Last updated: May 25, 2018
Introduction to this Policy
This website is brought to you by Better Things Marketing Limited, trading as Promote Your School (“we”, “us” or “our”). We are a company registered in England and Wales under company number 7129407. We have our registered office address at 60 Glencoe Road, Bushey, Hertfordshire, WD23 3DS and our main trading address at 14 Rosebery Avenue, London EC1R 4TD.
We ask that you read this Policy carefully as it contains important terms about how we will use your information. By accessing or using the Site you agree to be bound by, and comply with, this Policy. Where you create an account on the Site you will also be required to indicate your consent to the processing of your Information as set out in this Policy. If you do not agree with or accept this Policy, you should stop using the Site immediately.
We may update this Policy from time to time in accordance with the “Changes to this Policy” section below.
References in this Policy to:
- “Data Protection Law” means: the Data Protection Act 1998 (until repealed) (“DPA”), the Data Protection Directive (95/46/EC) (until repealed) and, from 25 May 2018, the General Data Protection Regulation 2016/679 (“GDPR”) or any equivalent provision which may replace the GDPR following the formal political separation of the United Kingdom from the European Union; the Regulation of Investigatory Powers Act 2000; the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699); the Electronic Communications Data Protection Directive (2002/58/EC); the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003); and all applicable laws and regulations which may be in force from time to time relating to the processing of Personal Data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner or any other supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction; and
- “Personal Data”, “Data Controller”, “Data Processor” and “processing” shall have the meanings given to them in the DPA or, from 25 May 2018, the GDPR.
For the purposes of applicable Data Protection Law, we, Better Things Marketing Limited, trading as Promote Your School are the Data Controller and therefore we are responsible for, and control the processing of, your Personal Data in accordance with applicable Data Protection Law. “Personal Data” has a legal definition but, in brief, it refers to information from which a living person can be identified. Such information must be protected in accordance with Data Protection Law.
Information we may collect about you
We will collect information about you when you visit the Site or do business with us through the Site (including setting up accounts or ordering goods and services from us). This information may include your name, your contact details (including postal address, email address and telephone number), your payment details (i.e. relating to any payment you make to us in connection with our goods and services), any other information we request from time to time to enable us to provide the Site and our service to you, and any other information you provide to us (together the “Information”). Some of the Information may constitute or include Personal Data.
Occasionally we may receive information about you from other sources, which we will add to the information we already hold about you in order to help us provide goods and services and to improve and personalise our service via the Site to you.
Additionally we may collect information on your use of the Site, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, cookie information, and Internet Service Provider (“Usage Data”). Our purpose in collecting Usage Data is to better understand how our users use the Site.
Safety of Children and COPPA
Our services are not intended for and may not permissibly be used by individuals under the age of 13. We do not knowingly collect personal data from persons under 13 or allow them to register. If it comes to our attention that we have collected personal data from such a person, we may delete this information without notice. If you have reason to believe that this has occurred, please contact firstname.lastname@example.org.
How long we keep your information
We will keep your Information only for as long as we need to hold it for the purposes set out in this Policy.
However, if required we will be entitled to hold Information for longer periods in order to comply with our legal or regulatory obligations.
Legal basis for processing your information
From 25 May 2018, under applicable Data Protection Law we may only process your Information if we have a “legal basis” (i.e. a legally permitted reason) for doing so. For the purposes of this Policy, our legal basis for processing your Information is:
- your consent (for which see below); or
- subject to your rights set out below (see “Your Rights”), the legitimate interest of providing services to our users through the Site, which requires the processing of your Information to enable us to provide these services.
Your consent to processing
As noted above, you will be required to give consent to the processing of your Information as set out in this Policy. We will seek this consent from you when you first submit Information to or through the Site. If you do not consent to such processing you should not submit any Information to or through the Site.
If you have previously given consent you may freely withdraw such consent at any time. You can do this through your account on the Site or by notifying us in writing using our contact details below.
If you withdraw your consent, and if we do not have another legal basis for processing your information (see above), then we will stop processing your Information. If we do have another legal basis for processing your information then we may continue to do so subject to your legal rights (for which see “Your Rights” below).
Please note that if we need to process your Information in order to operate the Site and/or provide our services, and you object or do not consent to us processing your Information, the Site and/or those services may not be available to you.
How we use your Information
We will use your Information for the following purposes:
- to help us identify you and any user accounts you hold with us;
- administration of user accounts and any goods and services our users order from us;
- research, statistical analysis and behavioural analysis;
- to provide insights based on aggregated, anonymous data collected through the research and analysis referred to above;
- marketing (see ‘Marketing and opting out’ below);
- fraud prevention and detection;
- billing and order fulfilment;
- customising the Site and its content to your particular preferences;
- to notify you of any changes to the Site or to our services that may affect you;
- security vetting; and
- improving our services.
Marketing and opting out
We and our group companies may wish to provide you with information by email about special features of the Site or any of our other goods and services we think may be of interest. Where the content of this email regards products and services specifically related to the business/service you provide we will be contacting you under the criteria of Legitimate Interest. We may also provide you with information by email about special features of the Site or any of our other goods and services we think may be of interest by collecting your consent. If you would rather not receive this marketing information, or you no longer wish to receive it, you can always decline and/or opt out (see below).
If you have given permission, we may also want to contact you by email to provide you with information we think may be of interest to you from carefully selected third parties. Again, we will inform you (before collecting your data) and seek your permission if we intend to use your data for such purposes. If you would rather not receive such third party information from us, or you no longer wish to receive it, you can always decline and/or opt out (see below).
If you have given permission, we may share your personal data with carefully selected third party organisations and business partners and they may contact you directly (unless you have asked them not to do so) by email about goods and services that may be of interest to you. As above, we will inform you (before collecting your data) and seek your permission if we intend to disclose your data to third parties for such purposes. If you prefer not to receive direct marketing communications from our business partners, or you no longer wish to receive them, you can decline and/or opt out at any time (see below).
You have the right at any time to ask us, or any third party, to stop processing your Information for direct marketing purposes. If you wish to exercise this right, you should contact us by sending an email to email@example.com, or contact the relevant third party using their given contact details, giving us or them enough information to identify you and deal with your request. Alternatively you can follow the unsubscribe instructions in emails you receive from us or them.
Disclosure of your information
We may disclose your Information (including Personal Data) to:
- other companies within our group;
- our agents and service providers who help us to provide our services (and we will ensure they have appropriate measures in place to protect your Information);
- third parties you wish to allow to access to your Information through the Site;
- law enforcement agencies and/or HMRC in connection with any investigation to help prevent unlawful activity; and
- our business partners in accordance with the ‘Marketing and opting out’ section above.
- If our business is sold or integrated with another business your Information may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Site. In such circumstances we do not disclose any information which can identify you personally.
Keeping your Information secure
We will use technical and organisational measures in accordance with good industry practice to safeguard your Information. However, while we will use all reasonable efforts to safeguard your Information, 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 Information that is transferred from you or to you via the internet.
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance. Any information that we receive through such monitoring and communication will be added to the information we already hold about you and may also be used for the purposes listed in above.
Information about other individuals
If you give us information on behalf of a third party, you confirm that the third party has appointed you to act on his/her/their behalf and has agreed that you can:
- give consent on his/her/their behalf to the processing of his/her/their Information;
- receive on his/her/their behalf any data protection notices; and
- give consent to the transfer of his/her/their Information abroad (if applicable).
From time to time we may need to transfer your Information to countries outside the European Economic Area, which comprises the EU member states plus Norway, Iceland and Liechtenstein (‘EEA’). Such countries may not have similar protections in place regarding protection and use of your data as those set out in this Policy. Therefore, if we do transfer your Information to countries outside the EEA we will take reasonable steps in accordance with applicable Data Protection Law to ensure adequate protections are in place to protect the security of your Information.
By submitting your Information to us in accordance with this Policy you consent to these transfers for the purposes specified in this Policy.
If you are an individual, this section sets out your legal rights in respect of any of your Personal Data that we are holding and/or processing. If you wish to exercise any of your legal rights you should put your request in writing to us (using our contact details below) giving us enough information to identify you and respond to your request.
- You have the right (which up until 25 May 2018 may be subject to the payment of a small fee) to request information about Personal Data that we may hold and/or process about you, including: whether or not we are holding and/or processing your Personal Data; the extent of the Personal Data we are holding; and the purposes and extent of the processing.
- You have the right to have any inaccurate information we hold about you be corrected and/or updated. If any of the Information that you have provided changes, or if you become aware of any inaccuracies in such Information, please let us know in writing giving us enough information deal with the change or correction.
- You have the right in certain circumstances to request that we delete all Personal Data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the Personal Data for legal compliance purposes. If this is the case we will let you know.
- You have the right in certain circumstances to request that we restrict the processing of your Personal Data, for example where the Personal Data is inaccurate or where you have objected to the processing (see below).
- You have the right to request a copy of the Personal Data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you we will let you know.
- You have the right in certain circumstances to object to processing of your Personal Data. If so, we shall stop processing your Personal Data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests.
- You have the right in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you we will let you know.
- You have the right to object to direct marketing, for which see (‘Marketing and opting out’) above.
If you have any concerns about how we collect or process your Information then you have the right to lodge a complaint with a supervisory authority, which for the UK is the UK Information Commissioner’s Office (‘ICO’). Complaints can be submitted to the ICO through the ICO helpline by calling 0303 123 1113. Further information about reporting concerns to the ICO is available at https://ico.org.uk/concerns/.
- provide you with an enjoyable experience when you access the Site;
- create and access a login token;
- improve the Site; and
- compile statistical reports on visitors to the Site and activity on the Site.
Our software will issue cookies to your system when you access and use the Site and you will be asked to consent to this at the time (e.g. when you first visit the Site). Cookies do not affect your privacy and security since a cookie cannot read data off your system or read cookie files created by other sites. You can set your system not to accept cookies if you wish (for example by changing your browser settings so cookies are not accepted), however please note that some of the features of the Site may not function if you remove cookies from your system.
Changes to this Policy
We keep this Policy under regular review and may change it from time to time. If we change this Policy we will post the changes on this page, and place notices on other pages of the Site as applicable, so that you may be aware of the Information we collect and how we use it at all times. You are responsible for this Policy to ensure you are aware of the most recent version that will apply each time you access the Site. This Policy was last updated on May 25, 2018.
Links to other websites
The Site may contain links to other websites. This Policy only applies to the Site. If you access links to other websites any Information you provide to them will be subject to the privacy policies of those other websites.
This Policy aims to provide you with all relevant details about how we process your Information in a concise, transparent, intelligible and easily accessible form, using clear and plain language. If you have any difficulty in reading or understanding this Policy, or if you would like this Policy in another format (for example audio, large print or braille), please get in touch with us.
Our contact details
We welcome your feedback and questions. If you wish to contact us, please send an email to firstname.lastname@example.org or you can write to us at Better Things Marketing Limited, trading as Promote Your School, 14 Rosebery Avenue, London EC1R 4TD or call us on 020 7404 3400.