Privacy Notice

EdenFiftyOne Ltd — ICO Registration Reference: ZB876397

1. Introduction

Welcome to the EdenFiftyOne™ privacy notice.

EdenFiftyOne Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we use information about you (personal data) when you visit our website and/or use our services.

You can download a copy of this policy by using the 'Save' or 'Print' feature of your browser.

2. Our Privacy Notice

When we process personal data about you, this may be as either a 'processor' (where we process on behalf of someone else) for Enterprise Services or as a 'controller' (where we process for our own purposes) for Private Services, as defined below.

It is important that you read this privacy notice so that you are fully aware of how and why we are using your personal data and to know what to do if you have any queries or concerns. In addition, where we are providing our services to your employer or school, you may wish to request further information from them.

This privacy notice covers the following scenarios under which EdenFiftyOne™ may process your personal data:

• a) Your use of our website;
• b) User verification for access to our platform;
• c) Services provided directly to learners or to learners' parents or guardians ("Private Services");
• d) Services provided to schools, businesses, government or professional tutors ("Enterprise Services"); and/or
• e) Where you contact us directly, either to give us feedback about our services, or to enquire about any aspect of our services.

a. Use of our website

In the course of using our website we may collect personal data about you – this will be limited to:

• your I.P address; and
• details of how you use our website.

Such personal data is collected in the form of 'cookies' which we will only collect and use in accordance with our cookies policy.

Additionally, in the event you wish us to contact you with more information about our services, your name, contact details and (where relevant for Enterprise Services) details of your employer and role may be collected from our website. You can ask us to stop sending you marketing messages by contacting us at any time.

b. User Verification

Where you, your school or your employer sign up to receive our services (whether for Enterprise Services or for Private Services), we may need to verify your identity when accessing our platform for which we may need to collect:

• Your name; and
• Your email address.

c. Private Services

Where we provide services directly to learners or to the parents or guardians of learners, we will need to collect the following personal data about the parent/guardian and/or the learner in order to provide these services:

• Name (learner and parent/guardian);
• Learner performance;
• Learner age;
• Learner gender; and
• Details of learner special educational needs.

d. Enterprise Services

Where we provide to schools, businesses, government and/or professional tutors we will also need to collect personal data about the learners, however, unlike a, b and c, above, we process this personal data on behalf of our clients and not for our own purposes. As such, the relevant school, business, government department or tutor will be primarily responsible for how they handle your personal data.

In these instances, we will process such personal data in line with our Data Processing Agreement agreed with such clients and if you have any queries relating to your personal data which EdenFiftyOne™ process as a processor for our clients, we would direct you to reach out to the relevant school, business, government department or tutor.

e. Direct Contact / Survey Feedback

Where you contact us directly or in the course of collecting feedback about our services, we may collect data you provide about you and (where necessary) about relevant learner(s).

3. Our Lawful Basis

UK privacy laws require a 'lawful basis' for the processing of any personal data (unless you are doing it on behalf of another person as a 'processor').

EdenFiftyOne™ rely on the following lawful bases for our processing of personal data:

• 'Legitimate interest': this means that the personal data is being processed as necessary to meet a lawful purpose which does not unacceptably impact your privacy rights. You have the right to know what this objective is and to object to our processing of any of your personal data on this basis.
• 'Contract': this means that the processing of your personal data is necessary to perform a contract we have agreed with you. This will only apply where we provide you with Private Service and in line with our Terms of Use.
• 'Consent': where we process any sensitive personal data about you or the learner we will only do so with your prior explicit consent. Sensitive personal data includes any data about an individual's race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, genes, biometrics (e.g. fingerprints), health, sex life or sexuality. Your submission of such personal data to us is entirely voluntary and will typically only be details of any special educational needs by you or the learner (and only to extent these reveal health information). Where you use our services as a parent of learner, we will ask you to provide consent on behalf of the learner. You have the right to withdraw your consent at any time – upon which we will delete the sensitive personal data. We may also rely upon consent where you contact us directly with any feedback or enquiry about our services.

For full details on the lawful basis on which we rely to process your personal data please see the Summary below.

4. Who we share your personal data with

Unless expressly agreed with you beforehand, EdenFiftyOne™ will only share your personal data with our suppliers as necessary to provide our services – for example, IT service providers who host our platform and store and process our data for us. EdenFiftyOne™ are committed to ensuring that such suppliers protect your personal data to the highest standards.

EdenFiftyOne™ currently stores your personal data in the UK and the European Economic Area (EEA). In the event that we transfer your personal data outside of the UK and European Economic Area (other than a transfer directly to you), we will notify you and provide details of such transfer.

5. How long we process your personal data for

We will only retain your personal data for as long as necessary in order to provide our services. In some cases, this will require retention of the personal data beyond the period in which you use it – such retention period will always be agreed in advance within our Terms of Use.

6. Your rights

Under UK privacy law you have rights to ensure we are processing your personal data lawfully. These rights include:

• Right of Access: you have the right to know what personal data we hold about you and to obtain a copy of that personal data.
• Right to Rectification: if any personal data we hold about you is incorrect you have the right to have that personal data rectified.
• Right to erasure / objection / restriction: you have the right to have the processing of your personal data stopped and for that personal data to be deleted (note this may not apply where the processing is necessary for the performance of a contract agreed with you).
• Right to portability: you have the right to have your personal data transferred to a third party.

For all personal data we process as a 'controller' (i.e. details of your use of our website, your user verification details and data collected in the provision of Private Services), see 'Contact Us' for details on how to exercise your privacy rights.

For any personal data we process as a 'processor' (i.e. personal data other than user verification details we process in order to provide Enterprise Services), please contact your relevant school, employer, tutor etc.

If you have any complaints or concerns as to how we process your personal data, please contact us on the details below. If you are unsatisfied with our response you have the right to complain to the Information Commissioner's Office via their website at ico.org.uk, via telephone on 0303 123 1113 or by mail at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

7. Summary

The table below sets out the types of personal data we collect and details of our lawful basis for each type.

8. Contact Us

Should you have any questions or comments on this Privacy Notice and/or how EdenFiftyOne™ process your personal data, please feel free to contact us at:

support@edenfiftyone.com