Privacy Policy

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy: This privacy policy aims to give you information on how Structural Learning collects and processes your personal data through your use of this website, including any data you may provide through this website when you register and use the Structural Learning app.This website and the Structural Learning app are not intended for children and we do not knowingly collect data relating to children.It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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. This privacy policy supplements the other policies and is not intended to override them.

Controller: Structural Learning Ltd is the controller and responsible for your personal data (collectively referred to as, Structural Learning, "we", "us" or "our" in this privacy policy).We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Our full details are: Structural Learning Ltd
Our data privacy manager: Paul Main
Email address: paul@structural-learning.com
Postal address: 1st Floor 121 High Street Cottenham CB24 8SD

Where we are processing your personal data on behalf of another data controller and acting as data processor we will only do so on the basis of the data controller’s instructions. For the avoidance of doubt, where we receive your personal information (as set out in this Privacy Policy) from a school, college or other education providers, to create an online account so you are able to access the Structural Learning app, we will be acting as the data processor.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.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 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 policy of every website 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).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:Identity Data includes first name, last name, username or similar identifier.Contact Data includes address, email address and telephone numbers.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, feedback and survey responses.Usage Data includes information about how you use our website, and services.Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties 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 policy.We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.If you fail to provide personal data:Where we need to collect personal data by law, or under the terms of a contract we have with you or the school, college or education provider on whose behalf we process your personal information, 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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time - we will also notify the school, college or education provider on whose behalf we process your personal information.

3. How we collect personal data

We use different methods to collect data from and about you including through:Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:use the Structural Learning app; subscribe to our service or publications; request marketing to be sent to you; enter a promotion or survey; give us some feedback; make an enquiry about our services.Education provider. Your employer and/or the School, Academy or College who has provided your personal information to allow an online account to be opened so you can use the Structural Learning app.Other third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:Technical Data from the following parties analytics providers such as Google based outside the EU.Automated technologies or interactions. As you interact with our website, we may 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. Please see our cookie policy for further details.


4. How we use your personal data

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:Where we have a legitimate interest: this means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.Performance of Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

To comply with a legal or regulatory obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.In addition to the above, where we act as a data processor on behalf of a school, college or other education provider who acts as data controller, we will only process your personal information where we have received their written instructions.Purposes for which we will use your personal dataWe have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

4. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. External Third Parties including: Service providers who provide IT and system administration services. Third-party service providers who we use for things such as monitoring site health and usage, sending notifications and communications and enabling live content updates. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances. 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 policy.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.Where we act as data processor on behalf of a school, college or other education provider and process your personal data on their behalf, please be aware that as they are the data controller for whom we are processing your personal information they have access to any personal data we hold in respect of you.


6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

Unless expressed otherwise we will only retain your personal data for a period of 12 months from when you cease to be a registered user of Structural Learning app or in accordance with the instructions of any school, college or other education provider on whose behalf we process your personal information.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Where we act as data processor and process your personal information on behalf of any school, college or education provider we will pass any request to them as data controller. We will assist in any request from you in accordance with our agreement with any school, college or other education provider for which we act as data processor. 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 to continue 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. If you wish to exercise any of the rights set out above, please contact us.

No fee usually required: 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. What we may need from you: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.Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may 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.