Your privacy is important to us

This privacy policy sets out the ways in which Cyberleader Ltd, (on behalf of its service www.careerpaths4students.com)  (we, us, our) collects, uses and shares your personal data (your information) in connection with our IT and educational business. It also explains what rights you have to access or change your personal data.

Cyberleader Ltd is committed to protecting you, and your family’s personal information. This policy, together with any other documents referred to within, sets out the basis on which we will process any personal data that we collect from you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Cyberleader Ltd is the Data Controller and is committed to protecting the rights of individuals in line with the Data Protection Act 2018 (DPA) and the General Data Protection Regulation (GDPR). The data controller decides how your information is used and protected. We take your privacy and our responsibility to protect your information seriously and will take care in use and handling of your personal data.


WHO WE ARE

Cyberleader Ltd is a company registered in England under company number, 11326898 with our registered address as set out below.

Address:     Flat 2, Kings Court, Priory Place, Dartford, England, DA1 2BP, UK
Email:          contact@cyberleader.co.uk

CHILDREN

Cyberleader Ltd websites are not directed at children. They are intended for adults including parents, carers and teachers. Children should only use the site with the involvement of parents, guardians or teachers. Subscriptions must be from adults. Where any Cyberleader Ltd digital platforms process information about children under 13, we will ensure that parental consent is firstly provided by the parent for the processing of the personal information.

WHAT INFORMATION WE COLLECT ABOUT YOU

Information you provide

During your interaction with us, whether via our websites, by email, through completion of surveys, use of our apps or by any other means, you may provide information to us which might include [such as] your name(of adult, parent/carer) , address, gender, email address, phone number, birthday, twitter handle, the type of device you use to connect to the internet, and the subjects you are interested in, in order to provide you with information or reply to your queries. If you are creating an account you will provide a password and if you are ordering products or services from us you will provide your payment details. Your information includes anything which identifies you.

We may collect your personal information in a number of ways, including:

  • directly from you (unless it is unreasonable or impracticable to do so);
  • from your school / educational institution customers (e.g. teachers or school administrators that purchase access to our Site for their students and teachers); or
  • from third parties such as our distributors (resellers and sales agents).

In order to register CyberleaderLtd/careerpaths4students resources, students registering individually and not part of a school, must give their consent at the time of registration to provide us with their personal information such as their name, age and email address (or if they are under 13 years of age, or legally a minor in their relevant location, a parent or guardian must consent on their behalf).

Alternatively, parents registering on behalf of their child(ren), must give their consent at the time of registration to provide us with information about them and their child(ren).

Teachers or administrators registering for their class or school must give their consent at the time of registration to provide us with their own name, class name, school name and their email address, as well as the names of their students.

We also ask for Registrants’ consent to use any personal information collected in accordance with this Privacy Policy at the time of login to our Site. If a Registrant does not wish to provide us with their consent, they cannot agree to the Site Terms and Conditions and must not use the Site.

We will not collect any Special Category (“Sensitive”) information such as those that may include details about a person’s racial or ethnic origin, political opinions, religious, philosophical or similar beliefs, trade union membership, genetics, biometrics, health, sexual life, sexual orientation or about criminal offences or proceedings.


Pupil 

If you are a pupil, information about you as a pupil , which is provided by the parent, or by the pupil after obtaining parent’s consent, may include your contact details, your email id, your age and date of birth.

We collect your information when you:

  • create an account in our website;
  • subscribe to or accept access to one of our digital platforms
  • subscribe to our newsletters
  • interact or correspond with us by  letter, phone, SMS, email or via our website
  • complete one of our surveys
  • use our mobile devices or website applications (apps)
  • sign up to attend events

Protection of Personal Data

You are responsible for ensuring that personal data is transferred to us securely.  We will take all reasonable precautions to ensure that all the personal data that is submitted to us for the purposes above remains secure and have procedures to protect the storage and disclosure of personal data. You must ensure passwords are not shared and are kept securely.

Cookies and how you use our website and apps.
We also collect certain information about how you use our website and apps and the device that you use to access them. This includes your IP address, geographical location, device information (such as your hardware model, mobile network  information , unique  device identifiers) browser type, referral source, length of visit to the website, number of page reviews, the search queries you make on the website and similar information. This information is collected by Google Analytics on our behalf and by some of our apps using cookies. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

Our website may include links to third party websites, plug-ins and applications. By clicking on those links or enabling these connections you may allow third parties to collect or share data about you. We do not control these websites and are not responsible for their privacy notices. Please ensure that you read the privacy notices on any such external websites.

HOW WE USE INFORMATION ABOUT YOU

We use your information lawfully. We do not sell your information to third parties. The details of how we use your information and the legal bases for our use are set out below:
We may use such personal data collected to:

  • process your request, for example, to purchase products or access services and to administer your account
  • communicate with you and provide information about our products and services 
  • send you marketing communications about products, services, activities, promotions or other matters that we feel may be of interest or use to you
  • contact you about products you have bought or services you have subscribed to
  • communicate with you and your school regarding digital platform offerings
  • analyse your use of our websites, our apps and response to our communications and improve the services we offer, including personalising our communications with you.

Pupil Information

If you are a pupil your school may have provided information about you to us which will be processed on their behalf in order to:

  • support your learning
  • conduct assessments and record assessment results
  • assess the quality of our services

We will process your data for these purposes in accordance with instructions from your school and will report on the outcome of our services to your school.  We will not give information to any third parties (other than contractors providing services to us with whom we have an agreement) without the consent of your school.  Where possible we will anonymise personal data.

When we have your consent to contact you, we may use your information to:

  • to keep in contact with you and provide you with marketing communications about our news, events and services
  • tell you about new website features or services;
  • send you newsletters;

In the following circumstances we will use your information to carry out our contract with you:

  • to process your requests to purchase our products/services from our website;
  • to provide customer service and support;

Sometimes we will use your information on the basis of our ‘legitimate business interests’ (legitimate interests). This means our legitimate interests in conducting and managing our business and our relationship with you.

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you, particularly where we process children’s personal data.  Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing, you have rights and choices which include the right to object .


We may use your information for the purposes listed below on the basis of our legitimate interests:

  • to contact you about products/services you bought from us;
  • to respond to your queries and correspondence;
  • to collect and store accurate data of our customers 
  • to administer your account with us;
  • to deal with enquiries or complaints as necessary to provide customer support in providing the correct products and services to our website users;
  • to carry out aggregated and anonymised research about general engagement with our website in providing the right kinds of products and services to our website users; 
  • to measure or understand the effectiveness of advertising;
  • to deliver relevant advertising and make relevant recommendations and suggestions to you about our products and services;
  • to analyse your use of our websites and apps and your responses to our communications;
  • to personalise, enhance, modify or otherwise improve the services and/or communications that we provide to you; 
  • to create our educational analysis tools
  • to mark assessment tests
  • to prepare aggregated benchmarks for the purpose of building educational tools and performance indicators from the results of anonymised data
  • to detect and prevent fraud and unauthorised access or illegal activity;
  • to improve security and optimisation of our network sites and services including trouble shooting, testing and software development and support;
  • to operate a safe and lawful business or where we have a legal obligation; 
  • to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees; 

We do not use data to engage in targeted advertising to children and we do not create or build personal profiles of students other than for the purpose of supporting authorised educational assessments or as otherwise specifically authorised by a parent/student or school/educational institution customer.


WHO CAN SEE YOUR INFORMATION

Your information may be processed by our staff or by the staff of third parties we work with to deliver our business. Processing can mean any activity that involves the use of information about someone that can identify them. All uses, for example, obtaining, recording, storing, disclosing, organising, retrieving, deleting and destroying are types of data processing. We take measures to ensure that third parties processing your information on our behalf are acting lawfully in accordance with our instructions and are subject to appropriate confidentiality requirements. We also have adequate technical and organisational safeguards in place in our company and with third party processors to protect your information. Third party processors of your information include: 

  • our website hosts and operators, IT support providers, database operators, site analytics providers and software developers; 
  • our marketing or publicity services providers;
  • specialist education research partners
  • our financial services and payment service provider;
  • our warehousing and delivery service providers;
  • our auditors, technical consultants and legal advisors;  
  • our fraud detection services;


WHEN WE SHARE YOUR INFORMATION

We share your information within the departments and services that make up Cyberleader Ltd. Where we share your information outside our company, you will be asked to consent to third party sharing of your information, and if you choose to give your permission, any interaction you have with a third party is governed by their privacy terms. The third party becomes a joint data controller of your information with us. This means that the third party can make decisions about how to use your information. Before we share your information, we require third parties to enter into a data sharing agreement which stipulates that they must maintain appropriate security to protect your information from unauthorised access, processing or use. 

We will share your information with the following third parties:

  • specialist education research partners  to help us create our educational analysis tools and products
  • any prospective seller or buyer of  businesses or assets, only in the event that we decide to acquire, transfer or sell any business or assets;
  • selected marketing partners; 
  • any other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law or where we have a legal obligation to do so


HOW WE LOOK AFTER YOUR INFORMATION 

We look for opportunities to minimise the amount of personal information we hold about you.  Where appropriate we anonymise and pseudonymise your information. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as: 

  • ensuring the physical security of our offices, warehouses or other sites;
  • ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
  • maintaining a data protection policy for, and delivering data protection training to our employees;
  • limiting access to your personal information to those in our company who need to use it in the course of their work and ensure it is kept behind a user password verification system.

 

YOUR RESPONSIBILITY

Having gained access to our website, you must never divulge your username or password to anyone. Please always remember to log out of your account and close your browser window when you have finished using them. This ensures that others cannot access your personal data, especially when using a shared, or public access computer terminal.

HOW LONG WE KEEP IT FOR

We retain the personal information that we collect from and about our Registrants for as long as it is needed to provide access to the Site or to manage that Registrant’s account. We take reasonable steps to delete the personal information we collect if your registration to use our Site lapses and you opt out of receiving further communications from us, or if you ask us to delete your information. We may however retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytic purposes and for product and service improvement.

We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example:

  • we archive our email and paper correspondence regularly and destroy unnecessary information;
  • we operate a best practice email retention policy requiring password protected folders and departmental shared drives to provide restricted access to information;
  • we conduct regular access reviews to keep access profiles and policies up to date;
  • we conduct periodic review and purge cycles of documents in accordance with our document retention policy;
  • we retain information relating to orders, refunds and customer queries for approximately 7 years;
  • we retain information relating to commercial contracts for approximately 7 years after expiration or termination whichever is the sooner;
  • we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently;
  • in the case of our digital platforms such as careerpaths4students, we will hold the data with your account for the period of your subscription (unless you ask us to delete it earlier) and thereafter until you instruct us to delete it.


INTERNATIONAL TRANSFERS OF YOUR INFORMATION

Our company is located in the UK.

Whenever we transfer your personal information out of the European Economic Area (EEA) we will take all steps necessary to ensure that it is adequately protected and processed in accordance with this Privacy Notice by using all appropriate cross-border transfer safeguards such as: 

  • entering into the European Commission’s Standard Contractual Clauses  with the provider  which give personal data the same protection it has in the EEA; and   


YOUR RIGHTS AND CHOICES

Your Right to Object

You have the right to object to our using your information for direct marketing and on the basis of our legitimate interests.

Your Right to Withdraw Consent

The right to withdraw your consent for our use of your information in reliance of your consent

Your Other Rights and Choices

You also have other choices and rights in respect of the information that we hold about you, including: 

  • the right to request access to the information that we hold about you to check that we are acting lawfully;
  • the right to receive a copy of any information we hold about you in a structured, commonly-used, machine readable format or in another format of your choice;
  • the right to request that we transfer your information to another service provider in a structured, commonly used, machine-readable format;
  • the right to ask us to correct information we hold about you if it is inaccurate or incomplete;
  • the right to ask us, in certain circumstances, to delete information we hold about you;
  • the right to ask us, in certain circumstances, to restrict processing of your information.

You may exercise your rights and choices by contacting us at contact@cyberleader.co.uk,

You can also prevent processing for marketing activities by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing. 

Your Right to Complain

Please contact us if you have any questions or are unhappy about the way your information is used. We hope we will be able to resolve any problems or issues you may.

You also have the right to lodge a complaint about us and our use of your information to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence; 


CHANGES TO THIS PRIVACY NOTICE
We may make changes to this Privacy Notice from time to time. We will post any changes to our site.
This Privacy Notice was updated on 03 September 2020.