OUR PRIVACY POLICY
Effective Date: 19 April 2022
Last Updated Date: 19 April 2022
Suburani and www.hands-up-education.org are owned and operated by Hands Up Education Community Interest Company. Hands-up-education.org hosts classics curriculum and it is intended for use by adults, including teachers. Suburani is an online Latin curriculum intended for use by schools and individuals, including children, teachers, and students.
We take privacy seriously at Hands Up Education, and our privacy policy tells you what we do with your personal information, why we use it, who we share it with and how long we keep it. As it’s your information, you have the right to know what happens with it. What kind of information we hold about you, and how long we keep it, will depend upon your relationship with us and the reasons why we have it. Personal information is information that could identify you. This could be anything from an email address to a job application. We have to have a valid reason to use your information. You might give us this information yourself, for example if you subscribe to our newsletter, attend our events, ask us to ship you materials or use our online learning tools.
Table of contents
CHILDREN'S PRIVACY NOTICE
Here you can read our Children's Privacy Notice.
1. HOW DO WE GET INFORMATION?
Most of the personal information we process is provided to us directly by you for one of the following reasons:
► You have made an enquiry to us.
► You have contacted us to provide us with information.
► You wish to attend, or have attended, one of our events.
► You subscribe to our e-newsletter.
► You subscribe to our e-learning software.
► You have agreed to take part in research.
We also receive personal information indirectly, for example in the following scenarios:
► Your personal information is contained in communications from Educational Organizations.
2. WHAT INFORMATION DO WE COLLECT?
If you sign up to our e-newsletter, attend one of our conferences, complete a survey, or use our e-learning software as a teacher or administrator, we may collect the following information:
► Name and job title.
► Contact information including email address.
► Demographic information such as postcode, educational preferences and interests.
► Other information relevant to education research and development, and teacher training.
If you use our e-learning software as a student at or above the age of consent, we may collect the following information:
► Your name.
► Your class (i.e. teaching group).
► Your performance in digital Latin resources, as you complete our online activities.
Our e-learning software doesn't use or store student email addresses. We aim to ensure that we only store data which is necessary to operate the e-learning service.
3. WHAT DO WE DO WITH THE INFORMATION WE GATHER?
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
► Internal record keeping.
► We may use the information to improve our resources and services.
► We may periodically send promotional emails about new resources, training events or other information which we think you may find interesting, using the email address which you have provided.
► From time to time, we may also use your information to contact you for education research purposes. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests.
If you are a student using our e-learning software, we may use your information for the following reasons:
► To help you and your teacher understand what you are doing well and what you need to improve.
► To organise and manage your account.
► To analyse which activities may be too hard or too easy.
► To conduct education research.
► To customise the software to suit your preferences.
► To detect and prevent fraud.
If you are a teacher or administrator using our e-learning software, we may use your information for the following reasons:
► To enable you to organise and manage your account, and to help you to do so ourselves.
► To contact you about your account.
► To conduct education research.
► To customise the software to suit your preferences.
► To detect and prevent fraud.
4. TELEPHONE AND EMAIL CONTACT INFORMATION
When you call us, we collect Calling Line Identification (CLI) information. This is the phone number you are calling from (if it’s not withheld). We hold a log of the phone number, date, time and duration of the call, but do not audio record the call itself. This information is deleted after 6 months. We may use the number to call you back if you have asked us to do so, if your call drops, or if there is a problem with the line. We may also use it to check how many calls we have received from it.
We don’t audio record any calls, but we might make notes to help us answer your query.
We’ll monitor any emails sent to us, including file attachments, for viruses or malicious software. You must ensure that any email you send is within the bounds of the law.
5. WHO CAN ACCESS YOUR INFORMATION?
Your information is accessible only to our staff (i.e. the staff of Hands Up Education CIC) and, in the case of users of our e-learning software, to teachers and administrators of the school (or institution) who have administrator privileges within the software.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In the case of marketing contacts, we review information held annually. We aim to remove contacts promptly upon request or when it is apparent that the person we are contacting is no longer interested in our communications.
For users of our e-learning software, we will delete personal information in inactive accounts six months after their expiry date, unless otherwise requested to do so.
We may retain personal information for longer if we are required to do so in order to comply with our legal and regulatory requirements.
We will not share your information with any third parties for the purposes of direct marketing.
We use data processors who are third parties who provide elements of services for us. For example, we may use a shipping company to send you materials in the post and to do so we will need to pass on to them your name and address. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. You can find out more about these third parties in the table below.
In some circumstances we are legally obliged to share information, for example under a court order. In any other scenario, we’ll satisfy ourselves that we have a lawful basis on which to share the information and document our decision making.
8. THIRD PARTY SERVICE PROVIDERS
Hands-up-education.org uses the following service providers in relation to teachers and grown-ups who visit our website, this includes teachers with accounts on Suburani.com, users on the Hands Up Education Mailing List, users who have purchased products from Hands Up Education, and users who have scheduled or attended a call with the Hands Up Education team.
Google Firebase, Google Firestore, and Fast Comet process student data solely to support the operations of the e-learning service. These providers do not disclose student data or use it for their own purposes.
| Service Provider Name | Personal data collected | Purpose for Processing | Place of processing | Privacy Policy |
| Google Firebase |
|
Cloud service provider and authentication | USA and Europe | policies.google.com/privacy?hl=en |
| Google Firestore |
|
Storage of Suburani progress data, and school, class, teacher, and student records | USA and Europe | policies.google.com/privacy?hl=en |
| Fast Comet |
|
Server host | USA | fastcomet.com/terms/privacy-policy |
| Mailchimp |
|
Email service provider | USA | intuit.com/privacy/statement/ |
| Stripe |
|
Payment processing | USA | stripe.com/en-ca/privacy |
| Shopify |
|
Payment processing | USA | shopify.com/legal/privacy |
| Calendly |
|
Meeting scheduling | USA | calendly.com/privacy |
| Zoom |
|
Meeting facilitator | UK, Europe, and USA | explore.zoom.us/en/privacy/ |
| Xero |
|
Accounting software | USA (on AWS) | xero.com/ca/legal/privacy/ |
| Co-op Online Banking |
|
Online banking | co-opbank.co.ke/privacy-policy-2/ | |
| Wise Online Banking |
|
Online banking | wise.com/us/legal/privacy-policy | |
| Metro Online Banking |
|
Online banking | metrobankonline.co.uk/about-us/privacy/M | |
| TPS |
|
Shipping (NA) | USA | |
| Spatial Global |
|
Shipping (UK and RoW) | UK | gdpr.spatialglobal.com/privacy/ |
9. CHILDREN UNDER THE AGE OF 13 IN THE US AND UNDER THE AGE OF 16 IN THE EU AND UK
Particular care has been taken to ensure that we gather as little identifiable information about children as possible. We only store data necessary to operate the e-learning service on cloud providers as described in the table above. We do not share or sell students’ personal information. We do not have advertising on our platform and do not disclose any information for targeted advertising.
For school accounts, we collect the following student information:
For individual accounts, we collect the following student information:
Student information is used to allow students to log in and monitor their progress as they engage with the interactive exercises, and to allow teachers to see the progress data of students in classes assigned to them.
Student information from school accounts is only available to our staff (i.e. the staff of Hands Up Education CIC) and to teachers and administrators of the school (or institution) who have administrator privileges within the software. We are also committed to ensuring that personal information is held securely and have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online. We delete inactive student accounts, and all associated personal information, six months after the expiry date, unless otherwise requested.
We comply with the U.S. Family Educational Rights and Privacy Act (FERPA), the U.S. Children’s Online Privacy Protection Act (COPPA), and the EU General Data Privacy Regulation (GDPR), as applicable. For school accounts, we collect and use student personal information solely to provide educational services to the school or district, and for no commercial purposes, under FERPA’s school official exception. For individual accounts, we also ensure that we obtain parental consent from children under the age of 13 in the U.S. and under the age of digital consent in the EU, depending on the Member State, prior to collecting or using children’s personal information.
For school accounts, the log in and password recovery system of our e-learning software has been purposefully designed not to make any use of, or permit, student email addresses.
Schools and parents can request to review, correct, or delete student personal information by emailing us at [email protected].
10. YOUR DATA PROTECTION RIGHTS
Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.
Your right of access
You have the right to ask us for copies of your personal information. There are some exemptions, which means you may not always receive all the information we process. You can read more about this right here.
Your right to rectification
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right here.
Your right to erasure
You have the right to ask us to erase your personal information in certain circumstances. You can read more about this right here.
Your right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right here.
Your right to object to processing
You have the right to object to us processing (using) your personal information at any time. This effectively means that you can stop or prevent us from using your information. However it only applies in certain circumstances, and we may not need to stop processing your information if we can show that there are strong and legitimate reasons for us continuing to use your information. You can read more about this right here.
Your right to data portability
This only applies to information you have given us. You have the right to ask that we transfer the information you gave us to another organisation, or give it to you. You can read more about this right here.
You are not required to pay any charge for exercising your rights. We have one month to respond to you.
Please contact us at [email protected] if you wish to make a request, or call us on +44 (0)1223 782 588.
11. YOUR RIGHT TO COMPLAIN
We work to high standards when it comes to processing your personal information. If you have queries or concerns, or would like to make a complaint, please contact us at [email protected].
If you remain dissatisfied about the way we process your personal information, you can make a complaint to the Information Commissioner’s Office (www.ico.org.uk).
12. SECURITY
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
13. HOW WE USE COOKIES
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We currently use only four cookies, and they are used within the ordering and checkout area of our website when people buy our books or software. They are used because they are necesary for processing your address and payment details. If you do not use the ordering and purchasing area of our website, the cookies will not be used.
14. PURPOSE AND LAWFUL BASIS FOR PROCESSING
The purpose for implementing the above is to maintain and monitor the performance of our website and to constantly look to improve the site and the services it offers to our users. The lawful basis we rely on to process your personal data is either Article 6(1)(a) of the GDPR, for example when you ask us to send your our e-newsletter, or Article 6(1)(b) when you ask to use our e-learning software, or Article 6(1)(f) which allows us to process personal data when it’s necessary for our legitimate interests, for example in order to maintain the integrity of our IT systems and the continuity of our business.
15. LINKS TO OTHER WEBSITES
Our website contains links to other websites that we think may be of interest. For example, they may help you learn about the ancient world or provide information about useful organisations. However, once you have used these links to leave our site, you should note that we do not have any control over the other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statements on the other websites you visit.
16. CONTROLLING YOUR PERSONAL INFORMATION
In addition to your rights explained above, you may choose to restrict the collection or use of your personal information in the following ways:
► whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
► if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to us at the address given below, or emailing us at [email protected].
We will not sell, distribute or lease your personal information to third parties unless we are required by law to do so. We may use your personal information to send you information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998, the General Data Protection Regulation 2016 and, for citizens of California, the California Consumer Privacy Act. If you would like a copy of the information held on you please email [email protected] or write to Hands Up Education, 133 Bradley Road, Little Thurlow, CB9 7HZ, UK.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.
17. CHANGES TO OUR PRIVACY POLICY
We may make changes to the policy from time to time so please be sure to check regularly. If we make a material change to this policy and we have your contact details, we will contact you before we make the change. We will also post a notice at the start of the policy.
18. CONTACT US
If you have any questions please contact us.
Honeytree Cottage,
133-134 Bradley Road,
Little Thurlow,
Haverhill,
Suffolk,
CB9 7HZ, UK
You can reach our Privacy Officer, Laila Tims, at [email protected]
+44 (0)1223 782 588