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Learning Clip Ltd Data Protection - Privacy Notice

Learning Clip Ltd (hereafter also referred to as 'The Company' and or 'we', 'us', 'our') offers the content and features of learningclip.co.uk & learningclip.com (hereafter also referred to as 'the site') for the purpose of delivering said features and content to benefit teaching and learning in a classroom setting.

We place a high priority on safeguarding the privacy of users of the site. This Privacy Notice is intended to help you understand what personal information we collect and how it is used when you use the site. Our aim is to collect the minimum of personal information required to make your use of the site beneficial, enjoyable and easy whilst still fulfilling our obligations under our Terms of Service, subscriptions and where applicable Data Processing Agreement

The Company reserves the right to modify this Privacy Notice at any time without giving you prior notice. Following any such changes, we will notify you and offer you the opportunity to review and accept the changes.

You can help make your use of the site safe and secure by adopting some basic security practices:

1. The information we collect about you.

The information we collect varies with how you use the site and whether you're a visitor, a registered user or a subscriber. To be a registered user or subscriber you will have to create an account with learningclip.co.uk. Your account can either be as an individual or as a member of a school account, the data we collect, our data protection role and our responsibilities differ slightly in each case.

1.1 Data collection information for visitors

When you visit the site and you are not logged in then unless you give us your permission we do not collect any data about your visit to the site. If you do give us that consent we will record which pages on our site are visited, in what order and how long for. We will not record any data that could personally identify you, although we will record part of your IP address to help give us some idea about which part of the world you are browsing from.

If you do give your consent we will use the Google Analytics tools to capture and analyse this data. The analysis we perform is on aggregated data and is only able to show broad trends in the use of the site. This Data is routinely deleted after 14 months.

1.2 Data collection information for individuals who register to use the site with or without a subscription

For users who register with the site but do not choose to subscribe you are giving your consent for Learning Clip Ltd to collect and process your data as outlined below (1.2.1 1.2.2 & 1.2.3), your consent is our lawful basis for that processing. You may withdraw your consent at any time and we will cease all processing of your data, in that case you will no longer be able to log in to the site. For users of the site who subscribe our lawful basis for processing your data is to fulfil the contract between you and the Company as set out in our subscription terms and conditions. Your account is strictly for your use and must not be shared with anyone else.

1.2.1 I'd like to register and create an individual account on the site.

Initially to create your account on the site, we collect your title, first name, surname, email address, date & time of application and the password you create. Your password will be hashed within our system using the industry leading bcrypt hashing function.

We will then send an email to the address supplied inviting you to activate your account. If you accept the invitation we will record your acceptance and the date & time it was made.

If you haven't responded to the invitation within 2 months and activated your account we will delete it from our system. There is nothing preventing you from registering again at a later date with the same credentials .

We will also ask for your consent to receive communications from us. Withholding consent in no way prejudices your ability to access the core functionality of the site.

1.2.2 I'd Like to start an individual Subscription to the site

If you choose to subscribe to the site the financial transaction will be handled by PayPal Ltd.

At the time of purchase information we hold about you (email, name & items being purchased) will be shared with Paypal Ltd. Any subsequent transaction will occur on the Paypal website any Paypal account or credit card details supplied by you during that process will only be handled by Paypal Ltd. Records of your transaction will be available to us via the Learning Clip Ltd Paypal account, we will also receive an email notification from Paypal confirming the transaction. The email address you supply to Paypal in order for them to process the transaction is shared with us. At no time will Learning Clip Ltd have access to your financial details.

1.2.3 I've registered with or subscribed to the site and I'm currently logged in.

When you login to the site we record the date & time of your login. We will also record key aspects of your use of the site, without recording this data we cannot deliver our services. Therefore we will make a record in our database of:

Additionally some key features of the site make it necessary for us to temporarily record data on your computer/device in the form of cookies. See Section 2 for a full description of the way we use cookies.

1.3 Data collection information for users of the site who are part of a school account.

For users of the site who are members of a school account our lawful basis for processing your data is to fulfil the contract between your school and the Company as set out in our subscription terms and conditions Data collection on behalf of schools is further detailed in our data processing agreement with your school.

When a user's account is part of a school account there is limited scope for sharing data, collected as you use the site, with users who have 'administrative user' status for the same school account.

Your school's account will have one or more administrative users, these users are able to add new users to the school, allocate access to the site's resources to users and view information about users' most recent logins and account activation status.

1.3.1 My school has created a teacher account for me

Schools may invite teachers to become members of their school account. In this case the school will create an associated individual account for you using your name, email address and date of account creation. the Company will use that data to send you an email invitation to join the school's account. Your acceptance and completion of the account creation process is at your discretion and the Company will not act to begin collecting data about you until you have indicated your consent. On receipt of the invitation you can: 1. Ignore the invitation in which case if you haven't responded to the invitation within 2 months and activated your account we will delete it from our system 2. Report the invitation to the Company if you have any suspicions about its validity. 3. Accept the invitation and complete the creation of your account.

To complete the creation of your account you will be asked to create a password, this password is personal to you and will not be shared with your school. Your password will be hashed within our system using the industry leading bcrypt hashing function. We will also record the date & time of the completion of your account creation. We will also ask for your consent to receive communications from us. Withholding consent in no way prejudices your ability to access the core functionality of the site.

1.3.2 My school has created a teacher account for me and I'm currently logged in to that account.

When you login to the site we record the date & time of your login. We will also record key aspects of your use of the site, without recording this data we cannot deliver our services. Therefore we will make a record in our database of: • Date and identity of any of the site's content you place in your 'planning calendar' • Identity of any of the site's content you place in your 'favourites' • Identity of any of the site's content you view in full

Additionally some key features of the site make it necessary for us to temporarily record data on your computer/device in the form of cookies. See Section 2 for a full description of the way we use cookies.

2. What are cookies and how does Learning Clip Ltd use them?

Cookies are small files placed on your computer when you visit the site.

Session Cookies: are required to maintain access to your account after you have logged in to the site. If these cookies are not permitted you will not be able to log in correctly or access many features of the site. These cookies are removed when you log out or close your browser.

Functional Cookies: are used to temporarily store information about your use of the site. For instance, cookies will remember the criteria you have used to search for an item of content so when you return to a page your search criteria will be preserved. These cookies are removed when you log out or close your browser.

Analytic Cookies: are third-party cookies and collect anonymous information about how visitors use our website. If you give your consent we will use the Google Analytics tools to capture and analyse this data. The analysis we perform is on aggregated data and is only able to show broad trends in the use of the site.

3. Who is collecting my information and who might it be shared with?

When you are on the site and are asked for personal information, you are sharing that information with Learning Clip Ltd.

Learning Clip Ltd is a Private Limited Company (06403621) and is wholly owned by the Bowland Charitable Trust (Charity Commission Number: 292027)

For individuals who register with, or subscribe to the site, Learning Clip Ltd. has the roles of both Data Controller* and Data Processor* with regard to the data you share with us.

For users who are part of a school account then the School has the role of Data Controller and the Company. has the role of Data Processor and is processing your data in accordance with your school's instructions. In this case your data is shared by and controlled by your school.

* The ICO offers the following definitions of a Data Controller and Data Processor
' A controller determines the purposes and means of processing personal data.'
' A processor is responsible for processing personal data on behalf of a controller.'

For any user (school or individual) who gives consent for the Company to use their data for the purposes of marketing (and any other non transactional communications) then the Company. has the roles of both Data Controller and Data Processor in respect of that processing.

Where users give consent for marketing communications, the Company will additionally store your limited contact details (email address & name) with one or more third party providers for the purposes of fulfilling our marketing objectives. The Company is responsible for ensuring that any third party subcontractor or provider is fully compliant with Data Protection regulations. Learning Clip Ltd may additionally process data we hold about your use of the site in order to ensure that any marketing communications are timely and relevant to you; for instance, KS1 teachers may not be interested in new resources we have produced for KS2 pupils. You may opt to stop receiving marketing communications at any time by: using an 'unsubscribe' feature in any marketing email we send, updating your consent within the site or, simply contacting us and making that request directly.

The Company reserves the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process initiated by or served on the Company.

4. Under what circumstances would the Company contact me?

Under most circumstances the Company will never contact you unless you request a communication, or consent to receive marketing information.

Requested communications take the form of email generated automatically in the process of: registering for an account, requesting a password reset, requesting a quote, confirming a subscription, issuing invoices, receipts for payment and subscription expiry notifications. Records of these communications may stored in our database and other systems including paper based filing systems.

In extraordinary circumstances we may send you transactional/notification email, for instance, when a crucial change has been made that could affect your use of the site However for the most part we will attempt to deliver such notifications directly via the site.

5. What will happen if I contact Learning Clip Ltd?

If you contact Learning Clip Ltd we will normally keep a record of that and any subsequent communication between us. Depending on your reason for making contact and the method of contact we will be able to respond in different ways and will make a record in the most appropriate way. This may variously be: manually recorded, recorded in our email systems or recorded in the site database.

Where an enquiry is general in nature, for instance regarding some aspect of the functioning of the site or our services, we will attempt to satisfy the enquiry in a timely manner without recording or accessing any personal data. When we cannot immediately deal with an enquiry or you request that we contact you at a future time we will record whatever data is necessary (e.g. name, phone, email, address) to adequately respond to you.

Where an enquiry is specific to an individual user it will be handled in accordance with the principles set out in section 7: Your rights regarding personal information held about you by Learning Clip Ltd

Where an enquiry can be classified as technical support we will, as far as possible, attempt to respond in general terms. However this may not always be possible and it may on occasion be necessary to examine your personal data in order to resolve technical issues or offer specific guidance. In these cases we will seek to confirm your identity (normally by email) and consent for this before we act. Where applicable we may, in some circumstances, also seek the consent of your school.

6. How Long Does Learning Clip Ltd retain my data for?

As well as aiming to collect as little of your data as possible, Learning Clip Ltd also aims to keep your data for the shortest time possible, and to give you as much control as we can over this.

For individual users who are not subscribed we will retain your data for as long as we regard you as an active user, if you make no use of the site for a period of 12 months we will delete your account and any data associated with it. This would in no way prevent you from creating another account at a future date using, if you wish, the same personal details.

For individual users who subscribe we will retain your data for a minimum period coinciding with the period of your subscription. Following the end of a subscription we will retain your data for as long as we regard you as an active user, if you make no use of the site for a period of 12 months we will delete your account and any data associated with it. However for tax and accountancy reasons we will retain any data relating to financial transactions between us for a period of at least 6 years.

For users who are members of a School account, we will retain your data for a minimum period coinciding with the period of your subscription. Following the end of a subscription we will retain your data for as long as we regard you as an active user, if you make no use of the site for a period of 12 months we will delete your account and any data associated with it). Records of our contract and any transactions with your school will be retained for a minimum of 6 years to comply with legal and accounting requirements.

7. Your rights regarding personal data held about you by Learning Clip Ltd

Where you are a member of a school account your school is the data controller and you should approach your school about exercising your rights. If you approach us directly we will in many circumstances refer the query to your school.

The law provides you with certain rights to access, erase or rectify your personal data. Our intention is to make as much of your data as possible accessible and editable via your account however we recognise that this may not cover all data and may be impractical in some circumstances. You are therefore invited to make a direct request to exercise your rights.

Users also have a right to data portability, under this right we will provide a full transcript of data the company holds about you in a machine readable form (normally CSV or XML)

You can make requests directly to Learning Clip Ltd in writing (info@learningclip.co.uk)or verbally. Subject to satisfactory confirmation of your identity, we will act fulfil your request within 30 days.

Our Individual Rights Policy details the individual rights of data subjects under data protection and privacy legislation (including GDPR).

8. What security precautions are in place to protect my information?

Our privacy policies, systems, practices and technology are all structured to ensure compliance with the GDPR and give assurance to all our users that we are handling their data in the most responsible way achievable.

Your account information is protected by password, your password is stored in encrypted form and cannot be accessed by anyone. You should keep your password private at all times. You should also remember to log out of your account and close your browser window when you have finished using the site.

Learning Clip Ltd cannot and does not ensure or warrant the security of any information collected by use, transmitted over the Internet, or maintained in your user account. You agree that any data transmission you make or receive through the Site is at your own risk.

Our Data Security Policy details the practical, organisational and technical measures we take to protect data.

9. Your right to lodge a complaint

If after contacting us regarding data we hold about you, you are not satisfied with our response you have the right to lodge a complaint with the Information Commissioners Office (ico.org.uk)

Learning Clip Ltd's registration number with the ICO is ( number ) https://ico.org.uk/for-the-public/raising-concerns/