Last updated on 16 September 2018
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
HandUp Learning LIMITED (is the controller and responsible for your personal data), (company number 11507564) whose registered office is at Kemp House 152-160 City Road, London EC1V 2NX.
You have the legal 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).
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified, directly from the information in question; or indirectly identified from that information in combination with other information. It does not include data where the identity has been removed (anonymous data). When you sign-up to HandUp Learning as a user, we will collect personal information about you (such as your name, e-mail address, and telephone number).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offences.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect personal data including:
You may give us your Identity, Contact and/or Financial Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
Automated technologies or interactions:
As you interact with our website or app(s), we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please contact us for further details and information about this at firstname.lastname@example.org.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data in compliance with UK data protection laws and GDPR. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
Further information on the legal basis for processing personal data:
In accordance with The Data Protection Act 2018 and Article 6 (1) GDPR, Processing shall be lawful only if and to the extent that at least one of the following applies:
1. The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
2. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
3. Processing is necessary for compliance with a legal obligation to which the controller is subject;
4. Processing is necessary in order to protect the vital interests of the data subject or of another natural person;
5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
6. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
In the below table you can see the ways in which we will use data, the type of data being used and the legal basis for using this data including our legitimate interests where applicable. Please note, more than one basis could be relied upon depending upon the specific purpose the data is being used for. You can contact us at, if you would like to clarify which ground we are relying upon for processing personal data where there may be more than one ground.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your subscription including:
(a) Performance of a contract with you
To manage our relationship with you which will include:
(a) Performance of a contract with you
To enable you to partake in a Promotion
(a) Performance of a contract with you
To administer and protect our business and this website and our apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
To deliver relevant website and app content, and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, app(s) products/services, marketing, customer relationships and experiences
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and app(s) updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about features that may be of interest to you
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
To deliver learning content to you and measure the effectiveness of that content
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to keep our product/services up to date and relevant, to provide personalised feedback to individual users)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details and in all cases have opted in to do so.
We do not share your personal data with any company for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us as firstname.lastname@example.org.
We endeavour to make the opt out process as simple as possible. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or a service experience.
A cookie is a small text file that is stored on your computer and allows the Company to identify you as a unique user but does not contain information that personally identifies you. This allows us to improve your experience of HandUp Learning. This website may make use of "cookies" in order to:
We use the following cookies in the Website:
1. Essential Cookies - These cookies are essential for the running of the Website or the Service. Without the use of these cookies parts of the Website or the Service would not function.
2. Analytical Performance Cookies - We use these types of cookies to monitor the Website or the Service performance. These cookies provide us with information that helps us provide a better service.
3. Functional Cookies - Functional cookies are used to remember your preferences on the Website or Service.
You are not obliged to accept cookies and may modify your browser so that it will not accept cookies. The browser you use to surf the web not only allows you to see the cookies that you have got but also allows you to control their use. You can control them by allowing them, deleting them individually or deleting all of them. You can also set your browser to not accept cookies altogether. If this option is selected, you should be aware that the Website or the Service will not function properly or at all. It may be possible to set your browser to not accept cookies and ask for your consent before each cookie is set on your device.
8. CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at Hello@handuplearning.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
9. DISCLOSURES OF YOUR PERSONAL DATA
We will treat your personal data confidentially at all times subject to circumstances in which we are required to disclose or share it as outlined in our purposes for processing personal data in the above table. We may have to share your personal data with the parties set out below:
We may provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you.
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.
10. INTERNATIONAL TRANSFERS
11. DATA SECURITY
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
You have the right, in some circumstances to ask us to delete your data: further information on request erasure below
In some circumstances we may 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.
Once we no longer require your personal data for the processing purposes outlined above, we will ensure that we securely dispose of it.
13. YOUR LEGAL RIGHTS
Data protection legislation gives you the right to know what information HandUp Learning holds about you and how it is used as set out above. You also have a number of rights in relation to this personal data that you may provide us with for our data processing activities.
You have the right to:
You are able to exercise any of your rights above by contacting us and informing us at email@example.com of your decision to exercise the relevant right. Please note the above rights are not absolute and are subject to conditions stipulated within GDPR and other statutory limitations which might apply under UK legislation.
14. 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.
15. TIME LIMIT TO RESPOND
An individual can make a legitimate request verbally or in writing. We have one calendar month to respond to such a request. If you wish to make a personal data request, get in touch with us regarding any queries or concerns about our privacy practices or file a complaint with us, we are contactable at firstname.lastname@example.org. If a request is particularly complex or a number of requests have been made, it may take us longer than a month to respond to. However, we will inform you if this happens and keep you updated. If a request is not legitimate, repetitive or excessive we may refuse to comply or charge a reasonable fee in order to respond.
16. GENERAL CONSENT
Please note that sometimes on particular web pages on HandUp Learning we will require you to provide additional personal information. When we do this, we will specify further on these web pages why we are collecting your information and how we will use it.
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 at email@example.com.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
18. HOW TO CONTACT US