Introduction
Teach Teach Ltd. (collectively referred to as “TT “, “We “, “Us ” or “Our ” in this privacy policy (“Policy “) takes privacy very seriously and has created this Policy in order to demonstrate Our commitment to protecting any personal data that is provided to Us when using Our website: https://www2.myfamilycoach.com (the “Site “) or mobile application: ‘My Family Journal’ (the “App “).
Unless otherwise specified below, all defined terms in Our Cookie Policy, Terms of Use, User Platform Agreement, Trainer User Agreement and Trainer Platform Agreement shall apply to this Policy and all of which are incorporated (where applicable) by this reference. In this Policy, “You ” or “your ” refers to any User of the Site or App irrespective of whether You are a Trainer, parent, guardian or any other type of user. This Policy will inform You about:
1.1 Important information and who We are
It is important that You read this Policy together with any other privacy policy or fair processing policy We may provide on specific occasions when We are collecting or processing personal data about You so that You are fully aware of how and why We are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.
For your information, We are the controller of personal data on Our Site or App and We are responsible for your personal data. We have appointed a data protection officer (DPO ) who is responsible for overseeing questions in relation to this Policy.
If You have any questions about this Policy, including any requests to exercise your legal rights, or Our privacy practices, please email: David.Millard@empowering-learning.co.uk
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 (www.ico.org.uk ). We would, however, appreciate the chance to deal with your concerns before You approach the ICO so please contact Us in the first instance.
Changes to the privacy policy and your duty to inform Us of changes
It is important that the personal data We hold about You is accurate and current. Please keep Us informed if your personal data changes during your relationship with Us.
2. The data We collect 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).
TT processes personal data as a necessary part of entering into and performing our agreement with You, which is governed by our Terms of Use, App Licence, User Platform Agreement and Trainer Platform Agreement. As part of the process of using Our Site, App and/or the Free and PAYG Services, we require You to give Us certain personal information which We will need to provide the Free Services and/or PAYG Services You require or have requested. Without this information We may not be able to fulfil Our agreement with You. The type of personal information We will collect depends on the services that We provide to You and/or the medium of doing but includes (without limitation):
Trainer verification checks : when You apply as a Trainer We may undertake qualification checks and ask for verification to evidence that You qualified at the institute You purport to have attended and request a copy of a valid ID card or passport (e.g. a driving licence etc.). We also ask for information to demonstrate that You have the right to work in the UK.
Trainer Registration Details : this information may include a Trainers’ educational background and qualifications, area of expertise re subjects, one profile picture and video or hardcopy curriculum vitae (“CV “), applicable coaching Fees, Trainer availability and gender. We require this information so that We can process your application to become a Trainer;
Trainer availability : If You have an account as a Trainer on the Site or App We collect information on your on-site behaviour, capacity and interactions with other Users to help show You the most compatible requests and show Users the most compatible Trainers;
Account information : to enable Us to create an online account for You on Our Site or App. Depending on whether You register as a User or a Trainer, this information can include your name, email, optional telephone number and geo-location;
Order History : to enable You to see what courses You have booked, attended and paid for;
Our App : encrypted details about a child’s mood and symptom levels on any times/days of your choosing. We will store any details You upload about a child’s mood or symptom levels in a secure and safe way. The only personal data that you should input about a child is its year of birth and please note that it is your responsibility to anonymise any further details to the extent practicable. Please do not enter any other personal data on Our App relating to a child and note your anonymisation responsibilities below;
Community Platform & Email history : to enable communication with other Users of the website and with the TT team, We store details about your Community Platform entries and email history including user messages, requests You have made, and your interactions with the TT team;
Offer and Promotions : We record details of discounts, referral codes shared, redeemed and other promotions You use in order to apply the relevant rewards (e.g. TT Credit(s) to your TT Account);
Automatically tracked information includes: Cookie information, your IP address, information relating to the device You use to access Our Site, App and/or Free and PAYG Services, the actions You have taken, the pages You visit and the times and dates of actions You take on Our Site or App, your interactions with Us, the source of your visit and/or previous webpage before visiting Our Site or App, and your page response times;
Financial information: We will need You to provide Us with financial information to authorise or process payments and bill You or pay You for the PAYG Services. For Trainers, this information includes: your nominated bank account and your payment history, and for Users your payment history and payment card details (in respect of the PAYG Services). Furthermore, Users should note, that when You book Training Services via Our Site or when You receive payment for delivering Training Services via Our Site, We will pass your personal information to our nominated third parties who are necessary to process your transactions with Us, such as credit card companies and banks. The legal basis under Applicable Data Protection Laws by which we are permitted to process your financial information is that it is necessary for the performance of the agreement between Us. For clarity, this includes processing information with other companies for fraud protection and credit risk reduction. Save for what is set out above, We will not share financial information with any other third parties without your express prior consent; and
Other sources : We reserve the right, where permitted by Applicable Law, to collect and use information on You from third party providers.
The App will automatically encrypt any data uploaded to the platform however, please note that at all times You are responsible for ensuring that any information relating to a child is anonymised and You do not in anyway provide identifiable details about the identity of a child. For clarity, We do not request any information from You (or a child) that is, or could be, regarded as Special Category Personal Data (for example, You should not enter full names only nicknames or first names of your children.
Where We need to collect personal data by law, or under the terms of an agreement We have with You, and You fail to provide that data when requested, We may not be able to perform the agreement We have or are trying to enter into with You (for example, to provide You with access to Our Site, App and/or the Free and PAYG Services). In this case, We may have to cancel the agreement You have with Us but We will notify You if this is the case at the time.
4. How We use your personal data
We will only use your personal data when the law allows Us to. Most commonly, We will use your personal data in the following circumstances:
Where We need to perform the agreement, We are about to enter into or have entered into with You;
Where it is necessary for Our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
Where We need to comply with a legal obligation.
Please go to the Glossary to find out more about the types of lawful basis that We will rely on to process your personal data.
Generally, We do not rely on consent as a legal basis for processing your personal data although We will get your consent before sending third party direct marketing communications to You via email or text message. You have the right to withdraw consent to marketing at any time by contacting Us.
We have set out below, in a table format, a description of all the ways We plan to use your personal data, and which of the legal basis We rely on to do so. We have also identified what Our Legitimate Interests are where appropriate.
Note that We may process your personal data for more than one lawful ground depending on the specific purpose for which We are using your data. Please contact Us if You need details about the specific legal ground, We are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To install the App and otherwise register You as a User so that You can access Our Site or App and receive the PAYG and/or Free Services. The purpose of this processing is to: enable You to access Our Site or App and create a TT Account;facilitate matching between Users and Trainers including filtering Users requirements against Trainers experience to show the most compatible matches;to enable Trainers to create and promote their profile on Our Site or App;enable You to communicate with other Users and receive updates from TT about your TT Account;enable bookings between Users and Trainers;process payments; and provide TT Platform Services to Users and Trainers.
(a) Identity (b) Contact
Performance of a contract with You
To manage Our relationship with You which will include: (a) Notifying You about changes to Our Site, App, Terms of Use, Cookie Policy, User Platform Agreement, Trainer Platform Agreement or this Policy; (b) Asking You to leave User Feedback; and (c) Providing marketing materials (such as a newsletter) to You subject to opting-in to such marketing materials.
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
(a) Performance of a contract with You (b) Necessary to comply with a legal obligation (c) Necessary for Our Legitimate Interests (to keep Our records updated and to study how Users are using Our Free or PAYG Services)
To enable You to partake in surveys and/or promotional activities.
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
(a) Performance of a contract with You (b) Necessary for Our Legitimate Interests (to study how Users use Our Free or PAYG Services, to develop them and grow Our business)
To administer, develop and protect Our business and Our Site or App. The purpose of this processing is: (a) to fulfil our safeguarding and legal obligations; (b) to ensure quality of the Free or PAYG Service; (c) to better understand how Our Site or App is functioning for Users to inform Our Free or PAYG Service development; (d) to draw conclusions upon demographic information; and (e) to prevent fraud, spam and abusive or inappropriate behaviour.
(a) Identity (b) Contact (c) Technical
(a) 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) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to You and measure or understand the effectiveness of the advertising We serve to You.
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Necessary for Our Legitimate Interests (to study how Users use Our PAYG or Free Services, to develop them, to grow Our business and to inform Our marketing strategy)
To use data analytics to improve Our Site, App, the Free or PAYG Services, marketing, User relationships and experiences.
(a) Technical (b) Usage
Necessary for Our Legitimate Interests (to define types of Users for Our Free or PAYG Services, to keep Our Site and App updated and relevant, to develop Our business and to inform Our marketing strategy)
To make suggestions and recommendations to You about services that may be of interest to You.
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
Necessary for Our Legitimate Interests (to develop Our Free or PAYG Services and grow Our business)
To use (anonymised and encrypted) data analytics from App Data to allow Us to highlight any correlations in a child’s behaviour with external environmental factors.
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
Performance of a contract with You
To advance scientific research on childhood behaviour, we share data with carefully vetted researchers to advance behavioural studies. For that purpose we de-identify your personal data by removing or hashing personal identifiers so that neither the researchers nor any third parties can link it to you.
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
Performance of a contract with You
To process in-App purchases and deliver Services including managing payments and collecting money owed to us
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Location
Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
Please also note that we reserve the right to use your personal data for commercial purposes and by registering an account on Our Site or App, You acknowledge the same and permit the sharing of your personal data with third parties (including but not limited to External Third Parties).
We strive to provide You with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
We may use your identity, contact, technical, usage and profile data to form a view on what We think You may want or need, or what may be of interest to You. This is how We decide which services and offers may be relevant for You (We call this marketing).
You will receive marketing communications from Us if You have requested information from Us or purchased services from Us and You have not opted out of receiving that marketing.
We will get your express opt-in consent before We share your personal data with any third party for marketing purposes.
You can ask Us or third parties to stop sending You marketing messages at any time by following the opt-out links on any marketing message sent to You or by contacting Us any time at David.millard@empowering-learning.co.uk.
Where You opt out of receiving these marketing messages, this will not apply to personal data provided to Us as a result of a service purchase, service experience or other transactions.
You can set your browser to refuse all or some browser cookies, or to alert You when websites set or access cookies. If You disable or refuse cookies, please note that some parts of Our Site and App may become inaccessible or not function properly. For more information about the cookies We use, please see https://www2.myfamilycoach.com/cookie-policy-uk/
We will only use your personal data 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 You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Us.
If We need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. Disclosures of your personal data
Your personal information may also be viewed by:
for the sole purposes of enabling a Trainer to deliver their Training Services direct to a User and to provide a User with information about a Trainer’s Services. If You (as a User) make a course booking via Our Site, your personal information will be shared with your selected Trainer to enable the Trainer to deliver the Training Services or to follow up on any enquiry. Such details may include: first name and initial of surname, the contents of your message, and the subject and course You requested.
If You (as a Trainer) upload personal information on Our Site (e.g. by creating a profile), personal information in your profile may be accessible by any User who visits Our Site. The personal information shared may include your first name and the initial of your surname, your profile picture, university details, your CV, your qualifications, your training subjects and Trainer Fees, your training record and User Feedback. Publishing this personal data is essential for You (as a Trainer) to make use of Our Site and the Training Services.
If You (as a User) send a message to another User on Our Site (whether it be User to User or Trainer to User or vice versa), You acknowledge that TT may monitor the content of your message to fulfil our obligations under the Terms of Use and to protect our Legitimate Interests.
In addition to the above, We may share your personal data with the parties set out below for the purposes set out in the table above:
External Third Parties as set out in the Glossary.
Specific third parties such as:
Google Firebase;
Google Tag Manager; and
Facebook Pixel.
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 the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with Applicable Data Protection Laws. You should be aware that we may release your Personal Information (which will include your financial information, if necessary) when We believe it is necessary to comply with Applicable Laws, to assist law enforcement, to enforce the terms under which You transacted with TT, or to protect the rights, property or safety of TT, the Site, App and/or other Users. We do not allow Our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with Our instructions.
8. International transfers
Many of Our external third parties are based outside the European Economic Area (EEA ) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever We transfer your personal data out of the EEA, We take additional steps to ensure that your information is protected to at least an equivalent level, as required by applicable data protection laws.
Please contact Us if You want further information on the specific mechanism used by Us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Our 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 where We are legally required to do so.
10. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with You.
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, regulatory, tax, accounting or other requirements.
In some circumstances You can ask Us to delete your data: see your legal rights below for further information.
In some circumstances We will anonymise your personal data (so that it can no longer be associated with You) for research or statistical purposes, in which case We may use this information indefinitely without further notice to You.
11. Your legal rights
Under certain circumstances, You have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data;
Request correction of your personal data;
Request erasure of your personal data;
Object to processing of your personal data;
Request restriction of processing your personal data;
Request transfer of your personal data; and
Right to withdraw consent.
If You wish to exercise any of the rights set out above, please contact Us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, We could refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to your request to speed up Our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take Us longer than a month if your request is particularly complex or You have made a number of requests. In this case, We will notify You and keep You updated.
12. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of Our business in conducting and managing Our business to enable Us to give You the best service 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 your personal data for Our Legitimate Interests. We do not use your personal data 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.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that We are subject to.
THIRD PARTIES
External Third Parties
Service providers, suppliers, business partners and sub-contractors acting as processors based in the United Kingdom and the European Union who provide IT and system administration services.
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Website designers and marketing agents acting as processors based in the United Kingdom who provide their services which may require access to personal data.
Fraud prevention agencies, to prevent crime and trace those responsible.
Identity verification providers, to comply with legal or regulatory requirements.
Analytics and search engine providers that assist Us in the improvement and optimisation of Our Site or App.
IT and software providers who supply Us with Our IT infrastructure for the provision of Our PAYG and/or Free Services and administering Our business (including Our internal and external communications) and who also help Us manage Our User and contact databases, user relationships and marketing.
YOUR LEGAL RIGHTS
You have the right to:
Request accessto your personal data (commonly known as a “data subject access request”). This enables You to receive a copy of the personal data We hold about You and to check that We are lawfully processing it.
Request correctionof the personal data that We hold about You. This enables You to have any incomplete or inaccurate data We hold about You corrected, though We may need to verify the accuracy of the new data You provide to Us.
Request erasureof your personal data. This enables You to ask Us to delete or remove personal data 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 data where You have successfully exercised your right to object to processing (see below), where We may have processed your information unlawfully or where We are required to erase your personal data to comply with local law. Note, however, that We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of your request.
Object to processingof your personal data 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 as You feel it impacts on your fundamental rights and freedoms. You also have the right to object where We are processing your personal data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request restriction of processingof your personal data. This enables You to ask Us to suspend the processing of your personal data in the following scenarios:
If You want Us to establish the data’s accuracy.
Where Our use of the data is unlawful but You do not want Us to erase it.
Where You need Us to hold the data even if We no longer require it as You need it to establish, exercise or defend legal claims.
You have objected to Our use of your data but We need to verify whether We have overriding legitimate grounds to use it.
Request the transferof your personal data to You or to a third party. We will provide to You, or a third party You have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw consent at any timewhere We are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before You withdraw your consent. If You withdraw your consent, We may not be able to provide certain PAYG and/or Free Services to You. We will advise You if this is the case at the time You withdraw your consent.
