Freeborn Academy Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, Freeborn Academy (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
2. Information About me
My Site is owned and operated by Freeborn Academy Ltd, Company Number 11720888.
Registered address: 1st Floor 2 Woodberry Grove, Finchley, London, England, N12 0DR.
Data Protection Officer: Natasha Freeborn.
Email address: email@example.com.
Telephone number: 07825828496.
Postal Address: PO Box 1087, Camberley, GU15 9DR.
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which I will always work to uphold:
b) The right to access the personal data I hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that I have. Please contact me using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Data Do We Collect?
· Email address;
· Telephone number;
· Payment information;
· Information about your preferences and interests;
· IP address;
· Web browser type and version;
· Operating system;
7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
· Providing and managing your access to Our Site;
· Personalising and tailoring your experience on Our Site;
· Supplying Our products and services to you. Your personal details are required in order for us to enter into a contract with you.
· Personalising and tailoring our products and services for you.
· Communicating with you. This may include responding to emails or calls from you.
· Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by emailing us or selecting unsubscribe on an email we have sent you).
· Analysing your use of Our Site and gathering feedback to enable me to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone with information, news, and offers on Our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.
The following automated profiling may take place:
o MailChimp collects your entered email, name, and when you subscribed on the website in order to add you to our mailing list for newsletters and offers.
o Facebook and Google AdWords keep track of what you click on so that we know what adverts interest you and what content is most appealing or not appealing so we can do more or less of it, respectively.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
· Personal data is only retained for as long as it is required and you are able to unsubscribe at any time.
9. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the “EEA”) or with parties that comply with GDPR. The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by me when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
· Using password protected and encrypted files on the computers used for your data.
Keeping any paper files in a locked, secured environment when not in use.
10. Do You Share My Personal Data?
We may sometimes contract with the following third parties to supply certain products or services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
· Stripe card processing is available as a payment processing method on Our Site, which will require your personal details to process a payment.
· Mailchimp stores your name and email address which allows Us to compile a list of people who have consented to receive email communication from Us.
If any of your personal data is required by a third party, as described above, We will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, my obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, We will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
11.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in our emails).
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling me to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of My Site may not function fully or as intended.
Certain features of My Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
Name of Cookie
Present as long as the browsing session is open
Keep login details and other things that remind the website you’ve been there before.
Anonymous information that see where you go on the website and what you click on.
Our Site uses analytics services provided by Google and Facebook. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling me to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie
First / Third Party
To track what ads or content you click on to improve our service and content.
Facebook Ads Manager
To track what ads or content you click on to improve our service
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Natasha Freeborn):
Email address: firstname.lastname@example.org.
Telephone number: 07825 828496.
Postal Address: PO Box 1087, Camberley, GU15 9RD.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.