PRIVACY AND COOKIES POLICY
Version number 1
Effective date: 01/11/23
1. Who are we?
1.1 We are Opal Education Ltd. For privacy queries, you can contact us at info@opaleducation.co.uk.
2. What’s the purpose of this policy?
2.1 It tells you what to expect when we collect personal information from users of our website. Please only use it if you are completely happy with this policy.
2.2 Generally, the policy covers only information provided to us. If you give personal information to other people, such as other websites, please check their privacy policies.
3. Might the policy change?
3.1 Yes. We will give you notice of the new version by posting it on our service and communicating it otherwise if appropriate.
4. What do we collect?
4.1 Information that you upload to our service or otherwise give us such as:
· your name and contact details;
· other information you provide in connection with our parent services including personal information about your children such as their name, age, character traits/descriptors, educational history, languages spoken;
· details about your transactions with us; and
· information that you otherwise in communications shared with us.
4.2 When you use our website, automated browsing information such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, the site from which you arrived at our service, details of your activity with date/time stamps including pages you visited and your searches/transactions.
5. What’s our reason / legal basis for collecting the information?
5.1 Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract. This applies to information such as initial enquiries and to contact, transaction, and child-profile information.
5.2 Because it’s in our “legitimate interests”, e.g., managing and improving our website including tracking usage patterns and preventing or detecting fraud or abuse. This applies to automated browsing data.
5.3 Because it’s necessary to comply with legal or regulatory obligations.
6. How long do we keep personal information?
6.1 We will generally hold your information for our default standard retention period of six years after the end of our contract/relationship with you, but we may delete it earlier/later as set out below or in our terms and conditions.
6.2 We will generally keep automated browsing information for up to 14 months.
7. To whom do we send or make available your personal information?
7.1 To other people who supply us with services, e.g., translation, email distribution, online advertising, analytics, etc.
7.2 To regulators, the police and other law enforcement or official authorities to help deal with fraud and abuse and/or comply with legal requirements and/or to protect us or others.
7.3 To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.
7.4 To (actual or potential) potential buyers so far as reasonably necessary in the case of a proposed or completed sale or merger or business combination involving all or the relevant part of our business.
8. Do we send your information outside the UK?
8.1 Your personal information (e.g., name, username, contact details, IP address, browsing information) is transferred to companies outside the UK (generally to the US) that provide us with the services mentioned above (see: To whom do we send or make available your personal information?). Where this happens, we will ensure that there is a legal basis to do so, for example under contracts with standard contractual clauses sanctioned by the Information Commissioner that are designed to provide adequate safeguards for your personal information.
9. What rights do you have?
9.1 If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete it or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g., marketing).
9.2 You may also have the right to object to use of your personal information in certain circumstances.
9.3 If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).
9.4 For more information about your rights, visit the ICO’s website: www.ico.org.uk.
10. What about cookies?
10.1 We and/or other companies use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your web browser. Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Some are temporary “session” cookies that remain in the cookie file of your browser only until your browser is closed. Whereas persistent cookies stay for longer (depending on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete existing cookies, visit: www.allaboutcookies.org Our site’s functionality will be limited if you configure your browser to reject cookies.
10.2 We ourselves may place the following types of cookies:
Type of cookie Purpose
Authentication Identify and authenticate you to help you move easily through the site
Cookie notice Store your response to our cookie notice
10.3 Companies which provide us with a service also place cookies. Some of these cookies (e.g., from Google) may involve certain information, such as your name and contact details and/or the IP and web address of the page you’re visiting, being sent to the company concerned. Below is a summary of the kinds of cookies used together with details about who places them and where you can go to get more information and to opt out (where possible):
· Analytics cookies: These kinds of cookies recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and where the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily. These cookies are provided by:
· Google Analytics (“GA”).
More information:
Google’s overview of GA data practices and safeguarding - https://support.google.com/analytics/answer/6004245
How to specifically opt out from GA cookies -
https://tools.google.com/dlpage/gaoptout/
Google’s use of its partners’ data -
https://policies.google.com/technologies/partner-sites
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