White Rose Education Services Limited (trading as White Rose Maths) with company number 10831473 (“White Rose Maths” or “we”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website at whiterosemaths.com (“our Website”) (regardless of where you visit from) and tell you about your privacy rights and how the law protects you, including how we comply with the UK General Data Protection Regulation (“UK GDPR”) and other related legislation which relates to the use of personal data.
This privacy notice is divided into sections so you can navigate through to the specific areas set out below. Alternatively you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. We also operate cookies on our website and information about that is provided separately in our Cookie Policy.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how White Rose Maths collects and processes your personal data through your use of our Website, including any data you may provide through our Website when you sign up to our newsletter, sign up for one of our events, complete a website form, purchase a product or service or take part in a competition.
Our Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other statements or fair processing notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements those other notices and is not intended to override them.
CONTROLLER
For the purposes of our Website and the information collected through it, White Rose Education Services Limited (trading as White Rose Maths) is the data controller and is responsible for your personal data.
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.
CONTACT DETAILS
Our full details are:
Full name of legal entity: White Rose Education Services Limited (trading as White Rose Maths)
Name or title of Data Protection Officer: Adam Phillips
Email address: dataprotection@whiterosemaths.com
Head Quarters: Trinity Academy Halifax, Shay Lane, Halifax, HX2 9TZ
Postal Address: White Rose Maths, Maltings Road, Halifax, HX2 0TJ
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR OBLIGATIONS
This version was last updated on 30.11.2021 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you provide us with information about any other person, for example any other individuals within your organisation, then you must ensure that you have their consent to pass those details to us and for us to use those details in accordance with this privacy policy. You should also make sure that you bring this privacy policy to their attention.
THIRD-PARTY LINKS
Our Website may include links to third-party websites, plug-ins and applications. For example, we provide links to our social media pages, to our partners’ websites, such as TTS or Pearson, and, if you book a training event advertised on our website, you may be transferred to the website of a third party booking provider, such as Eventbrite, to complete your booking. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not usually collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) nor do we usually collect any information about criminal convictions and offences. We may collect these categories of data if you apply for a job with us in accordance with our employment and safeguarding obligations, as further explained in the table below.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you or the organisation you represent, or for another lawful reason and you fail to provide that data when requested, we may not be able to perform our obligations in accordance with the contract we have or are trying to enter into with you (for example, to provide you with goods or services), provide you with the information you require, or otherwise properly deal with your request. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you, including:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
See the table below, to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing support@whiterosemaths.com
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
|
To register you as a new customer |
Identity Contact |
Performance of a contract with you |
|
To register you for and make arrangements for you to attend one of our events which you have signed up for, including through one of our third-party booking providers, such as Eventbrite. Following the event, to send any training materials to you, for example copies of any presentation slides. |
Identity Contact Marketing and Communications |
Necessary for our legitimate interests (to administer and provide our training events to you and to send you course materials thereafter)
Performance of a contract with you |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
Identity Contact Financial Transaction Marketing and Communications |
Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: notifying you about changes to our terms or privacy policy, and asking you to leave a review or take a survey |
Identity |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
Identity Contact Profile Usage Marketing and Communications |
Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
Identity Contact Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
|
To ensure our third-party service providers can perform their obligations to us. |
Identity Contact Technical Profile Usage |
Necessary for our legitimate interests in ensuring that our third-party service providers such as IT providers, external consultants and contractors are able to provide those services. Performance of a contract with you, for example for a publisher or stockist of the relevant product to fulfil your order. |
|
To transfer personal data to third parties for the proper operation of our business. |
Identity Contact Technical Profile Usage Marketing and Communications |
Necessary for our legitimate interests, for example, to transfer to third parties to whom we may choose to sell, transfer, or merge part of our business or our assets. If a change happens to our business, the new owners may use your personal data in the same way as set out in this policy. |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
Identity Contact Profile Usage Marketing and Communications Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
Technical Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
Identity Contact Technical Usage Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
|
To deal with job applications which we may receive, including appointing service providers to assist us in the administration of those job applications. |
Contact Identity |
Necessary to perform a contract or to take steps at your request, before entering a contract. |
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
From time to time, we may use your Identity Data, Contact Data, Technical Data, Usage and Profile Data and Marketing and Communications Data to contact you with information about our products or services. You will receive marketing communications from us if you have requested information from us or have purchased goods or otherwise agreed to be included on our marketing list.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any entity outside the White Rose Maths group of companies for marketing purposes.
Opting-out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like further information about how we use personal data and the purpose which we might use it for, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the following parties for the purposes set out in the table in paragraph 4 above:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our External Third Parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK, Hubspot for example have servers based in the EEA.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please Contact us if you want further information on the other specific mechanisms used by us when transferring your personal data out of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, tax or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please visit the Glossary for further information about your legal rights concerning each category below.
If you wish to exercise any of the rights set out above, please Contact us
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the White Rose Maths Group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
EXTERNAL THIRD PARTIES
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.