This policy applies to information we collect when you choose to use our App or subscribe on behalf of someone else.
This App is owned by Arc Education (York) Ltd (‘ARC’) and our registered office is at Blake House, 18 Blake Street, York, YO1 8QG, United Kingdom. ARC (‘we’ or ‘us’) are a ‘data processor’ for the purposes of the General Data Protection Regulation (‘GDPR’) as we process personal data on behalf of our users and, in some cases, their school or college (‘educational institution’).
Any questions about our data protection policy or how we handle your personal data should be emailed to firstname.lastname@example.org (See ‘How to contact us’ below).
For all our users, the personal information that we collect and store includes first name, surname and email address. When an account is created, we ask for a password for the account.
If the subscription has been paid for by users’ educational institution, we also collect and store additional information such as gender, month and year of birth and an institution code which enables us to link the institution name to that account.
We also collect performance data as described below.
We do not hold any special category data.
Parents/Guardians: If your child is a user and has been enrolled by their educational institution, we require that the educational institution has either obtained your consent, or the child’s consent directly (if over 13), to the use and storage of the child’s personal data (referred to above).
Users/Children: If you are a private user aged of 13 or over, by agreeing to our terms you agree to us using and storing your personal data (as referred to above). If you are a private user below the age of 13, we assume that parental/guardian consent has been obtained on the basis of the family sharing and ask to buy functions installed on iOS. If these functions have been disabled by the parent/guardian, then the parent/guardian assumes all responsibility for consenting to the storage of their child’s personal data.
We collect performance data in accordance with the user’s engagement with the App. This includes the
If your account is paid for by an educational institution, then your teachers will be able to access your personal data and performance data.
We share your personal information with our developer in order to help us improve the App.
We may also send information to universities for research purposes; however they will not be able to access any personal data, only anonymised performance data.
We may send your personal information to law enforcement agencies, where requested or required by law, in connection with any investigation to help prevent unlawful activity.
We do not send your personal data outside the EEA.
We process personal information about you so that we can:
We only send emails to users regarding their progression through the levels of our App. We may also send details of our related services to private users or to contacts at educational institutions. We do not send marketing emails to users who have been enrolled by their educational institution.
We will only process your personal data where we have a legal basis for doing so.
Most of the processing we carry out in relation to your personal data is done in order to supply you with the service offered by the App.
Where we use your personal data for any purpose other than to facilitate your use of the App, we have a legitimate interest to do so. We will not process personal data on this basis if we have any doubt that your rights might be adversely affected. We also revisit this assessment regularly and update our procedures according to our findings.
Our staff and associates are bound by obligations of confidentiality and trained in the protection of personal data. We will take all reasonable steps to comply with the GDPR and use the appropriate technical and organisational measures necessary to safeguard your personal data. We only share your personal data with third parties who are required to comply with the GDPR.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How to contact us’ below).
We store your personal data on secure servers for a period of:
or, in each case, unless the law requires us to store the data for a longer period.
The GDPR provides the following rights for individuals whose personal data is processed:
If you have any concerns or complaints about how we use your personal data we hope you will alert us to these directly (see ‘How to contact us’ below). You are entitled to complain to the Information Commissioners Office (ICO) which is the supervisory authority in the UK. Their contact details and the procedure can be found at www.ico.gov.uk.
If you wish to contact us about any other matter, please send an email to email@example.com or write to us at Arc Education, Blake House, 18 Blake Street, York, YO1 8QG, United Kingdom.
Arc Education (York) Ltd February 2020
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