The Education Company Privacy Policy

Last modified: July , 2019

1. Intro

This Privacy Policy describes how The Education Company collects and uses Personal Data about you through the use of our Websites and the SPIRIT Apps that provide you access to the SPIRIT Services, and through email, text, and other electronic communications between you and The Education Company.

The Education Company Ltd. ( "The Education Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy (our "PrivacyPolicy") describes the types of information we may collect from you or that you may provide when you visit the websites with the top-level domain names of http://spiritcrm.co.uk, http://educationcompany.co.uk and http://education.co.uk (each, a "Website" and collectively, the "Websites"), use the SPIRIT Services through our mobile and desktop applications (the "SPIRIT Apps" ) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Our services (the "SPIRIT Services" ) allow you to access the content of your email for the purpose of CRM and scheduling meetings.The SPIRIT Services include, but are not limited to, SPIRIT for Gmail, SPIRIT for Outlook, SPIRIT for Android, SPIRIT for iPhone, SPIRIT Calendar and all of the functions available through each of these.

This policy applies to information we collect:

on our Websites;
in email, text, and other electronic messages between you and our support team;
through mobile and desktop applications (including browser and Outlook extensions) you download from our Websites or other application stores (such as the Apple App Store® the Google Play® Store and the Microsoft Office® Store), which provide you access to the SPIRIT Services; and when you use the SPIRIT Services.

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by The Education Company or any third-party; or
any third party, including through any application or content (including advertising) that may link to or be accessible from, on, or through the SPIRIT Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites or the SPIRIT Services. By accessing or using our Websites and the SPIRIT Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Websites or the SPIRIT Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Data Processor

The Education Company is the data Processor of your Personal Data.

The Education Company is the data Processor of your Personal Data that you provide on the on and through SPIRIT.

3. Children Under the Age of 18

SPIRIT's Apps and Services are not intended for children under the age of 18, and children under the age of 18 are not permitted to use our Websites or directly use the SPIRIT Services. We will remove any information about a child under the age of 18 if we become aware of it.

Our Websites are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Websites, directly use the SPIRIT Services, or install the SPIRIT Apps. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Websites or on or through any of its features, install the SPIRIT Apps, or directly use the SPIRIT Services, including providing your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data directly from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected]

4. Data Collection

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with information from our other users. This includes information that we collect directly from you or through automated collection technologies, or through your use of the Service.

Generally

When you register to use the SPIRIT Services or use our Websites, we collect several types of information from and about users of the SPIRIT Services, specifically information:

by which you may be personally identified, such as name, postal address, e-mail address, telephone number any other identifier by which you may be contacted online or offline ("Personal Data");
that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream data, and other communication data and the resources that you access and use on the Websites; and/or
about your internet connection, the equipment you use to access our Websites and usage details.

We collect this information:

directly from you when you provide it to us; and
automatically as you navigate through the Websites. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

When you use the SPIRIT Service, we may also collect and process these types of information when you compose an email or meeting invite, send your calendar information, and when you hold or pause messages in your inbox or schedule communications for later, include a read receipt, request notification if a user doesn't respond, or otherwise use features provided by the Service. You and the other parties you communicate with are in complete control over the specific type of information contained in these messages.

Information You Provide to Us

The information we collect on or through our Websites are:

information that you provide by filling in forms on our Websites. This includes information provided at the time of subscribing to our service or requesting further services.
information that you provide as part of the process of authenticating SPIRIT and granting it access to your data on other services, such as 3rd party email providers. This information always includes your email address, and may include additional information such as your name and a profile picture.
information that you provide as part of email messages or calendar invitations when you use the SPIRIT Service while composing an email, when you pause, when you schedule an email for later, or when you otherwise interact with features in the SPIRIT service.
records and copies of your correspondence (including email addresses), if you contact us, including when you report a problem with the SPIRIT Services, the SPIRIT App, or the Websites;
details of transactions you carry out through our Websites or the SPIRIT Apps and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Websites or the SPIRIT Apps.

The Personal Data we collect from you is required to enter into a contract with The Education Company, for The Education Company to perform our obligations under the contract, and to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

You also may provide information to be transmitted to third parties (collectively, "Communications"). Your Communications are transmitted to others at your own risk. Although we use technology to protect your Communications, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of the recipients of your Communications, who may forward them to other third parties or otherwise disclose them. Therefore, we cannot and do not guarantee that your Communications will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Websites or use the SPIRIT Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. We collect:

details of your visits to our Websites or use of the SPIRIT Apps, specifically traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites or use of the SPIRIT Apps, error information, clickstream data, and other communication data and the resources that you access and use on the Websites;
Information about your computer, mobile device, and internet connection, email or calendar client, specifically your IP address, mobile device make and model, operating system, and browser type.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from you or other third parties. It helps us to provide you with the SPIRIT Services, improve the SPIRIT Services, and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
store information about your preferences, allowing us to customize our Websites and the SPIRIT Apps according to your individual interests;
recognize you when you return to our Websites or use our SPIRIT Apps.

Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy. (https://SPIRITapp.com/cookiepolicy.html)

Information We Collect Through Providing You With the SPIRIT Service

As you use the SPIRIT Services, we may collect certain information about your Communications. We collect:

the contents and header information from the Communications you send and receive through the service. This may vary by the systems used to send and receive information, but header information will generally include at least the senders and recipient's email address, subject line, message size, the date and time the Communications was sent and received by each server used in the delivery, the system name and IP address of each system used in the delivery, and other similar metadata;
geolocation data from your mobile device, if you have enabled this feature.
information about events in your calendar, such as event titles, attendees, locations, and meeting times.
responses from the recipients of your Communications, if you have enabled this feature.

The information we collect as a result of your use of the SPIRIT Service includes any information that may be in the subject line or in the contents of your Communications, which may include Personal Data that you include in it. This information is used to provide you with the SPIRIT Service.

5. Lawful Basis for Processing Your Data

We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

Consent. By using our Websites, the SPIRIT Apps, and the SPIRIT Service, you consent to our collection, use, and sharing of your Personal Data as described in this privacy policy. If you do not consent to this privacy policy, please do not use the Websites, SPIRIT Apps, or the SPIRIT Service;
Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Specifically, our legitimate interests are to: facilitate communication between The Education Company and you; detect and correct bugs and to improve our Websites, SPIRIT Apps, and SPIRIT Service; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; check your credit and perform risk assessments; aggregate non-identifiable data in order to provide new features of the Service, and improve our product and services;
To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our Contract with you to deliver our goods and services to you. Specifically, we process your Personal Data to provide you with the features and functionality of the SPIRIT Service that you subscribe to; and
As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspection, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

6. Special Category Data

We generally do not request you provide and do not process any special categories of Personal Data. However, this category of Personal Data may be in your Communications and, if so, we will process it only for the purposes described in this Privacy Policy.

The Education Company does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you that may be considered sensitive, including personal data that reveals your racial or ethnic origin, political opinions, religious, philosophical beliefs, or trade unions membership, or the processing of data concerning your health or data concerning your sex life or sexual orientation or history of criminal convictions. However, this category of Personal Data may be in the Communications that you send or receive. By using the SPIRIT Service with Communications that contain this category of Personal Data, you hereby consent to The Education Company's processing for the purposes described in this Privacy Policy.

7. Automated Decision Making

We may process your Personal Data in Communications with automated decision-making processes. The results of this automated processing are for your own informational use and are not stored by us or shared with anybody else, and this automated processing does not have any legal affect or otherwise significantly affect you.

8. How We Use Your Data

We use your Personal Data for various purposes described below, mostly involved in providing the service. We use information that we collect about you or that you provide to us, including any Personal Data:

to present our Websites and their contents to you;
to provide you with information about the SPIRIT Services that you request from us;
to provide you with the SPIRIT Services that you subscribe to;
to fulfill any other purpose for which you provide it;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to notify you about changes to our Websites or the SPIRIT Services; and
for any other purpose with your consent.

9. Disclosure of Your Data

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We may disclose your Personal Data to a few third parties, as described below. For example, we share data with your email and calendar provider, such as Google or Microsoft. We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

to our subsidiaries and affiliates;
to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Specifically, these entities provide IT and infrastructure support services, and payment processing services. Our payment processor's privacy policies may be found at https://recurly.com/legal/privacy
to your email and calendar service provider;
to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of The Education Company, Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by The Education Company, Inc. about the SPIRIT Services' users is among the assets transferred;
to fulfill the purpose for which you provide it. For example, if you give us an email address to use the "Send Later" feature of the SPIRIT Services, we will store your Communications on our servers and transmit the contents of that email and your email address to the recipients after the time you specify;
In public, user-facing educational and marketing content, provided that all such information is aggregated and does not identify any individual.
to the recipients of your Communications that you specify; and
with your consent.

We may also disclose your Personal Data:

to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of The Education Company Ltd., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

10. Your Rights Regarding Your Data and Accessing and Correcting Your Data

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

Access and Update. You can review and change your Personal Data by notifying us through the contact information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing, but we have retained it as permitted by law.
Portability. To the extent the Personal Data you provide The Education Company is processed based on your consent or that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies. If you delete your Communications from the your email or calendar service or client, copies of your Communications may remain viewable in cached and archived pages on websites used to access your calendar or email, or might have been copied or stored by recipients of your Communications.
Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods below or through the "Get in Touch" link on our Websites. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.

11. Security

Information transmitted over the Internet is never completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by making sure you don't remain logged in on shared devices and making sure you have good passwords on personal devices. We don't have any systems that currently ask you to create a password, but when and if we do, please follow good password practices.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions and Communications processed by the SPIRIT Services is encrypted both in transit and at rest.

The safety and security of your information also depends on you. Please be careful to log out of the Service on any shared computers and use passcode protection on any device where you remain logged into the Service. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites or SPIRIT Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the SPIRIT Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures used in the SPIRIT Services.

12. Data Retention

We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:

on our backup and disaster recovery systems;
for as long as necessary to protect our legal interests; and
and to comply with other legal requirements.

The Education Company will retain your Communications for only as long as necessary to provide you with the Services and we will retain your Personal Data for the entire time that you keep your account open. After retention of your Communications is no longer necessary and after you close your account, we may retain your Communications or Personal Data, as applicable:

for as long as necessary to comply with any legal requirement;
on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

13. Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Websites and in the SPIRIT Apps. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Websites' or SPIRIT Apps' home page/screen. If we make material changes to how we treat our users' Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Websites' or SPIRIT Apps' home page/screen. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this Privacy Policy to check for any changes.

14. Contact Us

If you wish to contact us about any of the information in this policy, or about anything else, our information is below.

If you have any questions,concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact us through our support email or our contact us page on our company site shown below.

To Contact The Education Company (Processor)
The Education Company

Denne Court

Oad Street, Hengist Field

Borden

Kent

ME9 8LT

[email protected]