1. How we use your personal data
In this Section 1 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data;
(c) the legal bases of the processing.
1.1 Usage data
We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics and our Campus Software. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services
1.2 Service data
We may process your personal data that is provided in the course of the use of our services ("service data"). The service data may include your name, email address, postal address, service preferences, and basic financial information. The source of the service data comes from you when you provide it to us in the course of a negotiation or sale. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
1.3 Enquiry data
We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. We may also process information relating to how you have interacted with our website and any marketing we have sent you in order that we may send you relevant communications. The legal basis for this processing is consent.
1.4 Transaction data
We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
1.5 Notification data
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
1.6 Correspondence data
We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and communications with users.
1.7 The establishment, exercise, or defence of legal claims
We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise, or defence, of legal claims, whether in court proceedings or in an administrative, or out-of-court, procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
1.8 Compliance with a legal obligation
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
1.9 Other People’s Personal Data
Please do not supply any other person's personal data to us, unless we prompt you to do so.
2. Providing your personal data to others
In this Section 2, we provide you with information about which third parties we may pass your data to.
2.1 Our group companies
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company, and all its subsidiaries) insofar as is reasonably necessary for the purposes set out in this policy.
2.2 Our professional advisors
We may disclose your personal data to our insurers and/or professional advisers insofar as is reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice, and managing legal disputes.
2.3 Our technical providers
We may disclose your personal data to our data centre, telephony, and server administration providers insofar as is reasonably necessary for the safe and efficient storage of your data.
2.4 Our payment providers
Financial transactions relating to our website and services may be handled by our payment services providers, PayPal and Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds. You can find our payment provider’s privacy policies in the following places:
2.5 Our productivity and communication application providers
We may disclose your personal data while using our internal productivity and communication applications insofar as is reasonably necessary for the purposes of proper administration of our website and business.
2.6 For compliance with a legal obligation
In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.7 Acknowledgement of personal data submitted for publication
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
3. International transfers of your personal data
In this Section 3, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
3.1 Transfers to the United States
Some of the internal productivity and communication application providers that we use in our daily work hold data outside the EEA. Xero (our accountancy software provider is based in New Zealand but holds data in the United States), Atlassian and Trello (our developer tools), and Slack and Help Scout (our communication tools) are all based in the United States and hold data there. The European Commission has made an "adequacy decision" with respect to the EU-US Privacy Shield.
You can find information about their privacy policies in the following places:
Help Scout: https://www.helpscout.net/company/privacy
4. Retaining and deleting personal data
This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.1 Length of retention
The periods for which we keep your information depend on the purpose for which your information was collected and the use to which it is put. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.2 Retention relating to a legal obligation
Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests, or the vital interests of another natural person.
5. Security of personal data
5.1 Appropriate measures
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse, or alteration of your personal data.
5.2 Secure storage
We will store all your personal data on secure servers, personal computers, and mobile devices, and in secure manual record-keeping systems.
5.3 Password storage
Any passwords you provide us will be stored by us in encrypted form.
5.4 Financial transactions
Data relating to financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
5.5 Acknowledgement of you transmitting unencrypted data
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of that data sent over the internet.
5.6 Campus user passwords
If you are a Campus user you should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing Campus confidential and we will not ask you for your password (except when you log in to Campus).
6. Your rights
In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.1 Principal rights
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority;
(h) the right to withdraw consent.
6.2 Right to access
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
6.4 Right to rectification
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 Right to erasure
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.6 Right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7 Right to object to processing
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8 Right to object to direct marketing
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.9 Right to object to processing for scientific or historical research
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6.10 Right to data portability
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.11 Right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In the UK the supervisory authority is the Information Commissioner’s Office - https://ico.org.uk.
6.12 Right to withdraw consent
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.13 Providing us with written notice
7. Third party websites
7.1 No control over third party websites
Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
8. Personal data of children
8.1 Age range
Our website and services are targeted at persons over the age of 13. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
9. Updating information
9.1 What to do if you want your data updated
10. Acting as a data processor
10.1 In respect of Campus
In respect of our Campus users’ CRM module data, we do not act as a data controller; instead, we act as a data processor. Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
11. About cookies
11.1 What a cookie is
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Types of cookie
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies and personal data
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11.4 Cookies that we use
(a) necessary cookies – we use these cookies help make our website usable by enabling basic functions like page navigation and access to pages which require visitors to create an account and login. The website cannot function properly without these cookies;
||Manages your session when browsing the website
||Keeps our site safe by preventing cross-site scripting attacks
||Allows us to track your usage of our website
||Relates to the playback of video in our site which is hosted by our video hosting provider, Wistia
||Relates to the playback of video in our site which is hosted by our video hosting provider, Wistia
(e) advertising - we use third party vendors, including Google and Facebook, to serve ads to you based on your visits to our website and other sites.
You can find their privacy policies in the following places:
||Used to check if the user’s browser supports cookies
||A Google advertising cookie used to serve you information about us on Google’s advertiser network
||A Facebook advertising cookie to serve you information about us on Facebook
||Registers a unique ID that is used to generate statistical data on how the visitor uses the website
||Used by Google to distinguish users
||Used by Google Analytics to throttle request rate
12. Managing cookies
12.1 Per browser
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari);
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and- privacy (Edge).
12.2 Blocking cookies
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all the features on our website.
13. Email marketing tracking
Tracking email opens
When we send marketing emails promoting Sprint Education’s products and services we employ a common software technology called beacons. Beacons are tiny 1px x 1px graphics with a unique identifier, similar in function to cookies, and are used to track if you have opened a marketing email. We use these in our HTML-based emails to let us know which emails have been opened by recipients. They allow us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns. We also combine the information gathered by beacons in emails to our customers' personal data. If you would like to opt-out of these emails you can do so by clicking on the unsubscribe link in the footer of each
email we send you.
Tracking email clicks
When we send marketing emails promoting Sprint Education’s products and services we personalise each link in each email with unique code to enable us to track whether the recipient has clicked on the link in the email. This allows us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns. We also combine the information gathered by beacons in emails to our customers' personal data. If you would like to opt-out of these emails you can do so by clicking on the unsubscribe link in the footer of each email we send you.
14. Our details
14.1 This website
This website is owned and operated by Sprint Media Limited.
14.2 Our company registration
We are registered in England and Wales under registration number 6177833, and our registered office is B1 The Courtyard, Tewkesbury Business Park, Tewkesbury, GL20 8GD.
14.3 Our place of business
Our principal place of business is B1 The Courtyard, Tewkesbury Business Park, Tewkesbury, GL20 8GD.
14.4 Contact methods
You can contact us:
(a) by post, using the postal address given above;
(b) by telephone, on 01684 297374 or the contact number published on our website from time to time;
(c) by email, on email@example.com or using the email address published on our website from time to time.
14.5 Data protection registration
We are registered as a data controller with the UK Information Commissioner's Office. Our data protection registration number is ZA143246.
14.6 Data protection officer
Our data protection officer's contact details are: Guy Lewis (firstname.lastname@example.org), Sprint Education, B1 The Courtyard, Tewkesbury Business Park, Tewkesbury, GL20 8GD.