Fledge.education data protection policy

V.1.0 Updated 06-04-18

Policy outline & purpose

This Data Protection Policy refers to our commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality.

With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights.

Scope

This policy refers to all parties (employees, teachers, customers, suppliers etc.) who provide any amount of information to us.

Who is covered under the Data Protection Policy?

Employees of Fledge.education must follow this policy. Teachers, consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.

Policy elements

As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, financial data etc.

Fledge.education collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply.

1. How we use your personal data
In this Section 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.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 enquiry or purchase. 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, 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. With the exception of parents or carers supplying data on children in their care. (see section 7)

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. We will never supply your data to a 3rd party for payment or any other transactional arrangement.

2.1 Our company
We may disclose your personal data to our employees, in order that they may use your data within the boundaries that you agreed to on its submission.

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, 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. 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:
Paypal: https://www.paypal.com/ee/webapps/mpp/ua/privacy-full

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. Retaining and deleting personal data

This Section 3 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.

3.1 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.

3.2 Retention relating to a legal obligation
Notwithstanding the other provisions of this section, 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.

4. Security of personal data

4.1 Appropriate measures
We will take appropriate technical and organisational precautions to secure your pesonal data and to prevent the loss, misuse, or alteration of your personal data.

4.2 Secure storage
We will store all your personal data on secure servers, personal computers, and mobile devices, and in secure manual record-keeping systems.

4.3 Password storage
Any passwords you provide us will be stored securely.

4.4 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.

4.5 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. Your rights

In this section, 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.

5.1 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.

5.2 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.

5.4 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.

5.5 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.

5.6 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.

5.7 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.

5.8 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.

5.9 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.

5.10 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.

5.11 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.

5.12 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.

5.13 Providing us with written notice
You may exercise any of your rights in relation to your personal data by written notice to us at info@fledge.education or to the postal address as published in this privacy policy.

6. Third party websites

6.1 No control over third party websites
Our website can include 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.

7. Personal data of children

7.1 Age range
Our website and services are targeted at persons over the age of 18, who may provide details of children under the age of 8 that they are responsible for. The adult providing that data is responsible for it, and we will remove that data on request from the responsible adult.

8. Updating information

8.1 What to do if you want your data updated

Please let us know by email at info@fledge.education if the personal information that we hold about you needs to be corrected or updated