory policies; and to detect, investigate and prevent the commission of criminal offences, in each case in accordance with applicable law and regulation.
i) Fraud prevention: To detect, prevent and investigate fraud or potential fraudulent activity.
j) Legal proceedings: To establish, exercise or defend our legal rights.
k) Marketing: To provide you with information concerning features, services, offers and related information.
l) Operation of this website and IT operations: To operate and support this website; to process your registration on this website; to communicate and interact with you via this website; to manage our IT systems and operations; and to operate our IT security and audits.
Marketing and opting out
5.1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
5.2. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase, experience or other transactions.
Who we may share data with
6.1. We share your personal data with our staff for the business purposes described above, such as providing services to you and operating this website. In addition, we may share your personal data with the third parties set out below for the purposes set out above:
a) Governmental, legal, regulatory, tax or similar authorities, ombudsmen, central and/or local government agencies; and/or law enforcement officials (if mandated by law and regulation or if required for the protection of our legitimate interests).
b) Anti-fraud services in relation to data on known or suspected fraudulent activity;
c) Third party service providers (for example, providers of hosting and maintenance of our website and other IT systems) who process personal data on our behalf.
d) Third parties to whom you request us to send your personal data. If you are a parent using our services, this includes any service providers who you decide to contact via our messaging platform. By contacting a service provider, you agree to your email address being shared with that service provider in order that they can respond to your message.
e) Third party processors (such as payment services providers and banks).
f) Our professional advisers (such as our auditors, accountants, financial advisers and lawyers).
g) Any relevant party, claimant, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights in accordance with applicable law and regulation.
h) Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law and regulation.
i) We may partner with other companies to offer you products or services. We may disclose personal information and/or non-personal or de-identified information collected about you to such third-party partners for the purposes described in this policy.
j) Any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation).
6.2. 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. If you request for us to stop processing your data, we will also communicate this to the relevant third parties if they are processing this on our behalf.
6.3. We do not specifically carry out international data transfers, but some of our external third parties may have operations based in other jurisdictions and so their processing of your personal data may involve an international transfer of data. Whenever your personal data may be transferred internationally, we ensure a similar degree of protection is afforded to it and we ensure that there are appropriate security measures in place, including data encryption and restricted access to your data.
How long we retain and use your personal data
7.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
7.2. 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, regulatory, tax, accounting or other requirements.
7.3. In some circumstances you can ask us to delete your data: see below for further information.
7.4. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
7.5. We take reasonable technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data. We will store all the personal information you provide on our secure servers that are subject to strict security requirements.
Third party links
8.1. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Your legal rights
9.1. You may have the following legal rights under data protection law (subject to certain legal exemptions and restrictions) in respect of your personal data that we hold:
a) request that we give you access to a copy of it;
b) request that we rectify or update it, if inaccurate;
c) request that we erase it, in certain circumstances where it is no longer needed;
d) request that we restrict our use of it;
e) object to our using it;
f) withdraw your consent to our using it (where our processing is based on your consent);
g) a right to data portability;
h) request us not to use it for direct marketing; and
i) lodge a complaint with the data protection regulator or supervisory authority in your country (if there is one).
9.2. If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
9.3. 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.
9.4. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Cookies
10.1. Our website uses cookies to distinguish you from other users of our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Cookies helps us to provide you with a good experience when you browse our website and allows us to improve our site. Some of the cookies we use are essential for the site to operate. They enable us to:
a) estimate our audience size and usage pattern;
b) store information about your preferences, and to allow us to customise our site according to your individual interests;
c) speed up your searches; and
d) recognise you when you return to our site.
10.2. We may use the following cookies from time to time:
a) 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.
b) Analytical or performance cookies: These 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.
c) Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences regarding certain areas of the website.
d) Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed.
e) Flash cookies: Our website may from time to time use the Adobe Flash Player to deliver audio and video content. The Flash Player uses a Flash Cookie (or Local Shared Object as it is technically known) to provide functionality features such as saving video playback preferences.
10.3. You can block cookies by activating the option on your browser that allows you to refuse the setting of all or some cookies. Advice on blocking cookies on a variety of popular browsers can be found online and you may be able to consult the ‘help’ section of your browser for instructions on how to block cookies. Please note that if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of our website. Moreover, disabling Flash cookies may result in you being unable to play content through our media players.