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THIRD SPACE LEARNING PRIVACY AND COOKIES POLICY

Introduction

This is the privacy and cookies policy for www.ThirdSpaceLearning.com (Website). The Website is operated by [Virtual Class Limited (trading as Third Space Learning) whose registered office address is at 14-22 Elder Street, London, E1 6BT, with registered company number 08260115] (Third Space Learning, we, us and our).

At Third Space Learning, we are very conscious about protecting the safety of the students and other users that we support and are aware that online learning, and the 1-to-1 support that online learning facilitates, demands that we are rigorous in terms of how we vet our tutors, and how we protect personal data

This privacy policy explains how we collect information, what we do with it and what controls you have over your information.

By using the Website and its services, you consent to the collection and use of information in accordance with this privacy policy.

We reserve the right to change this privacy policy from time to time by changing it on the Website. This privacy policy was last updated on 18th February 2016. Your continued use of the Website and/or continued provision of Personal Information to us will be subject to the terms of the then-current Privacy Policy

Personal Information we may collect from you

When you visit the Website or use our Service, we request that you provide Personal Information about yourself, this refers to any information that you voluntarily submit to us and that identifies you personally, including contact information and information about yourself or your business. Personal Information can also include information about any transactions (including free transactions) that you enter into on the Website, and information about you that is available on the internet, or publicly available information that we acquire from service providers. We may collect and process the following Personal Information:

Information (such as name, email address, school, teaching position and information relating to your students such as name, age, gender and academic school year) which may be provided by completing forms on the Website, including if you register as a user of the Website, upload or submit any material via the Website, or request any information from us;

  • in connection with an account sign-in facility, your log-in and password details;
  • details of any online class (“Sessions”) booking requests made by you through the Website for students;
  • communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Website or its content;
  • information from surveys and/or promotions that we may, from time to time, run on the Website, if you choose to respond to, or participate in, them;
  • information that you post in the form of comments relating to student’s academic capabilities to tutors in advance of a student attending a Session. This information allows our tutors to provide students with tailored Sessions suited to a student’s particular educational needs;
  • recordings of the Sessions (onscreen interaction and live conversations between students and the tutors) during Sessions. This provides students with a library of their sessions to support future learning, whilst giving teachers transparency on all 1-to-1 support. It also allows us to monitor quality, and provides us with an important tool for on-going Continuing Professional Development for our tutors.
  • our tutor’s record of students’ performance and progress.

Navigational Information we may collect from you

We may also collect and process navigational information. This refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.

Information collected from students

If you are a student, you may only use this Website and provide personal information if you are authorised and supervised by your teacher and your parent or guardian to do so.

We will limit the amount of information we collect about students (in addition to the information already provided to us by a student’s teacher) to no more than is necessary for the specified activity. This may include recording the Sessions attended by students to monitor training standards and compliance by tutors with Third Space Learning’ guidelines and for tracking and monitoring student performance in order to provide feedback on student progression to schools.

Uses made of your information

We use the information we collect only in compliance with this Privacy Policy. We will use the Personal Information that you provide us with to:

  • identify you when you sign-in to your account;
  • enable us to process your Session booking requests and to provide you with the services and information offered through the Website and which you request;
  • administer your account with us;
  • tailor Sessions to suit student’s educational needs;
  • provide feedback to schools on student performance during Sessions to allow schools to monitor and track progression performance;
  • establish whether Sessions have been attended as required by students;
  • analyse the use of the Website and the people visiting in order to improve our content and services;
  • send you information we think you may find useful or which you have requested from us, including receipt of marketing communications such as our periodic newsletter provided you have indicated that you are happy to be contacted for these purposes;

We use Navigational Information to operate and improve the Website and the Service. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalised information about Third Space Learning.

We will never sell your Personal Information to any third party.

To Unsubscribe from our communications

You can tell us not to contact you with information regarding our products and services, either at the point such information is collected on the Website or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise this right at any time by contacting us using the contacting us details at the end of this privacy policy.

Tutor vetting

Tutors are provided to us by our academic partners and contractors. All tutors are required to go through our rigorous training and vetting processes (developed in conjunction with the Institute of Education).

As a part of our training and vetting process, we have taken steps to ensure that:

  • Police Clearance Certificates and security certificates for the country within which tutors are located are obtained for all tutors as well as any necessary and relevant degree certification;
  • English for Speakers of Other Languages (“ESOL”) courses and accompanying certification is obtained for all tutors;
  • tutors operate under the management of Third Space Learning’s academic and operational staff. All tutors must demonstrate to our satisfaction that they meet and comply with our stringent academic standards and requirements before we allow them to teach any Sessions. We frequently carry out audit checks on tutors to ensure the continuing compliance of tutors with our academic standards and requirements;
  • all Sessions are recorded and stored by us and may only be accessed by teachers and limited Third Space Learning personnel;
  • tutors have no access to student data other than academic requirements directed by the students’ teacher;
  • students are only permitted to deal with tutors when directed to attend sessions by their teachers. Students may not book Sessions or gain any other access rights in respect of the services themselves.

Additional information

When you visit the Website, we may automatically collect additional information about you, such as the type of internet browser or mobile device you use, any website from which you have come to the Website and your IP address (the unique address which identifies your device on the internet) and your operating system, which are automatically recognised by our web server. You cannot be identified from this information and it is only used to assist us in providing an effective service on the Website and to collect broad demographic information for aggregate use.

We also aggregate and anonymize data on the performance of students, allowing us to track standards and performance development across different age groups, geographies and other categories of student. We may collate and use such aggregated data to improve the Service for all students and we do not release or otherwise use this data outside of Third Space Learning. No student will be identifiable directly or indirectly from the aggregated data.

Cookies and similar technology

The Website also uses cookies or similar technology to collect information about your access to the Website.

Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you. Cookies are uniquely assigned to you, and can only be read by a Web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Website and will last for longer. Cookies are not used to run programs or deliver viruses to your computer.

We use cookies to:

  • remember that you have used the Website before. This means we can identify the number of unique visitors we receive and allows us to make sure that we have enough capacity for the number of users we get;
  • allow you to navigate the Website more quickly and easily;
  • remember your login session so you can move from one page to another within the Website;
  • store your preferences;
  • customise elements of the layout and/or content of the pages of the Website for you;
  • collect statistical information about how you use the Website so that we can improve the Website

Some of the cookies used on our Website are set by us and some are set by third parties who are delivering services on our behalf

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the Website (as the case may be).

We also sometimes use third party analytics tools which may introduce web beacons. These help us better manage our Website and Service, informing us what content is effective by monitoring users on their journey around our site. These tools may also be used in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We may tie the information gathered by clear gifs in emails to our customers' Personal Information

Third Party Tracking Technologies

We monitor users on their journey around our site. We sometimes use third party analytics tools which may introduce web beacons. This is to enable us to further improve your use and the functionality of our Website.

The use of cookies and web beacons by any tracking utility company is not covered by our privacy statement. We do not have access or control over these third party tracking technologies.

Information sharing

We may disclose your personal information to our tutors, to any of our academic partners, or to our agents or contractors who assist us in providing the services you have requested from us through the Website, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions, and they are required to maintain the confidentiality of your information.

In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.

We may disclose your personal information if legally entitled or required to do so (for example if required by law or by a Court order or if we believe that such action is necessary to prevent fraud or cyber crime or to protect the Website or the rights, property or personal safety of any person).

External links

The Website may, from time to time, contain links to external Websites. Our provision of such links does not constitute our endorsement of these other websites. We do not control, and are not responsible for, the privacy policies, the content or the practices of such Websites. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

Security

We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and we secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure so that only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Website whilst it is in transit over the internet and any such submission is at your own risk.

It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.

Data storage and international transfers

Information that you submit via the Website may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if one or more of our service providers are located in a country outside the EEA. If we transfer your information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected. By submitting information via the Website you agree to this storing, processing and/or transfer.

In addition, if you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

Retention of Personal Information

We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about the Service we provide, and then we securely delete the information. We will delete this information from the servers at an earlier date if you so request. Please use the contact details at the end of this Policy to do this.

Your rights

You have a legal right under the Data Protection Act 1998 to a copy of all the personal information about you held by us. On request, we will provide you with a copy of this information subject to a fee not exceeding the prescribed fee permitted by law. You also have a right to correct any errors, outdated information, or omissions in that information. As mentioned above, you have a right to prevent the use of your personal information for direct marketing purposes. To exercise any of these rights, please contact us using the information provided below this Policy.

Contacting us

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data to us by any of the following means:

via the Website; by email at: teacher@thirdspacelearning.com;

by post to: Third Space Learning, 14-22 Elder Street, London, E1 6BT