What is the purpose of this document?
Fidjit Limited is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you and your child during and after your child’s use of our services. The use of the term ‘your child’ is designed to relate to any child who is under your care for who you are a parent or other care giver.
Fidjit Limited is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you and your child. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
We have produced a more concise version of this privacy notice which is designed to be read by children directly. This is to explain to them in more detail the use of their data as part of the service. This is in a much-reduced form to this notice and so the below acts as a more comprehensive guide.
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
The kind of information we hold about you
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).
There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.
We will collect, store, and use the following categories of personal information about you:
- Identity Data includes your first name, last name, username or similar identifier
- Contact Data includes billing address, delivery address, email address and telephone numbers.
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Financial Data includes bank account and payment card details.
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Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
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Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the service
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Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our products and services.
How is your personal information collected?
We collect personal information about parents and children directly from parents themselves. In certain instances we may be provided with information by the School but this should be provided to us with your knowledge and approval.
How we will use information about you
personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else's interests).
2. Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information, as well as providing a description of which categories of data are involved. Where a legitimate interest is involved, we state what the legitimate interest is.
- Identity Data – performance of a contract and legitimate interests [provision of the service]
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Contact Data performance of a contract and legitimate interests [provision of the service and collecting payments]
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Financial Data performance of a contract and legitimate interests [provision of the service and collecting payments
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Transaction Data performance of a contract and legitimate interests [provision of the service and collecting payments].
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Technical Data legitimate interests [provision of the service, monitoring usage]
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Profile Data performance of a contract
- Usage Data performance of a contract and legitimate interests [provision of the service, monitoring usage]
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
"Special categories" of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection.
Situations in which we will use your sensitive personal information
In general, we will not process particularly sensitive personal information about you or your child. The usage data collected will be used to track the development and use of the services but will not capture
Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.
We envisage that we will hold information about criminal convictions.
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. If appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.
Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you or your child based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you or your child using automated means, however we will notify you in writing if this position changes.
Data sharing
We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the UK if we have appropriate safeguards in place
If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
As part of the service your child’s usage data will be shared with their teachers and their school as to allow the school to track their growth and development within the service.
Which third-party service providers process my personal information?
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: financial providers, legal, accounting, professional advice and administration, IT services
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business.
We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, and disclosures to shareholders such as directors' remuneration reporting requirements.
Transferring information outside the UK
We do not envisage that we will transfer your personal data outside of the UK.
Data security
We have put in place measures to protect the security of your information.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
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Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
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Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
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Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
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Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the DPO Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data protection officer
We have appointed a data privacy manager (akin to a data protection officer so termed DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.