Harness Handitouch UK Private Limited (“we” “us” or “our”) are committed to protecting and respecting the privacy of the information and materials which we process through your use of the Unio By Harness platform (the “Platform”).
For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is Harness Handitouch UK Private Limited incorporated and registered in England and Wales with company number 09192382 whose registered office is at 24a Cranley Gardens, London, Greater London SW7 3DD.
Information which we collect from you
Information collected in connection with registration – Educational establishments and Teachers
We will collect and process the following data about teachers (which include any staff engaged by the educational establishment who utilise the Platform) in connection with registration for the Platform.
The information will be collected either from the person granted administrative rights on behalf of the educational establishment (if the Educational establishment has registered) or you as the individual teacher (where the individual teacher has registered).The information is collected from forms which are completed online in connection with the registration for the Platform or in connection with any correspondence with us by phone, e-mail or otherwise.
The information which may be collected includes your name, e-mail address, password, educational establishment name and location details, together with other optional information such as a contact number. Where relevant, financial and credit card information may also be collected.
Information collected in connection with sign-in – Students
The Platform enables the educational establishments and/or teacher to make the services on the Platform available to specific students. The students will be only be able to access a lesson on the Platform if the educational establishment/teacher has provided the student with the appropriate lesson ID access code and the student enters this and their first name.
The information which will be collected from students in connection with signing into the Platform will be a first name only. It is the responsibility of each Teacher User, (as such term is defined in our terms and conditions [insert link]), being an educational establishment or an individual teacher to ensure that any student to whom they intend to provide a lesson ID access code (including, without limitation, students under the age of 13) have, before any such code is provided, obtained all necessary consents and permissions (from a parent and/or guardian and from their educational establishment) to use the Platform and for us to collect and process any user data (including, without limitation, the collection of user data relating to students under the age of 13).
Information collected in connection with day to day use of the Platform
Information will also be collected in connection with day to day use of the Platform by the teachers and students. This information will be collected in connection with the use of the Platform in the classroom environment, and through teacher and student participation in discussion boards and from teachers participation in any competitions, promotions or surveys, and also when any problem is reported.
The information which will be collected includes subjects and lessons added, content uploaded such as presentations, images and videos, annotations made by both the teacher and students to the content, quiz and assessment questions and the student’s answers, questions which the students have asked the teacher through the Platform and the answers given by the teacher.
Technical Information which we collect about you
We will automatically collect the following information in connection with the teachers and students use of the Platform:
technical information, including your login information, the Internet protocol (IP) address used to connect the computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
- information relating to your visit, including the date and time of access, the duration of your visit to the Platform, details of the Platform features which were utilised during the visit and for how long, the location from which the Platform was accessed page response times, download errors, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number. In particular the
- Much of this information will be collected using cookies. For details of cookies and their use in connection with the Platform please see our Cookies Policy
Information which we receive from other sources
This is information we receive about you from any of the third parties we work with in connection with the provision of the Platform (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Uses made of the information
We use information held about you in the following ways:
- Information we collect from you. We will use this information:
to enable us to, provide you with you to access to the Platform, operate and provide the information, services and features of the Platform on a day to day basis and to communicate with you;
- to provide educational establishments and teachers with details of product updates, invitations to CPD events which we run and for research purposes (e.g. surveys) relating to the Platform and the services provided though the Platform. Student data is used solely to enable us to provide the Services and the Platform to the Student and will not be used for such purposes. Educational establishment and teacher data may be used to contact the teacher to obtain feedback from the teacher on the current Services and Platform and on proposed changes to the services and Platform.
- educational establishment and teacher data may, to the extent that the educational establishment or teacher has agreed to be contacted for such purposes, be used by our direct marketing agency- http://bee-seen.co.uk/ (who are based in London and France) for the purposes of cross selling upgrades to the Platform;
to notify you about changes to our service;
to ensure that content on the Platform is presented in the most effective manner for you and for your computer.
- Information we collect about you. We will use this information:
to administer Platform and services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve the Platform and services to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our platform;
to help keep the Platform safe and secure;
- Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
You agree that we have the right to share your personal information as follows:
- To the extent required to provide the service and the Platform for instance, to make the materials and information available to the educational establishment, teachers and students and to deal with any technical or performance issues with the services or Platform. The extent to which information is shared will depend on the services which are utilised within the Platform.
- Teacher data from registration will be disclosed to our employees in connection with the provision of the services and the Platform.
- Selected third parties as follows:
- Teacher data from registration will be disclosed to employees of our Digital Marketing Agency – http://bee-seen.co.uk/ who are based in London and France for the purposes obtaining feedback from educational establishments and teachers on the current services and Platform and on proposed changes to the services and Platform and, to the extent that the educational establishment or teacher has agreed to be contacted for such purposes, may be used for the purposes of cross selling upgrades to the Platform.
- Teacher and student data from registration/sign-up; and
- On-going product usage data will be accessible by our development agency (Gizra – https://www.gizra.com/ ) who are based in Israel, and who will use the data for the purposes of providing technical and operational support to the users.
- We may also share information with others in an aggregated and anonymous form. You agree that we may collect and use such information at any time use and share such data for our own purposes, provided that such data will be de-identified and/or aggregated to avoid identification of specific individuals.
- We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- 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.
We will only share teacher data as set out in this section.
We will never share student data with third parties for marketing purposes.
Termination of Subscription and Retention of data
We will retain the information for as long as your account is active.
Data which is the property of the educational establishment or the teacher can be deleted upon the request of the educational establishment or teacher. The request must be made in writing via email to firstname.lastname@example.org provided that we may retain and use any information required to comply with any legal obligations or to comply with any obligations or disputes which we have.
Data pertaining to any student use of the Platform will be retained for 3 months after the relevant teacher/educational establishment (as appropriate) subscription (premium or freemium) has ended. After this 3-month period we may destroy or otherwise dispose of the data in our possession. You shall pay all reasonable expenses incurred by us in returning or disposing of such data.
When a subscription has been taken out by an individual teacher then if that teacher deletes a specific student accounts associated with that subscription or the teacher terminates their subscription to the platform then the individual student account will be disabled and the student not be able to access the Platform. After termination the teacher will not be able to access any materials or information held by us in respect of such account. Student data will subsequently be deleted in accordance with the above paragraph.
Where we store your personal data
Data from teachers and students from registration/sign-in and from on-going product usage will sit in data centres in Europe.
The data that we collect from you may be transferred to a destination outside the European Economic Area (“EEA”) and may be processed by staff operating on our behalf outside the EEA . This includes staff engaged in, among other things, the provision of support services by our development agency. By submitting your personal data, you agree to this transfer, storing or processing.
Security of data
All information you provide to us is stored on our secure servers. We use a secured server – Drupal CMS – which has built in security features. Our development agency constantly ensure they have the relevant security updates and that they are supported by Drupal security team. Any potential threats are addressed by the Drupal security team.
Access to data limited though user/password credentials. Any payment transactions will be encrypted using SSL technology.
Where we have given you (or where you have chosen) a password which enables you to access to the Platform, you are responsible for keeping this password confidential.
We ask you not to share a password with anyone.
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 Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Accuracy of Your information
We endeavour to ensure that the information we hold about you is accurate and up to date. If you become aware that any such information is inaccurate and needs to be corrected please contact us using the details set out in the “Contact” section below and provide details of the inaccuracy. We will investigate your request and will either make the change or notify you why the change cannot be made.
Third party websites
Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request must be in writing.
This Policy was last updated 13 March 2017