Privacy Policy

UNIO BY            HARNESS PRIVACY POLICY

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“).

This privacy policy together with our terms and conditions and cookie policy and any other documents referred to in it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

These documents together form the legally binding contract between us. Please read each of these documents carefully to understand the contract which you are entering into with us and our views and practices regarding your personal data and how we will treat it.

By registering for or using the Platform you are accepting the terms outlined in these documents and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the “Act”) and any law that supersedes 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.

  1. Information   which we collect from  you
    1. Information collected in connection with registration –Teacher Users:

We will collect and process the following data about Teacher Users in connection with registration for and use of the Platform.

The information from Teacher Users 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.

    1. Information collected in connection with sign-in – Student Users

The Platform enables Teacher Users to make the services on the Platform available to specific Student Users. The Student Users will only be able to access a lesson on the Platform if the Teacher User has provided the Student User with the appropriate lesson ID access code and the Student User enters this and their first name.

The information which will be collected from Student Users in connection with signing into the Platform will be a first name only. It is the responsibility of each Teacher User to ensure that any Student User 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).

As a Teacher User you acknowledge and warrant that you have and will provide all requisite authority from, and on behalf of, the parent/guardian of the student and on behalf of the educational establishment to (i) allow the student to use the Platform; and (ii) for you to provide the Platform and make it available to Student Users and to make any User Data available to us in connection with the use of the Platform on the terms set out in our terms and conditions and this privacy policy.

  1. 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 Teacher Users and Student Users. This information will be collected in connection with the use of the Platform in the classroom environment, and through Teacher User and Student User participation in discussion boards and from Teacher Users 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 Users and Student Users to the content, quiz and assessment questions and the Student User’s answers, questions which the Student Users have asked the Teacher User through the Platform and the answers given by the Teacher User.

  1. Technical information which we collect about you
    1. We will automatically collect the following information in connection with the Teacher Users and Student Users use of the Platform:
      1. 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.
      2. 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 Platform utilises Google Analytics a web analytics service provided by Google, Inc. Google Analytics uses cookies to help analyse and provide the technical information referred to above as being collected in connection with the use of the Platform.

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.

  1. 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.

  1. Lawful basis for processing

When processing your personal data we rely upon the following lawful bases of processing: (i) performance of a contract with you (to provide the Platform and other services to you); and (ii) our legitimate interests (to allow us to update our records, run our business, monitor use of the Platform and to send you feedback / marketing / promotions materials).

  1. Cookies

Our Platform uses cookies to distinguish you from other users of the Platform. This helps us to provide you with a good experience when you use the Platform and also allows us to improve the Platform. For further information on our use of cookies see our Cookie policy.

  1. Uses made of the information
    1. We use information held about you to enable us to provide you with 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.
    2. Information we collect from you.   

We will use this information:

      1. to provide Teacher Users 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 through the Platform. Student User data is used solely to enable us to provide the Platform and services made available through the Platform to Student Users and will not be used for any other purposes. Teacher User data may be used to contact the Teacher User to obtain feedback from the Teacher User on the Platform and on proposed changes to the Platform;
      2. to notify you about changes to our services / the Platform;
      3. to ensure that content on the Platform is presented in the most effective manner for you and for your computer;
      4. for marketing and communication purposes, if you have not opted-out of receiving such content. You will always have the option to unsubscribe from receiving such marketing and communications by clicking the link in our emails, or by emailing support@uniobyharness.com.

    1. Information we collect about you.

We will use this information:

      1. to administer the Platform and related services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
      2. to improve the Platform and related services to ensure that content is presented in the most effective manner for you and for your computer;
      3. to allow you to participate in interactive features of our Platform;
      4. to help keep the Platform safe and secure.
    1. 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).

  1. Disclosure of your information
    1. You agree that we have the right to share your personal information as follows:
      1. To the extent required to provide the Platform and related services for instance, to make the materials and information available to the Teacher Users and Student Users and to deal with any technical or performance issues with the Platform or related services. The extent to which information is shared will depend on the services which are utilised within the Platform.
      2. Teacher User data from registration will be disclosed to our employees in connection with the provision of the Platform and related services.
      3. To selected third parties as follows:
        1. Teacher User and Student User data from registration/sign-up; and
        2. On-going product usage data will be accessible by our operational support agency who will use the data for the purposes of providing technical and operational support to the Teacher Users and Student Users. The agency, (Gizra – https://www.gizra.com/ ) is based outside of the EEA.
        3. Analytics and search engine providers that assist us in the improvement and optimisation of the Platform. The Platform utilises Google Analytics a web analytics service provided by Google, Inc. Google Analytics uses cookies to help analyse and provide the technical information referred to above as being collected in connection with the use of the Platform.
      4. 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.
    2. We will disclose your personal information to third parties:
      1. 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.
      2. 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.
      3. If we are under a duty or believe that 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 and conditions and other agreements; or to protect our rights, property, safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We will only share Teacher User data as set out in this section.

We will never share Teacher User or Student User data with third parties for marketing purposes.

  1. Termination of subscription and retention of data
    1. We will retain the information for as long as your account is active.
    2. Data which is the property of the Teacher User can be deleted upon the request of the Teacher User. The request must be made in writing via email to support@uniobyharness.com 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.
    3. Any User Data will be retained for a period of 30 days after the Trial Period / Subscription Period (as applicable) has ended. After this 30-day period we will permanently delete any User Data you have inputted into the Platform.
    4. When a subscription has been taken out by an individual Teacher User then if that Teacher User deletes a specific Student User account associated with that subscription or the Teacher User terminates their subscription to the Platform then the individual Student User(s) account will be disabled and the Student User(s) will not be able to access the Platform. After termination the Teacher User will not be able to access any materials or information held by us in respect of such account. Student User data will subsequently be deleted in accordance with the above paragraph.
  2. Where we store your personal data
    1. Data from Teacher Users and Student Users from registration/sign-in and from on-going product usage will sit in data centres in Europe.
    2. 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. We confirm that we have appropriate contracts in place with any third parties based outside the EEA to ensure your data is processed in accordance with data protection laws.
  3. Security of data
    1. We take security of data very seriously. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
    2. 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 the Drupal security team. Any potential threats are addressed by the Drupal security team.
    3. Access to data is limited though user/password credentials. Any payment transactions will be encrypted using SSL technology.
    4. 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.
    5. 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 therefore at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
  4. 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.

  1. 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 or your use of these websites. Please check these policies before you submit any personal data to these websites.

  1. 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.

  1. Your rights
    1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the following rights:
      1. The right to request access to your personal data;
      2. The right to request correction of your personal data;
      3. The right to request erasure of your personal data;
      4. The right to object to processing of your personal data;
      5. The right to request restriction of processing your personal data;
      6. The right to request the transfer of your personal data;
      7. The right to withdraw consent.
    2. If you wish to exercise any of the rights set out above, please contact us via support@uniobyharness.com
    3. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
    4. 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.
    5. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. Contact & complaints

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@uniobyharness.com

You have the 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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  1. Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this website. Please check back frequently to see any updates or changes to our privacy policy. By continuing to use the Platform you agree to be bound by the contents of any updated policy.

Version Date: 05/04/2018

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