The Family Learning App

Privacy Policy

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Introduction

Welcome to the privacy policy of Brighter Coaching & Consultancy Ltd.

We respect your privacy and are committed to protecting your personal data.  This privacy policy will inform you as to how we look after your personal data when you use The Family Learning App and tell you about your privacy rights and how the law protects you.   

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This privacy policy is provided in a layered format so you can click through to the specific areas set out below.   Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

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1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

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1. Important information and who we are

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Purpose of this privacy policy

This privacy policy aims to give you information on how Brighter Coaching & Consultancy Ltd collects and processes your personal data through your use of the Family Learning App, including any data you may provide through the Family Learning App when you sign up to our newsletter or use a product or service or take part in a competition.

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 other notices and privacy policies and is not intended to override them.

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Controller

Brighter Coaching & Consultancy Ltd is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy policy).  We have appointed a data privacy manager who is responsible for

email address: jonathan@thefamilylearningapp.com

Postal address: Kilcriag, Cairn Road, Kirriemuir, Angus, Scotland, DD8 4PW

Telephone number: 07980 386865

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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.

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

We keep our privacy policy under regular review. 

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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.

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Third-party links

The Family Learning App 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 the Family Learning App, we encourage you to read the privacy policy of every website you visit.

 

2. The data we collect about you ​​​

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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).

 

Head Teachers and school administrators

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name and school details.

 

Teachers

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name and username.

• Contact Data includes email address and school details.

• 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 the Family Learning App.

• Profile Data includes your password, your feedback and survey responses. 

• Usage Data includes information about how you use the Family Learning App.

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

 

Parents / Guardian

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes the QR code provided by your school to download the App and data of your child as detailed below.

• 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 and your child use to access the Family Learning App.

• Profile Data includes the ratings on how comfortable you feel helping your child to learn

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

 

Children

We may collect, use, store and transfer different kinds of personal data about your child which we have grouped together as follows:

• Identity Data comprises first name, last name, date of birth and school.

• Profile Data  comprises any chosen nickname and colour selected for their character.

• Usage Data comprises time and date of last log-in, details of activities completed, date activities completed, ratings for enjoyment and difficulty of each activity, details of favourite activities and names chosen for favourite activities.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.  Aggregated Data could be derived from personal data but is not considered personal data in law as this data will not directly or indirectly reveal identity.  For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific Family Learning App 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.

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We do not collect any Special Categories of Personal Data (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data).  Nor do we collect any information about criminal convictions and offences.

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If you fail to provide personal data

Where we need to collect personal data to provide you with our services and you fail to provide that data when requested, we may not be able to provide you with our 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.

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3. How is your personal data collected?

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We use different methods to collect data from and about you including through:

• Direct interactions. When creating your own profile you will provide your Identity Data (i.e. your name).  You may also provide us with 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:

• apply to use our services;

• create your profile;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

• Automated technologies or interactions. As you interact with the Family Learning App website (www.thefamilylearningapp.com), 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.  Please see our cookie policy for further details.

• Third parties or publicly available sources. We will receive personal data from various third parties as set out below:

• In the case if teachers, your school administrator will provide us with Contact Data, namely your e-mail address and the name of your school.

• In the case of parents or guardians, when setting up your child’s profile your child’s teacher will provide us with your child’s name, date of birth and the name of your child’s school.   

• Technical Data from analytics providers such as Google based outside the EU. 

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4. How we use your personal data

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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 it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

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Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

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Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending 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.

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Purposes for which we will use your personal data

We 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.

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Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.  Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Marketing

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.

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We will not share your personal data with any third party for marketing purposes.

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You can ask to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you 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 a product/service experience or other transactions.

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Cookies

1. Our website, www.thefamilylearningapp.com, uses cookies.  You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.  For more information about the cookies we use, please see our cookie policy

 

5. Disclosures of your personal data

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We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Third Parties as set out in the Glossary.

• Specific third such as Hyper Luminal Games Ltd of Unit 1a 63 Brown Street, Dundee, Scotland, DD1 5AQ and Google LLC and its associated companies. 

• 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.

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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.

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6. International transfers

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We use Google’s Firebase Services to host and store your data.  As Google is based outside the EEA their processing of your personal data will involve a transfer of data outside the EEA.

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Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.  For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries:  https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries:  https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.  For further details, see European Commission: EU-US Privacy Shield:   https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en  

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For the purposes of providing the Firebase Services, the parent company of the Google group, Google LLC, is self-certified under the Privacy Shield on behalf of itself and its wholly owned US subsidiaries.  For further details, see https://firebase.google.com/terms/data-processing-terms.

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Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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7. Data security

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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.

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We will notify you and any applicable regulator of a personal data breach where we are legally required to do so.

 

8. Data retention

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How long will you use my personal data for?

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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.

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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.

Details of retention periods are set out below.

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Teachers:

The administrator for your school’s account is responsible for deleting your data.  If your data is not deleted by your school administrator we will continue to hold your data for up to six (6) months after your school account has been closed.  

 

Parents / Guardians:

Your data will be automatically deleted when your child’s data is deleted. We will continue to hold your data for as long as we hold your child’s data.

 

Children: 

A child’s profile may be deleted at any time by a teacher.  A child’s profile will be automatically deleted after six (6) months if there has been no activity on the account.  As long as a child continues to use the Family Learning App their data will not be deleted unless their teacher decides to do so.  

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In some circumstances you can ask us to delete your data: see your legal rights below for further information.

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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.

 

9. Your legal rights

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Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

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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.

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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.

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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.

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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.

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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:

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• 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.

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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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.

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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.

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If you wish to exercise any of the rights set out above, please contact us.

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No fee usually required

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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 could refuse to comply with your request in these circumstances.

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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.

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Time limit to respond

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.

 

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.

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Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

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THIRD PARTIES

• Service providers acting as processors based in the United Kingdom and, in the case of Google, around the world, who provide IT and system administration services. 

• Professional advisers including lawyers and auditors based in the United Kingdom who provide legal and accounting services. 

• HM Revenue & Customs and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances. 

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