PLN Privacy Policy relating to the use of Language Boosters application
Introduction
The purpose of this policy is to explain how Primary Languages Network Limited collects, protects, and uses personal data associated with the Language Boosters application. Primary Languages Network is committed to ensuring that any personal data supplied by its Clients and end users or is otherwise generated by its business activities is collected and processed fairly and lawfully. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.
Who are we?
We are Primary Languages Network Group Limited.
Our address is Abney Hall, Manchester Road, Cheadle, SK8 2PD
Our designated Data Protection officer is Sylvia Brown, Customer and Operations Manager and you can contact her by post at the above address, by email at: sylvia@primarylanguages.network or by telephone on +44(0)161 4288063.
What types of personal data does Primary Languages Network collect for Language Boosters?
Primary Languages Network needs certain personal data to enable it to provide its products and services to its Clients and end users. The personal data collected may include: Forename & Surname and school name. This information is optional. Admin / Teachers have on option to use more generic naming for enhanced safety eg. Pupil 1. The information is only used within the Language Boosters application and never circulated to 3rd parties.
How does Primary Languages Network obtain personal data?
Primary Languages Network obtains personal data via registration. i.e. setting up of personal login details for the use of the application.
There is a recommended way of setting pupil usernames and passwords client schools will be shown on registration. This involves randomly generated usernames and shared class password. This has been chosen for high level of security as well as ease of use by younger pupils and your control over the login details. PLN will not be liable for breeches of privacy when login details, either user names or passwords, have been set in a different manner. Teachers / Admin can access or change pupils’ username information but not the passwords. If a pupil /pupil’s parent or carer sets a private password, admin or teacher will not be able to retrieve it but the pupil would be able to reset their own password.
Primary Languages Network has no access to password information.
QR code sharing
When onboarding pupils outside school via QR code, the school is responsible for this being done by secure means in line with your own safeguarding policy.
How does Primary Languages Network use the personal data it holds?
Lawful basis for processing
Primary Languages Network have determined that the processing of the data you provide is necessary in order for us to fulfil our contractual duty to you, which includes access to the application and monitoring of pupil performance on the application. This is only accessible to the teachers and admin in any particular school and is never shared with third parties. There will be no direct contact on behalf Primary Languages Network with individual pupils.
Network updates
Primary Languages Network may from time to time inform its Clients representative (Admin) through email about possible updates or changes to the product.
You have a right to opt out of this communication.
Third Party Data Collection
Primary Languages Network use first party cookies to report on how Primary Languages Network is used by Clients which allows us to monitor and improve our service to you. It is important to note that Primary Languages Network does not collect any identifiable or personal information at all through this system, and it is only used to collect statistics on patterns of use and to monitor the performance of our services.
Individual pupil sign ups use cookies to remember login details and track progress of the game and are not shared with third parties or access any personal information beyond login details.
Does Primary Languages Network transfer personal data overseas?
Primary Languages Network is provided globally from several different countries, so depending upon where you access the service from, your data may be processed elsewhere. To fulfil our Client service obligations, it may be necessary for Primary Languages Network to transfer and process personal data outside the country in which the personal data is collected. This will include transfers to the United Kingdom and all such data transfers are encrypted, password protected and only accessible to our management team at Primary Languages Network.
Maintenance of information
Primary Languages Network shall retain your personal data in accordance with all applicable laws and remain consistent with the purpose in collecting your personal data and may be stored on one or more databases directly maintained by Primary Languages Network. We employ industry standard security measures to protect the confidentiality of the information. Although Primary Languages Network cannot guarantee that any loss, misuse or alteration of data will not occur; every effort is made to prevent such occurrences.
To whom does Primary Languages Network disclose personal data?
Primary Languages Network will share personal data between staff in order to fulfil support obligations to its Clients.
As a general rule, Primary Languages Network does not disclose personal data to any third parties except where Client consent has been obtained, where Primary Languages Network is under an obligation by law to disclose personal data or where Primary Languages Network has contracted with third parties to assist in providing services to Primary Languages Network Clients.
How does Primary Languages Network protect the personal data it holds?
Primary Languages Network takes Client confidentiality and security very seriously. Primary Languages Network has implemented appropriate internal security procedures that restrict access to and disclosure of personal data within Primary Languages Network. These procedures are reviewed from time to time to determine whether they are being complied with and are effective.
Primary Languages Network does not use any of the Clients personal information for the purpose of marketing. The data we hold does not include any of the items below:
interest or participation in adult activities (including alcohol, gambling, adult dating, pornography, etc.)
sexual behaviour or orientation
racial or ethnic information
political affiliation
trade union membership or affiliation
religion or religious belief
financial status or situation
the commission or alleged commission of any crime
Primary Languages Network will also actively investigate and cooperate with law enforcement agencies any allegations of abuse or violation of system or network security.
Client responsibility
Clients are responsible for the security of their login and password. Make sure you keep it in a safe place and only share with authorised staff. Always remember to log out after your session ends, to ensure that others cannot access your private personal information. You should take this precaution even if you are not using a public computer.
Clients' Rights
The law in certain jurisdictions (including countries within the European Economic Area) gives individuals whose personal data is held by Primary Languages Network specific rights to access and rectify personal data held about them.
These include the right to:
obtain from Primary Languages Network confirmation that personal data is held, as well as a written description of such personal data, the purpose(s) for which it is being used, the source(s) of the personal data and details of any recipients;
request the deletion or rectification of personal data which is inaccurate;
opt out of any unsolicited information sent by Primary Languages Network regarding products and services.
"Personal data" is information about an individual that could, alone or together with other information personally identify that individual. Information such as full name, address, email address and telephone number are examples of Personal data. Dynamic I.P addresses and anonymous log data will not be classed as personal data.
Contact Details
If any individual wishes to contact Primary Languages Network regarding the personal data held about them or has any other question about data privacy procedures, they should contact our Data Protection Officer by email to sylvia@primarylanguages.network or send a letter to the companies official address on this notice.
Your right to complain
If you have a complaint about our use of your information, you can contact the Information Commissioner’s Office via their website at http://www.ico.org.uk/concerns or write to them at:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
You can also telephone 0303 123 1113 (local rate) or 01625 545745 (national rate).
Policy Updates
As part of Primary Languages Network's commitment to compliance with data privacy requirements, and to reflect changes in Primary Languages Network's operating procedures, Primary Languages Network may update the terms of this policy from time to time.