WHO WE ARE
We are Virtual Class Ltd (trading as Third Space Learning). Our contact and other details are set out at the end of this policy. We are the data controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).
We provide personalised 1-to-1 maths lessons to children via our secure online classroom, together with access to high quality primary maths teaching resources and up-to-date continuing professional development modules for teachers through our online learning hub. We also, from time to time, provide free access to resources, blog posts and articles to teachers and parents via our social media platforms. We provide our services primarily to schools for the benefit of the teachers and children at the schools concerned, but we may also provide them to individual parents for the benefit of their children
THE PURPOSES FOR WHICH WE COLLECT AND PROCESS PERSONAL DATA
We collect and process personal data as follows:
If you are a teacher (or other member of staff) at a school to which we provide services or if you register on our online learning hub to access the resources available on it
We may collect: your individual contact information, including your name, school name and address, your e-mail address, your role/job title the school, a contact telephone number (which may be your personal mobile number should you choose to give it to us); your PPA timetable availability and the user ID we assign you; in order to enable us, our group companies or other suppliers of ours or our group companies to communicate with you in relation to the provision of our services to you or the school that you work for (for example, in relation to the management and administration of the provision of the relevant services).
We may also collect other personal information relating to you to in the course of provision of the services concerned, which may include, for example, information relating to the school year/age groups you teach, your experience, material that you access via our learning hub and other information relating to you that is included in any communications between us and you or the school where you work in the course of provision of our services.
We may also collect publicly available information about you or information about you we may acquire from service providers or educational information providers.
If we provide services to you as an individual in relation to your children
We may collect your individual contact information (including your name, your user ID, your address and other similar details) to enable us, our group companies or other suppliers of ours or our group companies to communicate with you in relation to the provision of services to you (for example, in relation to the management and administration of the provision of the relevant services) and other personal information relating to you to in the course of provision of the services concerned.
We will not process any bank account, credit card or other financial details relating to you, as we transfer you to secure third party service providers to process any relevant payments and do not process the payments ourselves.
We may also process any other information relating to you that is included in any communications between us and you in the course of provision of the services.
If you are a child to whom we provide our one-to-one online maths lessons (or a teacher or a parent of such a child who wishes to know what information we process relating to children to whom we provide tutoring)
We may collect information about the child necessary to enable us to deliver the lessons to the child, including name, age, gender, academic school year, educational needs and capabilities, information about any relevant medical or learning needs or other special needs that we may need to take account of in providing the lessons to the child. The information about the child will normally be provided by the child’s school or parent, except to the extent that the child itself provides any information during the tutoring session.
We limit the amount of information we collect a child (in additional to the information provided by the child’s school or parent) to no more than is necessary to deliver the service.
All online lessons that we provide are recorded (on-screen interaction and live conversations between the child and tutor) and the recordings are used by us to monitor and track the child’s progress and to provide feedback on progression and performance, the quality of the teaching provided, compliance by tutors with our guidelines, and other factors relevant to the teaching. We also store the recordings for archival purposes. The recordings also provide us with a tool for on-going continual professional development for our tutors and enable us to improve the services provided and enhance educational outcomes through conducting analysis and research into sessions and outcomes.
When we conduct analysis and research we aggregate and anonymize data. We analyse and track standards and performance development across different age groups, geographies and other categories of student and no student will be identifiable directly or indirectly from the aggregated data.
If you request information about, or a demonstration or free trial of, our services
We may collect your individual contact details, including your name, school name and address, your e-mail address, your role/job title the school, a contact telephone number (which may be your personal mobile number should you choose to give it to us) in order to arrange a demonstration or free trial. We may also combine this with other information we obtain about the things you are interested in and that are relevant to the services provided by us (for example, when you use our services or browse our website and view particular content) in order to help us ensure that any relevant marketing material that we send you is relevant to what you are interested in.
If we wish to send you advertising, marketing or promotional material
We may collect your individual contact details in order to send you direct marketing material in order to advertise, market or promote our services. We may combine this with other information we obtain about the things you are interested in and that are relevant to the services provided by us (for example, when you use our services or browse our website and view particular content) in order to help us ensure that any marketing material that we send you is relevant to what you are interested in.
If you provide goods or services (or you work for someone who supplies goods or services) to us.
We may collect your individual contact information to enable us, our group companies or other suppliers of ours or our group companies to communicate with you in relation to the provision of goods or services by you or the person that you work for (for example, in relation to the management and administration of the provision of the relevant goods or services) and other personal information relating to you to in the course of provision of the goods or services concerned. This may include, for example, bank account or other financial details, personal description and photograph, and other information relating to you that is included in any communications between us and you or anyone you work with in the course of provision of the goods or services.
If we are assessing your suitability or ability to provide goods or services to us or to any of our group companies
We may collect relevant personal information relating to you to the extent necessary to enable that assessment to take place – for example, if we need to assess or confirm your age, your right to work in the UK, your skills and previous experience, your qualifications or whether there is anything (for example, relating to your past history, your health or your conduct or reputation) that would adversely affect your suitability or ability to provide the goods or services concerned. This will be explained to you in more detail at the time we collect the personal data and, where appropriate, will be subject to your prior consent.
If you are invited to, or attend, an event organised or managed by us
We may collect your individual contact and related information (as well as that of anyone who is attending the event with you) as necessary to enable you and any other relevant individuals to be invited to, and to attend, the event and to facilitate your attendance (for example, dietary or special access requirements).
If you register to use or browse any of our online learning hubs, websites or social media platforms
If you apply for a position with us (including as a tutor)
We may collect personal information in relation to you in connection with any application by you for a position with us. In that case, we will explain in more detail at the time how and for what purposes we intend to process the relevant personal information.
If you respond to or complete a survey we have sent you or published on our website
In responding to surveys carried out on our behalf (or to relevant survey invitations), you may disclose information that could make you personally identifiable to the third party entities carrying out the survey on our behalf or to us. You will, in advance of completing the survey, be told what identifiable information (if any) will be disclosed to us. We may use feedback you have given us from customer experience surveys (Ask Nicely for example) to help resolve issues or problems that you may be having to improve the service we deliver to you and to improve the service generally. For more detailed information concerning the protection of privacy when responding to surveys or survey invitations, you should contact the entity conducting the survey.
WHERE WE PROCESS YOUR PERSONAL DATA
We are established in the UK and the systems which we use to process your personal data are hosted here or elsewhere in the EU.
Our 1-to-1 maths lessons are provided by tutors in India and Sri Lanka, who are employed either by another company in the same group as us or by a supplier to us. In order to provide the lessons, the tutors use our learning platform which is hosted by Amazon Web Services (AWS) in the UK or the EU and all relevant data is processed and stored on that platform. During delivery of lessons, the data is held on AWS’s servers in India until the end of the lesson, when it is automatically uploaded on AWS in the UK or the EU and deleted from the server in India.
We use a number of third-party service providers to provide data monitoring and analytic tools, which may require them to access or use information about you. A number of the third party service providers are located in the US and hold data for between 6 and 15 months before deleting the data.
Where necessary in order to manage our business, we may share relevant personal data with our group companies or suppliers outside the EU, but only to the extent necessary in order to provide the services concerned.
Where personal data is transferred in relation to providing our services we will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism which may include by entering into EC approved standard contractual clauses relevant to transfers of personal information – see:
SECURITY OF YOUR PERSONAL DATA
All personal data processed by us is stored securely (the level of security being appropriate to the nature of the data concerned and the other relevant circumstances). We use a range of organisational and technical security measures to protect your information.
Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and to use a password that is appropriate (i.e. a mixture of upper and lower case letters, and characters, which isn’t used on other sites and isn’t easily guessed).
Schools are responsible for setting up staff members and granting them access to the platform and online learning hub. It is the responsibility of the School to ensure that only authorised persons have access to personal data. Once a teacher leaves the school or ceases to be involved in the service, the school should remove access to the service and online learning hub. We cannot be responsible for unauthorised access caused by failure of a school to remove a teacher’s access.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.
WHO WE SHARE YOUR PERSONAL DATA WITH
We may where appropriate share your personal data with:
- Any member of our group, which means our subsidiaries, our holding company and its subsidiaries.
- Appropriate third parties including:
- our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
- third-party service providers who provide website and application development, hosting, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information;
- our auditors, legal advisors and other professional advisors or service providers;
- credit or other similar reference agencies for the purpose of assessing your suitability or ability where this is in the context of us entering (or proposing to enter) into a contract with you or the person that you work for.
- In relation to information obtained via our website:
- our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy;
- analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.
OTHER DISCLOSURES WE MAY MAKE
We may disclose your personal data to third parties:
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you or the person that you work for; or to protect the rights, property, or safety of our business, our group companies, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, or credit risk reduction.
THE LEGAL BASIS FOR OUR PROCESSING OF PERSONAL DATA
The legal basis on which we process your personal data is as follows:
- Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned (in relation to any processing we are carrying out with your consent, see below for how to withdraw your consent). If you are a child, we take the provision by a teacher at your school or your parent, of personal information about you as confirmation of consent.
- Otherwise, we will process your personal data where the processing is necessary:
- for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
- for compliance with a legal obligation to which we are a subject; or
- for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data (most circumstances in which we process your personal data in relation to a relationship that we have with the person that you work for will fall into this category).
HOW LONG WE KEEP YOUR PERSONAL DATA
We process personal data only for so long as is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.
You have the following rights in relation to personal data relating to you that we process:
- You may request access to the personal data concerned.
- You may request that incorrect personal data that we are processing be rectified.
- In certain circumstances (normally where it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
- Where we are processing your personal data for marketing purposes or otherwise based on our legitimate interests, you may in certain circumstances have a right to object to that processing.
- Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent, after which we shall stop the processing concerned.
To exercise any of your rights (including withdrawing relevant consents or obtaining access to your personal data), you should contact us as set out below.
If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal compliant with the Information Commissioner.
CONTACTING THE REGULATOR
The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Our contact details are:
Virtual Class Ltd (or Third Space Learning)
4th Floor Frazer House
32-38 Leman Street
Contact: Company Secretary
Phone: 020 3794 2736.
UPDATES TO THIS POLICY
DATE OF THIS POLICY
This policy was last updated on 18 May 2018