This policy is effective 18 May 2018.

At School Pretests, we’re working hard to serve our schools and their pupils. Looking after the personal data schools share with us is a hugely important part of this. We want you to be confident that your data is safe and secure with us, and understand how we use it to offer you a better and more personalised experience. By using our site you agree to accept this privacy policy.

This policy may be reviewed from time to time so please check back here each time you submit personal data to us. You may also receive a privacy notice specific to the service you are receiving.

This policy should be read in conjunction with our Terms and Conditions and are applicable to School Subscribers, to their Pupil(s) and Parents or legal guardians.

We are committed to doing the right thing when it comes to how we collect, use and protect your personal data.

That’s why we’ve developed this privacy and cookies policy (“Policy”), which:

• sets out the types of personal data that we collect
• explains how and why we collect and use your personal data
• explains when and why we will share personal data within School Pretests and with other organisations; and
• explains the rights and choices you have when it comes to your personal data

We want you to be clear about what this Policy covers. This Policy applies to you if you use our services (referred to in this Policy as “our Services”). Using our Services means communicating with us over the phone, or online (including email) or otherwise using any of the websites (“our Websites”) where this Policy is posted. This Policy also applies if you contact us or we contact you about our Services.

1. Personal data we collect

This section tells you what personal data we may collect from you when you use our Services and what other personal data we may receive from other sources.
We store data for as long as it is necessary to provide our service to you and others. Information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide service.

1. When you register for our Services, you may provide us with:
• Your personal details, including your name, school postal and billing addresses, email addresses, phone number, date of birth, relationship to a data subject, proposed name and year of entry to a senior school.
• Your account login details, such as your username and the password that you have chosen.
2. When you use our online service or browse our Websites we may collect:
• Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers).
• Family relationships (if any) of multiple registered Pupils.
• The time, duration and results of your activities when you login.
3. When you contact us or we contact you about our Services, we may collect:
• Personal data you provide about yourself anytime you contact us about our Services (for example, your name, username and contact details), including by phone, email or post or when you speak with us through social media.
• Details of the emails and other digital communications we send to you that you open, including any links in them that you click on.
• Your feedback and contributions.
4. Other sources of personal data

Further interaction may involve the voluntary provision of information to us outside of these contexts (for example, in general correspondence). This other personal data might help us to:

• review and improve the accuracy of the data we hold; and
• improve and measure the effectiveness of our communications.
2. How and why we use personal data

This section explains in detail how and why we use personal data.

1. Make our Services available to you
• Manage the accounts you hold with us.
• Process your orders.



Why do we process your personal data in this way? We need to process your personal data so that we can manage your customer accounts, provide you with the services you want and help you with any orders.

2. Manage and improve our day-to-day operations
• Manage and improve our Websites.



Why do we process your personal data in this way? We use cookies and similar technologies on our Websites to improve your customer experience. Some cookies are necessary so you should not disable these if you want to be able to use all the features of our Websites. You can disable other cookies but this may affect your customer experience. For more information about cookies and how you can disable them, see the cookies and similar technologies section.

• Help to develop and improve our product, services, information technology systems, know-how and the way we communicate with you.



Why do we process your personal data in this way? We rely on the use of personal data to carry out internal research and development, and to improve our information technology systems (including security) and our product and service. This allows us to serve you better.

• Detect and prevent fraud or other crime.



Why do we process your personal data in this way? It is important for us to monitor how our Services are used to detect and prevent fraud, other crimes and the misuse of services. This helps us to make sure that you can safely use our Services.

3. Personalise your School Pretests experience
• Use your online browsing behaviour to help us better understand you and your educational needs and provide you with a more personalised service.



Why do we process your personal data in this way? Looking at your browsing behaviour allows us to personalise our services for you and assess your performance. This helps us meet your needs.

• For baseline assessment.

Why do we process your personal data in this way? Baseline assessment enables us to create progress measures for schools. For this purpose only, we retain some pseudonymized data to help assess children’s needs, abilities and potential. Pseudonymization is the separation of data from direct identifiers so that linkage to an identity is not possible without additional information that is held separately. When an account is deleted, that additional information is also deleted but we retain the pseudonymized data for the purposes of baseline assessment.

4. Contact and interact with you
• Contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us.

Why do we process your personal data in this way? We want to serve you better so we use personal data to provide clarification or assistance in response to your communications.

3. Sharing personal data with Service Providers

This section explains how and why we share personal data with Service Providers.

We work with carefully selected Service Providers that carry out certain functions on our behalf. These include, for example, companies that help us with technology services, storing and combining data. We only share personal data that enable our Service Providers to provide their services.

When we share personal data with these companies we require them to keep it safe, and they must not use your personal data for their own marketing purposes.

Your personal information will only be shared outside of School Pretests and other partner agencies where there is written agreement and where it is necessary to provide you with the service you have requested and where the law allows or requires it. It may also be used to help improve the service you receive and to develop other services.

For the prevention and detection of crime we may disclose your information to law enforcement or government authorities if they request it.

We will not make your information available to anyone outside of your written instruction unless the personal information has been pseudonymised or anonymised.

4. Sharing personal data with other organisations

This section explains how and why we share personal data with other organisations.

We may share personal data with other organisations in the following circumstances:

• if the law or a public authority says we must share the personal data;
• if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud);
• to an organisation we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organisation receiving your personal data can use your personal data in the same way as us; or
• to any other successors in title to our business.


5. How we protect personal data

We know how important it is to protect and manage your personal data. This section sets out some of the measures we have in place.

We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep this data safe. We only authorise access to employees who need it to carry out their job responsibilities.

We protect the security of your information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).

We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We may occasionally ask for proof of identity before we share your personal data with you.

However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.

We are especially conscious of the need to protect information concerning children using the Site. We design our processing with children in mind from the outset and use a data protection by design and by default approach. We minimise what data is required in order to provide an effective service to our subscribers. Personal information is stored in electronic databases that use industry-standard technical safeguards including, but not necessarily limited to, password and/or cryptographic key-based authentication controls on servers which house personal information, browser-based SSL encryption, and other storage system access control mechanisms to protect the integrity of internal databases and prevent unauthorised access.

We require parental consent in order to process the data of any child who is under the age of 13, and make reasonable efforts (taking into account the available technology and risks inherent in the processing) to verify that the person providing consent holds parental responsibility for the child. We regularly review available age verification and parental responsibility verification mechanisms to ensure we are using appropriate current technology to reduce risk in the processing of children’s personal data.

Whilst we rely on parental consent, a child-friendly Privacy Policy written in plain, age-appropriate language is available to children.

The personal data we collect from you will remain inside the European Economic area (EEA) unless you are informed otherwise. By submitting your personal data you agree to the transfer, storing or processing within the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where a subscription has been terminated, an account deleted or where an account has been inactive for a period of 12 calendar months accounts will be automatically deleted after no later than 90 days.

6. Cookies and similar technologies

We use cookies and similar technologies, such as tags and pixels (“Cookies”), to personalise and improve your customer experience as you use our Websites and to provide you with relevant online advertising. This section provides more information about Cookies, including how we use them and how you can exercise your choices about our use of Cookies.

1. How we use Cookies

Cookies are small data files that allow a website to collect and store a range of data on your desktop computer, laptop or mobile device.

Cookies help us to provide important features and functionality on our Websites and we use them to improve your experience. For example, we use Cookies to do the following:

• Improve the way our Websites work

Cookies allow us to improve the way our Websites work so that we can personalise your experience and allow you to use many of their useful features.

For example, we use Cookies so we can remember your preferences when you return to our Websites.

• Improve the performance of our Websites

Cookies can help us to understand how our Websites are being used, for example, by telling us if you get an error messages as you browse. These Cookies may collect information about your online behaviour, such as your IP address and the website you arrived from.

These Cookies collect data that is mostly aggregated and anonymous.

• Your choices when it comes to Cookies

You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or other device. You can find more detailed information about how you can manage Cookies at the All About Cookies and Your Online Choices websites.

If you choose to disable some or all Cookies, you may not be able to make full use of our Websites. For example, you may not be able use any of our services that require you to sign in.

7. Disclaimer and copyright

Although we make reasonable efforts to keep the information on this website up to date and accurate, we make no representations, warranties or guarantees whether express or implied, that the content on our site is accurate, complete or up to date. School Pretests will not be held responsible for any loss, damage or inconvenience caused as a result of reliance on such information.

Unless otherwise stated, the design, layout and all the material published on this website is the copyright of School Pretests. We authorise you to view and download the material on this website only for your personal, non-commercial use. You must keep any copyright or other notices contained in the original material on any of the material you download. Any use of the material on this website, including distribution, requires express written permission from School Pretests.

8. Your rights

You can access the information we hold on you through your account settings. However, if you would like a copy of this personal data, please write to:
Data Protection Officer, School Pretests, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

You can also email us at info@schoolpretests.co.uk.

The law allows us to charge an administration fee of £10. If you write to us by post, please enclose a cheque or postal order for £10 made payable to “School Pretests”.

We want to make sure that the personal data we hold about you is accurate and up to date. If any of the details are incorrect, please let us know and we will amend them.

You can delete your account any time. If you delete your account:

• You can’t regain access once it’s deleted.
• It may take up to 90 days to delete data stored in backup systems. Your information isn’t accessible during this time.
• Copies of some material (example: log records) may remain in our database but are disassociated from personal identifiers.


9. How to contact us

Email: info@schoolpretests.co.uk

Write to us at:
School Pretests Ltd
71 – 75 Shelton Street
Covent Garden
London
WC2H 9JQ


Personal information is collected by School Pretests which is registered with the UK’s Information Commission.