Privacy Policy




About our Privacy Notice

Thinkbox Education Ltd (“we” or “us”) is committed to protecting and respecting the privacy, safety and security of our registered (and prospective) users, including pupils, teachers, school administrators and parents (together “Users”).


This notice (together with our SATs Companion terms of use and Mirodo terms of use and any other documents referred to on it) explains in plain language who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. Please read this notice carefully to understand how any personal information is used. If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.


About Thinkbox Education Ltd

We currently have two products; SATs Companion and Mirodo. SATs Companion is an online assessment for Years 5 & 6 (comprising a website, worksheets and teacher resources). For more information about SATs Companion, please see our website at satscompanion.com (the “Site”) (the “SATsComp Site”).


Mirodo is an all-through assessment and intervention platform for Key Stage 2 & 3. For more information about Mirodo, please see our website mirodoeducation.com (the “Site”) (the “Mirodo Site”). Other products are in development and this Privacy Notice will be updated as necessary to reflect these as soon as they are available.


Each resource created by Thinkbox Education Ltd, together with the SATsComp Site and the Mirodo Site and any other website created for national and regional competitions and/or events (together the “Sites”), is owned and operated by Thinkbox Education Ltd. References to the Sites in this Privacy Notice therefore include all related Thinkbox Education Ltd owned websites.


What Personal Information does Thinkbox Education Ltd collect?


We collect the following categories of personal information:


School Users

In the case of school/educational institution subscriptions (including on a trial basis) (“School Users”) we may collect:

Home Users and Tutors


In the case of home or Parent subscriptions (“Home Users”), or tutor subscriptions, we may collect:

We may also collect details of other interactions that you and/or your Users have with us, together with any other information that you and/or your Users choose to provide us with, for example, through correspondence and interactions with our customer and technical support teams.


This information is required in order to fulfil our contractual obligations to you as it is necessary to correctly identify each registrant as a site User, manage their account and for other purposes identified below. It is impractical in most circumstances for Users to remain anonymous, and we may not be able to interact with you, provide access to the Sites, or answer your enquiry if we are not able to identify Users or collect your personal information.


Please note that by registering with any of the Sites and providing the requested personal information, whether on a trial, subscription or gifted basis, the School is deemed to have a lawful basis (pursuant to all applicable data protection laws) for supplying such data and information for and on behalf of all Users (to include both teachers and pupils). It is the school’s responsibility to ensure that they have a sufficient lawful basis for supplying all data to us. Where the lawful basis that the school is relying on is “consent”, it is the School’s responsibility to seek and confirm all necessary parental consent for all pupils. If a school does not have (or in the future no longer has) a sufficient lawful basis for supplying us with such personal data, any User to which this applies must not use the Sites, and the School must promptly inform us so any relevant data can be deleted from our Sites.


Please note that by registering with either of the Sites and providing the requested personal information, whether on a trial, subscription or gifted basis, the Home User’s or Tutors’ consent to provide us with information for and on behalf of all Users (to include parents, tutors and children) is deemed to be given. Users who do not wish to give this consent must not use the Sites. Where applicable, the Tutor is deemed to have a lawful basis (pursuant to all applicable data protection laws) for supplying such data and information for and on behalf of its tutees. Where the lawful basis that the Tutor is relying on is “consent”, it is the Tutor’s responsibility to seek and confirm all necessary parental consent for all tutees. If a Tutor does not have (or in the future no longer has) a sufficient lawful basis for supplying us with such personal data, any User to which this applies must not use the Sites, and the Tutor must promptly inform us so any relevant data can be deleted from our Sites.


For the benefit of impact reporting, you may also opt to provide further pupil details, to include; pupil’s date of birth, pupil’s gender, pupil’s Special Education Needs (SEN) status, pupil’s gifted and talented status, pupil’s ethnicity, pupil’s Free School Meal (FSM) status, pupil’s premium status, whether or not children are Looked After Children, and details of any languages spoken at the pupil’s home, however this information is all entirely optional and not required in order to use the Sites.


We do not however collect any unnecessary personal information from Users (for instance, information about religious beliefs, medical history etc).


Children and Consent


Please note that children (under the age of 18 years) cannot register to use the Sites themselves. A teacher, tutor, parent or guardian must register for them (either as part of a school subscription or parent subscription) and in doing so is consenting on behalf of the child (including on a trial basis) to provide us with their personal information (as identified above).


How does Thinkbox Education Ltd collect Personal Information?


The personal information collected about Users broadly falls into the following categories:


Information that you provide voluntarily


Information that we collect automatically

Some of this information may be collected using cookies and similar tracking technology.


 

Information that we obtain from third party sources

What does Thinkbox Education Ltd do with your Personal Information?


The personal information of Users, including any prospective Users, may be used for the following purposes:

Please note that our Sites do not provide pupils with any means to communicate directly with each other. There are no chat rooms connected with our products and services.


Legal basis for Processing Personal Information


Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. Ordinarily, we collect personal information from Users either because it is needed to enable us to fulfil and perform our contractual obligations with you as regards the provision of our products and services, and/or where we have the consent of the Users to do so. We may also collect personal data where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.


Who does Thinkbox Education Ltd share my personal information with?


We will keep personal information confidential and will not sell or knowingly divulge Users’ information to advertisers or any external third parties, however the following categories of recipients may access, process or be transferred your data:

Thinkbox Education Ltd Cookie Policy


A cookie is a little piece of information handed to a web browser from a web server that contains information that can be retrieved from the server later. When you visit the Sites the server may attach a cookie to your computer’s memory. We use cookies only to remember what language is set, which school last logged into the machine and the session cookie for knowing who is logged in. You should be able to configure your browser so that it disables cookies.


To help us better understand your needs, we also use analytical software. This software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the Sites, but will not store, save or collect personal information. You can read Google’s privacy policy regarding use of cookies for further information.


 

How does Thinkbox Education Ltd keep my personal information secure?


We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The data that we collect from you is stored on secure servers in the UK. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. All traffic and passwords are encrypted. As part of our privacy compliance processes we review these security procedures to consider appropriate new technology and methods.


We use a third-party payment processor, Stripe, to process credit card payments made to us. Transactions are encrypted using SSL technology. We do not retain any credit card numbers ourselves. Stripe’s use of your personal information is governed by their privacy policy.


You and your pupils/children are responsible for keeping your passwords confidential. We ask Users not to share their passwords with anyone.


Users should be aware that unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.


We also expect all our employees and contractors to comply with this Privacy Notice, and we will take appropriate actions to address breaches by employees and contractors of the obligations imposed by this Privacy Notice.


 

Data Transfers


Specifically, our Sites servers are in the UK through Digital Ocean. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.


None of the data processing or transfers takes place out of the UK.


Data Retention


We retain personal information we collect from Users where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).


When we have no ongoing legitimate business need to process User’s personal information, or where you ask us to delete Users’ information, we take reasonable steps to either delete or anonymise it. If this is not possible immediately (for example, because your personal information has been stored in backup archives), then we will securely store Users’ personal information and isolate it from any further processing until deletion is possible, but will endeavour to do so as soon as reasonably practicable. We may have to retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our terms and conditions.


Our policy is to automatically delete all pupil/child data from school accounts, tutor accounts and family accounts 12 weeks after expiry of a free trial or 3 years after an expiry of a subscription, where no renewal or pending subscription has been requested by that school, tutor or family. Please note that subscriptions are not automatically renewed at expiry. The main contact will be notified by us of our deletion policy prior to expiry of the subscription, and again prior to deletion of the pupil data. Deleted pupil/child data cannot be retrieved following deletion.


Users have the following data protection rights:

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.


 

Updates to this Privacy Notice


We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. Users will be deemed to have consented to any such changes by their continued use of the Sites following any changes being made.


You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.


 

How to Contact Us


If you have any questions or concerns about our use of your personal information, please contact us using the following details:

SATs Companion: data@satscompanion.com

Mirodo: data@mirodoeducation.com

The data controller of your personal information is Thinkbox Education Ltd which is registered with the Information Commissioner’s Office (“ICO”) with registration number ZA799146