Privacy Policy

PRIVACY NOTICE – GROUP ED LIMITED

Consent to installation of the App

Before installation of this App, please indicate your consent to our processing of your personal data (‘your’ personal data throughout this policy also includes the personal data of the pupil/student you are using these services on behalf of and you confirm you have the necessary appropriate consents to provide us with their personal data), which may also include sensitive personal data as described in this policy

Yes I consent to the installation of the App and the use of my personal data and, where necessary, sensitive personal data.

No I do not consent to the installation of the App.

How you can withdraw consent

Once you provide consent by selecting 'Yes', you may change your mind and withdraw consent at any time by contacting us at our contact details set out below but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

GROUP ED LIMITED (we, our, us) are committed to protecting your personal data (which includes the personal data of the pupil/student you use our Services on behalf of) and respecting your privacy.

Introduction

This policy (together with our Terms and conditions, both being our Terms of Use) applies to your use of:

• Our mobile application software (App) or hosted on www.grouped.org.uk (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App that are available on the App Site (Services).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This policy is compliant with the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK (Data Protection Law). Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

We are the controller and we are responsible for your personal data.

Contact details

Our full details are:

• Full name of legal entity: Group Ed Limited, company number 10416481
• Email address: info@grouped.org.uk
• Postal address: Group Ed Limited Ocean Park House, East Tyndall Street, Cardiff, CF24 5ET.

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

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated in October 2018. It may change and if it does, these changes will be posted on this page.

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 our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data – including name, address, date of birth and gender;
• Contact Data – including telephone number, address and email address;
• Financial Data – including payment card details;
• Transaction Data – including payment history, in-app purchases and balances;
• Device Data – including IP address, cookies, web analytics and browser type and version;
• Profile Data – including login details, passwords, email address and in-app messages (which includes messages sent between you and the school using our Services);
• Special categories of personal data – including, but not limited to, data relating to religion, race and health;
• Content Data: includes information stored on your Device; and
• Usage Data: includes details of your use of any of our Apps or your visits to any of our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information you consent to giving us about you by providing us with the data on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties such as providers of technical, payment and delivery services.

Cookies

We use cookies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. Please see our Cookies Poicy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data to carry out the Services on your behalf. We have introduced appropriate technical and organizational measures to protect the confidentiality , integrity and availability of your personal information during storage, processing and transit.

Purposes for which we will use your personal data

Under Data Protection Law, there are various grounds which are considered to be a ‘legal basis for processing’. The legal basis for processing your personal data is that ‘processing is necessary for the purposes of legitimate interests pursued by the controller’ and that you have ‘given clear consent to process the personal data for a specific purpose’.

It should be noted that in some circumstances the legal basis may vary, however, we always operate in full compliance of Data Protection Law and will only process data with a fair and reasonable legal basis for doing so.

Disclosures of your personal data

When you consent to providing us with your personal data, we may also share your personal data with certain third parties (such as those set out below) to enable us to provide you with the Services:

• Payment processors (to process your card payments).
• Email and SMS providers (to send out email or SMS notifications).
• Security providers (to protect our software and systems from viruses and attacks).
• Hosting providers (to manage our data).

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

We only retain your information for as long as is necessary to deliver the Services. We may need to retain some records to ensure compliance with legislation, for example, finance and tax legislation means that such data will need to be retained for up to seven years.

Your legal rights

Under certain circumstances you have the following rights under Data Protection Law in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:(a) if you want us to establish the data's accuracy;
• (b) where our use of the data is unlawful but you do not want us to erase it;
• (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• You also have the right to ask us not to process your personal data for marketing purposes.
• You can exercise any of these rights at any time by contacting us at info@grouped.org.uk