Maths — No Problem! Privacy Policy
Introduction
We are Fig Leaf Promotions Limited, trading as "Maths — No Problem!". We respect your privacy and we are committed to protecting personal data you provide to us. This privacy policy informs you about how we look after personal data you provide to us when you use our Insights program (available through our website: (https://www.mathsnoproblem.com) regardless of where you visit it from, and it tells you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. Important Information and Who We Are
Purpose of this privacy policy
This privacy policy aims to give you information on how we process your personal data through your use of Insights. By using Insights, you acknowledge that you are accepting and consenting to the practices described in this policy.
It is important that you read this privacy policy together with the data processing agreement between you and us or any other policy we may provide on specific occasions when we are processing personal data on your behalf.
Data Processor
Fig Leaf Promotions Limited, part of the Fig Leaf Group, is the data processor responsible for processing the personal data provided by you on your behalf as part of our service offering, Insights. We are regulated under the UK General Data Protection Regulation which applies in the United Kingdom.
We are a member of group companies, which includes Fig Leaf Promotions Limited and Fig Leaf Promotions Canada Limited (“Fig Leaf Group”). This privacy policy is issued on behalf of the Fig Leaf Group so when we mention “Fig Leaf Group, "Maths — No Problem", “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Fig Leaf Group responsible for processing your data.
When using Insights and in the case of pupil personal data, you (the school) are the data controller of this information, and we are processing pupil personal data that you input into Insights on your behalf only in relation to the service offering. You determine what data is collected, what purpose(s) it is used for and who is allowed to process it. You acknowledge and agree that prior to utilising Insights and inputting pupil personal data into Insights to be processed by us you have received the requisite permissions from pupil parent or guardians to share pupil personal data with us.
Data Controller
In some circumstances we may act as a data controller in relation to personal data provided by you through Insights. We will only act as a data controller where we use the personal data provided by you to improve our product and service offering (including technical and usage data as discussed below), and where we can we will anonymise this data (so it becomes anonymous aggregated data and not personal data as discussed below) prior to using it.
When we collect Aggregated Data such as statistical, learning achievement or demographic data we may use it for any purpose. Aggregated Data may be derived from personal data you provide but is not considered personal data in law as this data does not directly or indirectly reveal an individual's identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We will also process and retain anonymous pupil results data to help us improve our product and service offerings. However, if we combine or connect Aggregated Data with any personal data so that it can directly or indirectly identify an individual, we treat the combined data as personal data.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
In the event that we are a data controller in relation to the personal data provided by you please refer to our privacy policy for how we will handle the personal data.
Contact details
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Fig Leaf Promotions Limited, trading as Maths — No Problem! (company number 07233807)
Name or title of data privacy manager: Priscila Heathcote (priscila@mathsnoproblem.co.uk).
General email address: hello@mathsnoproblem.co.uk
Postal address: 20 Old Bailey, London, EC4M 7AN.
We hope that we can resolve any query or concern you raise about our use of your information. However, under the UK General Data Protection Regulation you have the right to make a complaint at any time to the supervisory authority in the UK, which is the Information Commissioner’s Office who may be contacted at https://ico.org.uk/ or via telephone on 0303 123 1113.
Changes to the privacy policy and your duty to inform us of changes
This version was last updated on 16 August 2023. We will provide you with reasonable prior notice of substantial changes in how we use your information, including by email at the email address you provide.
If you would like this policy in another format (for example: audio, large print, braille) please contact us.
It is important that the personal data we process on your behalf is accurate and current. Please keep us informed if personal data you have provided to us changes.
Third-party links
Insights may include links to third-party websites, plug-ins and applications. 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 Insights, we encourage you to read the privacy policy of every website you visit.
2. The data we process on your behalf
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).
In the case of pupil personal data, as provided by you (the school):
- Identity data which includes first name, last name, pupil ID, gender, date of birth, name and address of school, year group and class.
- Optional learning needs data which includes English as an Additional Language status (yes/no), Special Educational Needs status (yes/no), Pupil Premium status (yes/no) and Free School Meals status (yes/no).
Please note that Special Educational Needs is classified as special category data as it relates to health. You acknowledge and agree that as the data processor in relation to pupil personal data we are relying on you (the school) having obtained consent from each pupil's parent or guardian to process pupil personal data including special category data where necessary.
Pupils cannot use or access Insights themselves and therefore no technical or marketing and communications data or contact data will be collected or processed about pupils.
If you fail to provide personal data
Where we need to process personal data under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). 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.
How is your personal data processed?
Direct interactions. You will provide us with pupil personal data when you upload information and data files to Insights
3. How we use your personal data
We will only process information provided by you on your instructions (unless otherwise required by law). We will not use pupils’ personal information for commercial purposes nor send marketing or advertising material to pupils. We will only process personal data provided by you in the following circumstances:
- To perform the contract we are about to enter into or have entered into with you; and
- Where we need to comply with a legal or regulatory obligation.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
To register you as a new customer |
|
|
To process and deliver your order including: | 1. Identity | 1. Performance of a contract with you |
To manage our relationship with you which will include: | 1. Identity | 1. Performance of a contract with you |
To enable you to partake in a prize draw, competition or complete a survey | 1. Identity | 1. Performance of a contract with you |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | 1. Identity 2. Contact 3. Technical | 1. 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) |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | 1. Identity | 1. 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 | 1. Technical 2. Usage | 1. 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 | 1. Identity 2. Contact 3. Technical 4. Usage 5. Profile | 1. Necessary for our legitimate interests (to develop our products/services and grow our business) |
To build products carrying relevant content that may be of interest to you in a professional capacity. | 1. Identity 2. Technical | 1. Necessary for our legitimate interests (to develop our products/services and grow our business) |
To produce filmed footage for our marketing/advertising content | 1. Identity | 1. Necessary for our legitimate interests (to develop our products/services and grow our business) |
To be able to accurately identify individuals and connect assessment information to the right individual. | Pupil data | 1. Performance of a contract with you. |
To allow users to filter assessment data based on different criteria and ensure equity of teaching and learning for children with different needs. (optional to provide) | Pupil data | 1. Performance of a contract with you. |
To provide you with information about individuals’ and groups’ learning. | Assessment data, such as test scores, marks per item, performance in comparison to sample cohort etc. | 1. Performance of a contract with you |
We will process anonymised pupil and assessment data to improve our services and products. When we process, analyse and use anonymised data, it can’t be linked back to any individual pupils, and is not considered personal data in law.
Cookies
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4. Disclosures of personal data you provide to us
You acknowledge and agree that we may have to share personal data you provide to us with the parties set out below for the purposes set out in the table in paragraph 4 above to act as sub-processors on our behalf.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then (subject to your instruction) the new owners may use personal data you provide to us in the same way as set out in this privacy policy.
We require all third parties to respect the security of personal data you provide to us and to treat it in accordance with the law. We do not allow our third-party service providers or sub-processors to use personal data you provide to us for their own purposes and only permit them to process personal data you provide to us for specified purposes and in accordance with our instructions. We will ensure that we put in place a contract with any sub-processor that we use that includes terms that offer an equivalent level of protection for the personal data as those in the contract between you and us.
5. International transfers
You hereby acknowledge and agree that we may and may need to share personal data you provide to us within the Fig Leaf Group and that you have gained the requisite permissions from the pupil's parents or guardians to allow us to do so. This will involve transferring your data outside the European Economic Area (EEA) to Canada.
Some of our external third parties/sub-processors are based outside the European Economic Area (EEA) so their processing of personal data on our behalf will involve a transfer of data outside the EEA:
- Google, our analytics provider, is based outside of the EEA;
- our advertising networks such as Mailchimp, Survey Monkey, Facebook, Twitter, Instagram are based both inside and outside the EEA; and
- Our providers of technical, payment and delivery services are based both inside and outside the EEA.
Whenever, with your permission, we use sub-processors or third parties and transfer personal data provided by you out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
6. Data Security
We have put in place appropriate security measures to prevent personal data you provide to us from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data you provide to us to those employees, agents, contractors, sub-processors and other third parties who have a business need to know. They will only process personal data on our instructions (in accordance with your 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 so immediately of any data breach. We will assist you in complying with your obligations as data controller regarding personal data breaches.
7. Data Retention
Retaining personal data
We will only retain the personal data you provide to us for as long as you instruct us to retain it for (subject to our normal practice as detailed below, unless otherwise agreed between us in writing).
You acknowledge and agree that it is our practice to delete all identifiable pupil data no longer than 6 months after either:
a) The pupil completes the highest national curriculum key stage for the school; or
b) Your subscription to Insights comes to an end.
We will delete or return all personal data to you after (a) or (b) occurring and we will delete existing personal data we have processed on your behalf unless the law requires its storage.
We will take appropriate measures to help you, as the controller, to respond to requests from individuals i.e. pupils or parents/guardians to exercise their rights in relation to their personal data you provide to us, including its erasure.
You can also delete pupil data on Insights directly in which case the pupil data shall be permanently deleted from Insights and all associated security back ups within a maximum of 30 days.
Non-identifiable data, which is no longer linked to an individual, such as test scores, may be stored in Insights indefinitely without further notice to you.
You may at any time delete or export, or ask us to delete or export, any data that you no longer require us to process.
We will submit to audits and inspections requested by you on fourteen (14) days' notice during normal working hours as detailed in the data processing agreement between us and you. We will also provide you with whatever information you require to ensure that we as processor and you as controller are meeting their Article 28 (GDPR) obligations.
8. Glossary
LAWFUL BASIS
1. 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 personal data you provide to us for our legitimate interests. We do not use personal data you provide to us 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.
2. 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.
3. Comply with a legal or regulatory obligation means processing personal data you provide to us where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
4. Public task means the processing is necessary to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
5. Protecting the vital interests of the data subject or another natural person means that processing is necessary to protect someone’s life.
6. Consent means we have your express consent to process personal data you provide to us for the stated purposes.
THIRD PARTIES
Internal Third Parties
Other companies in the Fig Leaf Group acting as joint controllers, processors or sub-processors and who are based in Canada and in the UK and provide IT and system administration services.
External Third Parties
- Service providers acting as sub-processors based in the UK, New Zealand, US, Canada who provide IT and system administration services, including AWS, Google, Stripe, Xero, Unleashed, Freshdesk, Freshchat, Slack, Atlassian.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and Canada who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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