Firefly Learning Limited
Last Updated: 09/05/2018
Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is Firefly Learning Limited of 100 Cambridge Grove, London, England, W6 0LE.
Changes to this Policy: We will post any modifications or changes to the Policy on www.fireflylearning.com. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email prior to such changes(s) taking effect.
Purposes of Processing
What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the European Data Protection Directive 95/46/EC until 25 May 2018, and from 25 May 2018 onwards, as defined in the General Data Protection Regulation 2016/679 (“GDPR”) and any successor legislation, including, to the extent that the GDPR is no longer applicable in the United Kingdom, any implementing legislation or legislation having legal effect in the United Kingdom. This includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Services and complete requests that you make via the Site, such as requesting a free trial (see ‘Using Your Personal Data’ for more information). If you have created a profile/registered with us, you will have been asked to tick to agree to provide this information in order to access our Services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Services.
Collecting Your Personal Data
We collect information about you in the following ways:
Information You Give Us. This includes:
- the personal data you provide when you register to receive a free trial of our Applications, or when you complete our online enquiry form, including your first name, last name, school, position, and email address;
- the personal data you upload to our Applications;
- the personal data you provide when you report a problem with our Services or when we provide you with customer support;
- the personal data you provide when you correspond with us by phone, email or otherwise.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Services. For example, when visiting our Site, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the sections on Cookies below.
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognise your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
Type of cookie
These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.
Using Your Personal Data
We may use your personal data as follows:
- to operate, maintain, and improve Services;
- if you have an account with us, to manage your account, including to communicate with you regarding your account;
- to respond to your comments and questions and to provide customer service;
- to send information including technical notices, updates, security alerts, and support and administrative messages;
- with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
- to link or combine user information with other personal data;
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
- as described in the “Sharing of your Personal Data” section below.
Sharing Your Personal Data
We may share your personal data as follows:
- Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so. Your personal data will be made available to appropriate users within the school community that have been authorised by you.
- Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data
- Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
When we use the term “anonymous data”, we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyse usage patterns in order to make improvements to our Services.
Third Party Sites
Our Site may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
User Generated Content
You may share personal data with us when you submit user generated content to our Services. Please note that any information you post or disclose on our Services will be available to other users of our Services that you have authorised. We urge you to be very careful when deciding to disclose your personal data, or any other information, on our Services. Such personal data and other information will not be private or confidential once it is published on our Services.
If you provide feedback to us, we may use and disclose such feedback on our Services, provided we do not associate such feedback with your personal data.
International Data Transfer
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and other third parties outside the country in which you reside, including, but not limited to the United States and Australia, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We seek to use reasonable organisational, technical and administrative measures to protect personal data within our organisation. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Information section below.
We will only retain your personal data for 2 years unless a longer retention period is required or permitted by law (for example for regulatory purposes).
Our Policy on Children
Many aspects of our Services are aimed at children under 13. We obtain parental consent to the processing for children under the age of 13 and make reasonable efforts to verify that the person providing consent holds parental responsibility for the child. We make reasonable efforts (taking into account the available technology and the risks inherent in the processing) to verify that anyone who provides their own consent is at least 13 years old. Children are therefore able to register with our Services to view content, upload content, and receive communications from other users and so on. We will not require a child to provide more information than is reasonably necessary to allow them to register and use our Services.
- Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the Services may be ineffective upon opt-out.
- You may access the information we hold about you at any time [via your profile/account] or by contacting us directly.
- You can also contact us to update or correct any inaccuracies in your personal data.
- Your data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us using the details in the Contact Information section below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: firstname.lastname@example.org. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
We welcome your comments or questions about this Policy. You may contact us in writing at email@example.com or The Aircraft Factory, 100 Cambridge Grove, London, W6 0LE, UK.