Last modified: July , 2019
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 policy applies to information we collect:
It does not apply to information collected by:
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.
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:
We collect this information:
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:
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:
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:
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 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):
6. Special Category Data
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:
9. Disclosure of Your Data
We may also disclose your Personal Data:
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.
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:
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:
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.
To Contact The Education Company (Processor)
The Education Company
Oad Street, Hengist Field
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