PRIVACY NOTICE

This privacy notice (Privacy Notice) sets out the ways in which Komodo Learning Ltd (we, us, our) collect, use and share your personal data (your information) in connection with our publishing business. It also explains what rights you have to access or change your personal data.

Komodo Learning Ltd publishes digital teaching and learning resources including on-line resources via on-line platforms such as Komodo Maths and the Kickstart Maths Quiz system.

This policy applies to the processing of your information by Komodo Learning Ltd as data controller. The data controller decides how your information is used and protected. We take your privacy and our responsibility to protect your information seriously and will take care in use and handling of your personal data.  Read our privacy notice to understand:

• Who we are

• Children

• What information we collect about you

• How we use information we collect about you

• Who can see your information

• When we share your information

• How we look after your information

• How long we keep your information

• The cookies we use

• International Transfers of your information

• Rights and choices

WHO WE ARE

The Komodo Learning Ltd is a company registered in Northern Ireland (UK)  under company number, 206386904 with our registered address as set out below. 

FAO:     HEAD OF DATA PROTECTION

Address:   109-113 Royal Avenue, Belfast BT1 1FF, UK

Email:     ged@komodomath.com

CHILDREN

Komodo Learning Ltd websites are not directed at children. They are intended for adults ( teachers and parents ). Where any Komodo Learning Ltd digital platforms (such as Komodo Maths and Kickstart ) process information about children under 13, we will ensure that the required parental consent has been obtained directly from parents during sign up to our digital services or by the schools if they provide us such personal information.

WHAT INFORMATION WE COLLECT ABOUT YOU

Information you provide

During your interaction with us, whether via our websites, by email, through completion of surveys, use of our apps or by any other means, you may provide information to us which might include [such as] your name, address, gender, email address, phone number, birthday, twitter handle, the type of device you use to connect to the internet, and the subjects you are interested in, in order to provide you with information or reply to your queries. If you are creating an account you will provide a password and if you are ordering products or services from us you will provide your payment details. 

Schools:

If you are a pupil and your school or college has provided information about you to us which we will process on your school’s behalf or for the purposes of providing services to you.

Learners, Parents

This information about you as a learner may include your contact details, your age and date of birth, your gender and any further information your parent has provided to help us assign appropriately personalised learning.

We collect your information when you:

• create an account in our website;

• subscribe to or accept access to  one of our digital platforms such as Komodo maths and Kickstart

• are added as a teacher user to Komodo maths and Kickstart  our digital platform by one of your teacher colleagues   

• subscribe to our newsletters

• apply for technical support assistance 

• interact or correspond with us by  letter, phone, SMS, email or via our website

• complete one of our surveys

• use our mobile devices or website applications (apps)

• sign up to  attend events we hold or interact with us in person

• submit contributions to our publications by post or via our website or our contact form

• enter into a contract with us to publish an article or ebook

• enter a prize competition or draw

• submit  permission requests 

Protection of Personal Data

We will take all reasonable precautions to ensure that all the personal data that is submitted to us for the purposes above remains secure and have procedures to protect the storage and disclosure of personal data. You must ensure passwords are not shared and are kept securely. You are responsible for ensuring that personal data is transferred to us securely from your device.  

Cookies and how you use our website and apps.

We also collect certain information about how you use our website and apps and the device that you use to access them. This includes your IP address, geographical location, device information (such as your hardware model, mobile network  information , unique  device identifiers) browser type, referral source, length of visit to the website , number of page reviews, the search queries you make on the website and similar information. This information is collected by Google Analytics on our behalf and by some of our apps using cookies. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout. For more information on cookies please read our Cookies Policy. 

Our website may include links to third party websites. By clicking on those links or enabling these connections you may allow third parties to collect or share data about you. We do not control these websites and are not responsible for their privacy notices. Please ensure that you read the privacy notices on any such external websites.

Information we receive from third parties

In certain circumstances, we will receive information about you from third parties. For example: 

• If you are a job applicant we may contact your referees to provide information about you;

• We may receive pupil information from schools and other institutions. In this case we expect schools to have informed parents or guardians of the processing activity we are undertaking of pupil data and to have obtained their consent when they share such personal data with us.    

HOW WE USE INFORMATION ABOUT YOU

We use your information lawfully. We do not sell your information to third parties. 

However we may share your information as set out in the section 'When We Share Your Information'. The details of how we use your information and the legal bases for our use are set out below:

We may use such personal data collected to:

• process your request, for example, to purchase products or access services and to administer your account

• communicate with you and provide information about our products and services 

• send you marketing communications about products, services, activities, promotions or other matters that we feel may be of interest or use to you

• contact you about products you have bought or services you have subscribed to

• communicate with you and your school to provide support services

• analyse your use of our websites, our apps and response to our communications and improve the services we offer, including personalising our communications with you.

Pupil Information

If you are a pupil your school will have provided information about you to us which will process on its behalf in order to:

• support your learning

• monitor and report on your progress

• assess the quality of our services

We will process your data for these purposes in accordance with instructions from your school and will report on the outcome of our services to your school.  We will not give information to any third parties (other than contractors providing services to us with whom we have an agreement) without the consent of your school.  Where possible we will anonymise personal data.

Teachers/Tutors

If you are a teacher or staff of a School or college, we will process your information provided to us by your School or by you:

• to support you teaching and use of any digital platform products  

• to process any orders you make for products and services on behalf of the School or Institution or on your own behalf as the case may be.

• Obtain feedback from you in surveys relating to our products and services/ educational topics

When we have your consent to contact you, we may use your information to:

• to keep in contact with you and provide you with marketing communications about our news and new products that we believe may interest you;

• tell you about new website features or services;

• send you newsletters;

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you, particularly where we process children’s personal data.  Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing you have rights and choices which include the right to object (please see the section headed ‘Your Rights and Choices’).

We may use your information for the purposes listed below on the basis of our legitimate interests:

• to contact you about products you bought from us;

• to contact you about submissions you made or content you provided to us;

• to respond to your queries and correspondence;

• to collect and store accurate data of our customers 

• to administer your account with us;

• to deal with enquiries or complaints  as necessary to provide customer support in providing the correct products and services to our website users;

• to carry out aggregated and anonymised research about general engagement with our website  in providing the right kinds of products and services to our website users; 

• to measure or understand the effectiveness of advertising;

• to deliver relevant advertising and make relevant recommendations and suggestions to you about our products and services;

• to analyse your use of our websites and apps and your responses to our communications;

• to personalise, enhance, modify or otherwise improve the services and/or communications that we provide to you; 

• to create our educational analysis tools

• to mark assessment tests

• to prepare aggregated benchmarks for the purpose of building educational tools and performance indicators  from the results of anonymised data

• to detect and prevent fraud and unauthorised access or illegal activity;

• to  improve security and optimisation of our network sites and services including trouble-shooting, testing and software development and support;

• to operate a safe and lawful business or where we have a legal obligation; 

• to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees; 

• to process any job applications you submit to us 

WHO CAN SEE YOUR INFORMATION

Your information may be processed by our staff or by the staff of third parties we work with to deliver our business. Processing can mean any activity that involves the use of information about someone that can identify them. All uses, for example, obtaining, recording, storing, disclosing, organising, retrieving, deleting and destroying are types of data processing. We take measures to ensure that third parties processing your information on our behalf are acting lawfully in accordance with our instructions and are subject to appropriate confidentiality requirements. We also have adequate technical and organisational safeguards in place in our company and with third party processors to protect your information. Third party processors of your information include: 

• our website hosts and operators, IT support providers, database operators, site analytics providers and software developers; 

• specialist education research partners

• our financial services and payment service provider stripe.com;

• our customer service partner intercom.com

• our independent review partner reviews.com

• our warehousing and delivery service providers;

• our auditors, technical consultants and legal advisors;  

WHEN WE SHARE YOUR INFORMATION

Where we share your information outside Komodo Learning Ltd you will be asked to consent to a third party sharing your information and if you choose to give your permission any interaction you have with a third party is governed by their privacy terms. 

We will share your information with the following third parties:

• specialist education research partners  to help us create our educational analysis tools and products

• any prospective seller or buyer of  businesses or assets, only in the event that we decide to acquire, transfer or sell any business or assets;

• any other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law or where we have a legal obligation to do so

HOW WE LOOK AFTER YOUR INFORMATION 

We look for opportunities to minimise the amount of personal information we hold about you.  Where appropriate we anonymise and pseudonymise your information. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as: 

• ensuring the physical security of our offices, warehouses or other sites;

• ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;

• maintaining a data protection policy for, and delivering data protection training to, our employees;

• limiting access to your personal information to those in our company who need to use it in the course of their work and ensure it is kept behind a user password verification system.

You are responsible for ensuring that passwords are not shared and are kept securely.

HOW LONG WE KEEP IT FOR

We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our legitimate interests, such as for the purposes of exercising our legal rights or where we are permitted to do so for purposes of academic, literary expression and research purposes. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example:

• we archive our email and paper correspondence regularly and destroy unnecessary information;

• We operate a best practice email retention policy requiring password protected folders and departmental shared drives to provide restricted access to information;

• We conduct regular access reviews to keep access profiles and policies up to date;

• We conduct periodic review and purge cycles of documents in accordance with our document retention policy;

• we retain information relating to orders, refunds and customer queries for approximately 7 years;

• we retain information relating to commercial contracts for approximately 7 years after expiration or termination whichever is the sooner;

• we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently;

• in the case of Komodo maths, we will delete your account details 2 years after the end of your subscription period unless you request us to delete it earlier. 

• we delete information collected through marketing channels and information in  our customer relationship management system 2 years after our last interaction with you;

• we destroy CVs and related information from job applicants who have not been shortlisted for interview once the recruitment process is complete.  The shortlisted candidates’ CVs and related information is kept until after the successful candidate’s probation period, which can be 6 months from their start date. 

THE COOKIES WE USE

When you visit our website or use our apps we may send your browser a cookie. A cookie is a small file placed on your computer or mobile phone's browser that helps us recognise you when you return to our website or to the app and can tell us whether or not you've visited the site before. Your browser will tell us if you have these cookies, and if you don't, we may generate new ones. Cookies contain information which is transferred to your computer’s hard drive.

You can set your browser to refuse all or some browser cookies or to alert you when a website sets or uses cookies. You can disable cookies from our site at any time - all modern browsers allow you to change your cookies settings, and these settings will typically be found in the 'options' or 'preferences' menu of your browser. Please note, this may prevent areas of a website from working as intended.

The cookies we use are:

Essential cookies: these are required for us to operate the website. They include cookies that permit you to store items in an online shopping cart; allow you to log into secure parts of our site or make use of e-payment services.

Analytical/performance cookies: They allow us to recognise you and to count the number of visitors to our website and to  see how visitors move around our website; It improves the performance of our website  by ensuring that visitors can find what they are searching for easily and to speed up your searches.

Analytics & data collection cookies: Our website uses third party technologies to help us gather aggregate information about the user experience. The Site uses analytics tools (Google Analytics). Because of this, the web browsers used by our visitors automatically send certain information to Google. This includes, for example, the web address of the page that you’re visiting and your IP address. Google may also set cookies on your browser or read cookies that are already there. We do not share any of this information with any other third parties.

The information we collect allows us to better tailor our web experience to the interests of our visitors. This information may be used in aggregate form by Hachette to assess general user interest in our Site and the content on it. No personally identifying information is included in this type of reporting.

Functionality cookies: these allow us to recognise you when you return to the website after your first visit. It helps us to personalise content, to greet you by name and remember your preferences (such as language or country). They are used for statistical purposes.

Targeting advertisements cookies: These cookies record your visit to the website, links you have followed and pages you have visited. We will use this information to target information on our website and advertisements displayed on the website more relevant to your interests. We may share this information with third parties and other social media such as Facebook, Instagram for this purpose. Cookie profiling, also called web profiling, is the use of persistent or permanent cookies to track a user’s overall activity online.
When used in conjunction with our advertising services, such as those using the DoubleClick cookie, Google Analytics information is linked, by the Google Analytics customer or by Google, using Google technology, with information about visits to multiple sites.

The following table explains which cookies we may use and why:

INTERNATIONAL TRANSFERS OF YOUR INFORMATION

Our company is located in the UK. Your personal information is stored within the European Economic Area (EEA).

Special Information for Prospective employees / employees / freelance contributors

If you contribute as an author to one of our blog posts or ebooks, or are applying for a job with the company we may also collect information about your academic and work history, references and any other information you may choose to supply. Your information includes anything which identifies you so if you contribute to a blog or provide other user generated content to us it may include personal information.

If you provide us with more sensitive information this is known as Special Category (“Sensitive”) information and may include details about a person’s racial or ethnic origin, political opinions, religious, philosophical or similar beliefs, trade union membership, genetics, biometrics, health, sexual life, sexual orientation or about criminal offences or proceedings. This type of information will be treated differently and we will explain why we are collecting it and it will only be used with your explicit consent.

YOUR RIGHTS AND CHOICES

Your Right to Object

You have the right to object to our using your information for direct marketing and on the basis of our legitimate interests (refer to ‘How We Use Your Information’ above to see when we are relying on our legitimate interests). If you want to do this you can contact us using the details in the section 'Who We Are'.

Your Right to Withdraw Consent

The right to withdraw your consent for our use of your information in reliance of your consent (refer to section ‘How We Use Your Information’ to see when we are relying on your consent), which you can do by contacting us using any of the details in the section 'Who We Are'.

Your Other Rights and Choices

You also have other choices and rights in respect of the information that we hold about you, including: 

• the right to request access to the information that we hold about you to check that we are acting lawfully;

• the right to receive a copy of any information we hold about you in a structured, commonly-used, machine readable format or in another format of your choice;

• the right to request that we transfer your information to another service provider in a structured, commonly used, machine-readable format;

• the right to ask us to correct information we hold about you if it is inaccurate or incomplete;

• the right to ask us, in certain circumstances, to delete information we hold about you;

• the right to ask us, in certain circumstances, to restrict processing of your information.

You may exercise your rights and choices by contacting us using the details above 'Who We Are'.

You can also prevent processing for marketing activities by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing. 

Your Right to Complain

Please contact us if you have any questions or are unhappy about the way your information is used. We hope we will be able to resolve any problems or issues you may.

You also have the right to lodge a complaint about us and our use of your information to the UK Information Commissioner’s Office ( https://ico.org.uk/) or the relevant authority in your country of work or residence; 

CHANGES TO THIS PRIVACY NOTICE

We may make changes to this Privacy Notice from time to time. We will post any changes to our site.

This Privacy Notice was updated on 1st June 2018.