Get My Grades Ltd. Simplified Privacy Policy

Last Updated: 21/05/2018

 

Get My Grades Ltd

Simplified Privacy Policy – Summary

We understand that privacy policies can be seen as long and scary legal documents. For this reason, we created a simplified version, with a summary page which is much easier to read. To clarify, this is not our full privacy policy, which can be found here. To see more detailed information, scroll down to the full simplified version.

What is a privacy policy and what is personal data?

Our privacy policy is a document which informs you of what ways we collect and how we process your personal data. Your personal data is any form of information that can be used to personally identify you.

What personal data do we collect?

Get My Grades collects your personal data, to create your profile and personalise it to you and other information including payment method and your academic record.

How we use this data?

The personal data we collect is used to personalise your account and how we interact with your account following your choices. The data is also collected so that our platform can work, to track student performance and to improve how our platform works in future.

How do we collect this data?

Most of the data we collect will be entered by the user or the institution (such as a school) the user is part of. We will also automatically collect academic data for you as students work on the platform.

How we disclose data?

We will only disclose personal data to other parties when you have given us permission to do so. This includes other institutions or our research partners. We may also disclose your information to the police or other public bodies if there is an issue with criminal activity or safeguarding.

Where do we store this data?

The data will be stored in secure servers in the EEA but may be sent outside of this region at times. This data will be stored for two years after you end your subscription but can be deleted at your request.

What are my rights to this data?

The personal data we store is your data, this means you have a lot of rights to the data, which are:

  • You have the right to be informed of what data we process.
  • You have the right to access what data we store.
  • You have the right to have your data corrected where it is incorrect.
  • You have the right to have any data we hold on you deleted.
  • You have the right to restrict us processing your data if you believe we are processing your data unfairly.
  • You have the right to access and re-use your personal data.
  • You have the right to object for us to process your personal data.
  • You have the right to lodge a complaint against our data processing methods with the ICO.

What does Get My Grades do to protect personal data?

Get My Grades uses industry standard processes to protect your personal data, this includes the training provided to our staff to protect your data. However, you have a responsibility to ensure your account password is kept confidential (ie. don’t tell anyone else your password).

What does Get My Grades do to protect children’s data?

Get My Grades will not process any students data under the age of 18 until we have the parent/guardians consent to do so (which, in some cases, may be through a school or other institution).

What right does Get My Grades have to process my data?

Get My Grades processes data for its own legitimate interest. This being to provide an educational platform to students and help them learn. We have been careful to only process data that is necessary for us to do this and does not infringe on your own personal rights and freedoms.

How does Get My Grades work with schools?

From time to time, Get My Grades will act as a data processor for schools. We will work with schools to ensure we only process data that is in line with both of our needs and the needs of its students.

Will this privacy policy change?

The Get My Grades privacy policy will change from time to time. When we do make any changes, we will contact you to ensure that you know changes have been made.

If I have any questions about the policy, how can I contact Get My Grades?

If you have any questions about this privacy policy, you can contact the Get My Grades team at [email protected]

Simplified Privacy Policy – Full

Collection and Use of Personal Information

This Privacy Policy has been written to explain our binding Privacy Policy – which you can find here. We hope this helps to explain how important your privacy is to us, the information we will collect, and what we will do with it, as well as your rights.

When you use the Get My Grades Platform, we will collect and process some of your personal data. Personal data is any information that can be used to personally identify you. The security, privacy and data protection of your personal data is very important to us. Whether you are a user or potential user of Get My Grades, this Privacy Policy explains:

  • what data we collect, and how it is collected
  • how we disclose and use data
  • where data is stored
  • your rights to your data
  • the choices you have about your data

Please take time to read this document. If you have any questions Section 12 explains how you contact us with them.

1.  The Data we Collect:

Get My Grades will collect the following pieces of data:

  • When you create your profile, we will collect data to personalise your profile, including your title, name, mailing address, email address, contact preferences and payment method/status.
  • We also allow you to further personalise your profile by giving you the option to add pictures.
  • Get My Grades will collect sensitive personal information on you including race, gender and ethnic background. You can choose if you do or do not want to share this information with us.
  • When you use the Get My Grades platform, we will collect data on your academic achievement and performance.
  • When you create additional profiles that link to your account, we may collect information on those people such as the title, name, mailing address, email address, phone number, contact preferences.
  • In certain situations, Get My Grades may ask for and collect details on your SEND (Special Educational Needs and Disabilities), EAL (English as an Additional Language) and FSM (Free School Meals) status.
  • We collect information on how you use the site such as your IP Address (a code that identifies your computer network), location and which version of web browser you use, by using cookies and page tagging techniques.

2. How We Use Data:

We collect personal data for a variety of reasons, in line with our legitimate interest, as well as your interests, rights and freedoms. We use the data in the following ways:

  • Personal information is used to identify and personalise your account so that you can use the platform efficiently.
  • Personal information allows us to keep in touch with you about Get My Grades’ latest announcements, updates and events. If you don’t want to be part of this mailing list, you can unsubscribe via your emails, or you can update your preferences through your profile.
  • We may use your personal or sensitive information to do internal research. This research helps us to maintain, improve and develop our system, including what content to present, what assignments to recommend, or other features.
  • We collect your academic achievement, history and performance. This helps us to provide you with the best service. Along with our algorithms and software, this data helps us set the skill level of questions you will see, as well as which concept pages or assignment to suggest you complete.
  • We will use the data from your linked accounts to provide information and progress on the user’s account.
  • We will use the personal information to communicate with you about purchases and changes to subscriptions, terms and conditions, contracts, and policies. This information is key to the running of the platform, as it tells us about purchases and the services we are providing.
  • We may use your personal information for internal purposes such as auditing, data analysis, the design or delivery of services and customer communications.
  • Your data may be used for external research with our research partners. However, if your data is used it will be made anonymous, and we will make sure it is not possible to be tracked back to you, or any other user. We will only use identifiable personal data with our research partners if you have given us your consent to do this.
  • We may collect information about your activities, IP address, location and which version of the browser you are using. This information helps to understand which parts of our website and platform are of the most interest to you, and help us to improve the user experience and how to provide more useful information to our customers.
  • We may collect details of any questions you have about our products. This helps us to answer future questions more efficiently, and also to make improvements based on your feedback. We may use your questions for marketing, customer support, employee training or research, but we will make sure that this is done anonymously, and it is not possible to be tracked back to you, or any other user. As before, we would only include personally identifiable information if you have given us your consent to do this.

3. The Collection of Data:

Get My Grades will collect data in a variety of ways. Most of the data we collect is the information that you enter onto our platform yourselves. This can include any personal information that is needed to create your profile or other information you choose to give us. Any sensitive personal information will need to be entered by you, and you’ll have the choice whether or not to provide some information. We also autonomously collect data on academic achievement based on concepts you have completed, and questions you’ve answered.

We may also collect personal information from other data controllers such as institutions, academies, schools, tuition agencies, research organisations and other third-party organisations. This is allowed when we have a legitimate interest in the data, and the other parties can legally share it. If we receive any data which we don’t have a legitimate interest in processing, or we believe it has been collected without consent, we will either delete the information from our systems or make the data anonymous so it cannot be traced back to you or any other user.

We will also collect data through cookies. These provide us with information that informs us of how you use our website and where you are located.

4. How We Disclose Data:

Get My Grades will only share your personal data with other parties if and when you have given us permission to do so, or when the other party is linked to you in some way. Other parties you might be linked to include:

  • tutor or tuition agency
  • school, academy or similar

We may use sub-processors to process data on our behalf, in line with our instructions and this policy. All data will be protected by industry standard data security measures. All staff who have access to such data will be given the appropriate training. We will not sell or rent personal data to marketers or other unrelated third parties without good reason.

We may share personal data with a public body (e.g., the police or local authorities) if we believe there is a good reason to do so. Some reasons we may share data with public bodies are:

  • prevention, detection or prosecution of criminal offences
  • safeguarding children or young people
  • any reason that is an overriding public interest

We may share your data with our research partners. Unless you specifically give us your consent, this data will be anonymous, and it will not be possible to trace it back to you. The data will be protected by the measures you will read about in Section 7, and we will provide appropriate training for all staff who have access to the data.

5. Where Data is Stored:

We store your data on secure servers in the European Economic Area (EEA). At times, we may send data outside of the EEA to improve our services, at all times the data will have the appropriate checks and security measures.

Data will be stored here for up to two years after your account is deactivated (or until you ask for it to be deleted). This allows you to open your account after it is deactivated, to restore their personal and academic data on our system. After the two years, we will delete all personal information and additional information from your account and our servers. If you would like us to erase this data earlier, follow the instructions in Section (6), Subsection (D). If you would like to obtain and re-use this data, follow the instructions in Section (6), Subsection (F).

6. Access and Choice (including rights of data subjects):

Get My Grades takes your privacy and security very seriously; we have outlined your rights to your data that we store and process. The following eight sub-sections show you exactly what rights and freedoms you have to your data, following the General Data Protection Regulation. If you have any questions about accessing your data, contact us as instructed in Section (12).

If you want to exercise any of the rights included below, you will need to notify us in writing. We may also ask you to provide proof of identification. Data is valuable and often difficult to restore, so we need to be sure that the person asking for data to be released or deleted is who they say they are.

We may provide features or tools to help you to exercise the rights included below, which we might ask you to use instead of contacting us directly. We will still be happy to confirm whether or not you have successfully completed what you were trying to do if there isn’t any other way to check.

    A. Right to be informed

You have the right to be informed about your personal data, including any details on what data we are processing, how we collect and share data, and where data is stored. All of this information can be found in this policy, but if you have any further questions, please contact us by email: [email protected].

    B. Right of access

You have a right to access your personal data, as well as any additional information about you that is stored and processed by Get My Grades. You also have the right to know and confirm the data that we are processing, access this personal data and any other information we have collected about you. We will provide the first copy of this data for free, but we may charge a fee if the request(s) is:

  • without good reason
  • excessive
  • repetitive

We will try to provide this information as soon as possible, but it may take up to 20 working days. We may ask you to specify the information that you have requested, depending on the amount of information that we have for you. If you would like access to any of this data, contact us by email: [email protected].

    C. Right to rectification

You have the right to have your personal data corrected if it’s inaccurate or incomplete. Once we are aware of data being inaccurate or incomplete, Get My Grades will correct it as soon as possible. Sometimes this may take up to 20 working days after you have requested a change. You can contact us by email: [email protected]

In many cases, you will be able to correct information yourself through the settings and features on our platform. If there is a feature that allows you to change information yourself, we may ask you to use these to change the incorrect information yourself.

    D. Right to erasure

You have the right to have your data deleted from our system is there is no reason for it to continue being processed. Get My Grades will remove all personal and additional data about you (and other users) within two years of your subscription ending. This helps with internal research and development, but also allows you to return to the platform and have your data restored if you wish to.

You have the right to ask us to delete your personal and additional data within the two years following the end of your subscription. Our decision to go ahead with the request will rely on one of the circumstances included below:

  • The personal data is no longer needed for the purpose it was originally collected or processed.
  • You withdraw your consent for your data to be stored or processed.
  • When you object to the processing, and there is no overriding legitimate interest reason to continue.
  • The personal data was unlawfully processed (this includes a breach in the GDPR).
  • The data must be erased to comply with a legal requirement.
  • The data was obtained by a child signing up without permission of an adult.

If we have shared any of your data with another organisation, and you have requested that we delete it, we will contact them and inform them of the request. We will request that they delete any copies that have of your data.

Get My Grades takes the storage and processing or your data very seriously, so if you want us to delete data because of one of the above reasons, we will do so within 7 working days. If you would like to make a request for data to be deleted, contact us by email: [email protected].

E. Right to restrict processing

You have the right to ask us to stop processing your data, but to continue storing it, until you give us permission to process it again. This is called suppressing your personal data. You can ask us to do this in the following circumstances:

  • Where the accuracy of personal data is challenged, the data processors should suspend processing the data until the accuracy is checked.
  • When someone has objected to data being processed (as part of tasks of public or legitimate interest), and we are deciding whether our grounds override those of the person objecting.
  • When processing the data us unlawful, the person it is about asks us to suppress processing rather than erase their data.
  • If we don’t need the personal data anymore, but the person it is about needs the data for legal reasons.

If one of these applies to you or the user managing your account, Get My Grades will stop processing the data as soon as possible, or within 5 working days. If we have shared any of your data with another organisation, and you have requested that we stop processing it, we will contact them and inform them of the request. We will also let them know when we start processing data again, and why.  When we lift the restrictions we’ll let you know when and why.

    F. Right to data portability

You have the right to access and re-use your personal data for your own use. Get My Grades will provide this if you ask for it, as soon as possible, but it can take up to 20 working days. If data is needed by an important deadline, please inform us of this when you make your request. The information will be sent in a structured, commonly used and machine-readable form.

    G. Right to object

Get My Grades processes data through legitimate interest. This means that if you think our legitimate interest in processing your data (which you can find in Section 10), goes against your rights or freedoms you can object to the data being processed. You will need to provide reasons specific to your situation to use your right to object to processing.

If you object to us processing your data, you will need to email us the details: [email protected].co.uk. We will then stop processing your data, and reply to your objection, and explain our legitimate interest clearly.

    H. Rights related to automated decision making including profiling

Get My Grades will only use automated decision making to set questions or recommend subjects to you automatically. This decision making will be based on your academic progress and performance, not on the personal or sensitive information you enter into the platform. This has been designed to help you learn more efficiently as you are studying on our platform. In almost every case, the automated decisions are used to suggest progress.

If we ever use your personal data for profiling, it will be made completely anonymous. We have created safeguards and protections to protect your rights, freedoms and interests.

If you have any questions about the automated decision making, please email us: [email protected]

    I. Rights to lodge a complaint

Get My Grades takes the protection of your data very seriously, but if you feel we have not protected your data well enough, you have the right to make a complaint.

Our supervisory authority is the Information Commissioner’s Office, and you can direct any complaints to them. You can lodge your complaint on their website through the following URL, https://ico.org.uk/concerns/.

7. Security and Protection of Data:

Get My Grades takes data security extremely seriously and we have a number of strategies, policies and measures to keep the data we hold secure. These include:

  • Encryption of personal data while being stored or transferred.
  • Industry-standard technical measures to stop unauthorised access (we won’t go into detail about these, to increase the level of security).
  • Only employees, contractors or third parties with legal right to access and/or process data will have access to it.
  • All contracts with third parties will have appropriate requirements to protect any data they could need to access for any reason.
  • All employees with access to personal data will have relevant training.
  • Insurance (including cybersecurity cover) provided by a reliable insurer.
  • Policies within the company to stop any unauthorised transfer of data to third parties. This includes a ban on sending any data via email without consent – the consent will only be granted in person from a senior manager, once the identity of the person making the request has been confirmed. Remember, we will always need to verify your identity when you make a data request, and we may decline any request if you cannot prove your identity.

You, and other users whom we collect data from, have a responsibility to protect your own data. In our Terms and Conditions, we explain that you should keep your password safe, and not share it to stop others from accessing your data.

Get My Grades cannot be held responsible if data is lost or taken by unauthorised access if you have not kept your password safe, or it is guessed by a third party. If you have not kept your account or your password safe, and the data of others is lost or stolen you could be held responsible.

If you think there has been a security breach, you should email us all of the details as soon as possible: [email protected] We may block activity on your account if we see a good reason to.

8. Children:

Get My Grades understands the importance taking extra precautions to protect the privacy and safety of children (those under the age of 13) using the Get My Grades platform. Children under the age of 13 are legally required to have parental consent given before they can set up an account; Get My Grades requires all students under the age of 18 to have parental consent in order to use our platform. The only details we will process before receiving parental consent are a child’s first name and the email address of their parent or guardian. This will be used to send an email to the parent or guardian on behalf of the child with instructions on how to provide the necessary consent and to set up the child’s user account. If an account is not set up by a parent or guardian within 14 days, then we will delete the email address and the child’s first name.

Parents or guardians must review the terms and conditions and the privacy policy and then give explicit consent to allow us to process the child’s data before we can create a child’s user account. If consent is not given or is rejected at any point in time, then the child’s data and account will be deleted as soon as possible.

If at any time a parent or guardian needs to access, rectify or delete the child’s data, then they may contact us through Section 13 in the privacy policy.

9. Legitimate Interest:

To process data, Get My Grades needs a legitimate interest to do so. The legitimate interest we have is that for the platform to work and help you learn, we must process the personal data of our users. We process and track your data and the data of those linked to your account, to provide you with the best service.

Processing your personal data, and the data of anyone linked to your account, helps the platform to work to the best interest of you, your rights and your freedoms. This, as well as our lawful objective (which you can find in our Terms and Conditions), allows us to provide an online educational platform which adapts to your educational needs and shares data with other individuals and organisations linked to your account by the fee payer. This data also helps us to improve and maintain the platform, to give you the best experience possible while using it.

10. Get My Grades as a Data Processor:

When we are in contract with an institution (e.g. schools, tuition agencies), Get My Grades will act as the data processor. We will only process data according to the contract unless individual users ask us to and there is a legal reason for us to do this. The data controllers are responsible for protecting privacy rights and how data is shared with third parties (not associated with Get My Grades).  We will process data using our own security and privacy policies, our Terms and Conditions, and the legal instructions from our users.

11. Changes to this Privacy Policy:

As circumstances change, we may change this privacy policy from time to time. At the top of this page, we will note when the policy was last updated.

We will notify you about changes to this privacy policy through your user dashboard, as well as emailing you a reminder to check the new policy. 24 hours after updating the privacy policy on our website, we will assume you have seen these notifications and read the updated policy. If you disagree with the privacy policy, you should let us know as soon as possible. We may ask you to stop using the platform if you do not agree with the privacy policy. If you stop using the platform because you disagree with the privacy policy, you will not be eligible for a refund, unless you are entitled to one for another reason.

12. Contact:

If you have any questions about this privacy policy, please get in contact with the Get My Grades team by emailing us: [email protected].