1.2. We collect and process personal data in line with our legal requirements under the GDPR and the Data Protection Act 2018.
1.3. Because this website may be used by children, we have taken great care to ensure that users are made aware of any times when their data may be recorded.
1.4. If you have any questions about this policy, please contact us on firstname.lastname@example.org.
1.7. 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. WHO WE ARE
2.1. We are Life on Time ltd (Company Number 12002332), a personal development and wellbeing company. The platform youHQ enables schools to fulfil their personal, social, health and economic (PSHE) requirements while also giving schools the opportunity to help improve student wellbeing and personal development.
2.2. When we refer to ’’we’’, ’’our’’ or ’’Lifeontime’’ we are referring to Life on Time ltd the business.
2.3. We are the controller responsible for your personal data.
3 DATA PROTECTION OFFICER AND OUR RESPONSBILITIES
3.1 Our Data Protection Officer and data protection representatives are responsible for answering any questions you may have and making sure that your data is protected. They can be contacted directly here:
By mail: Data Protection Officer, Life on Time Ltd Trade Fair House, 2 West Court, Enterprise Road, Maidstone, Kent, ME15 6JD England
3.2 The Managing Director is responsible for ensuring that this notice is made available to you before we collect or process your personal data.
3.3 All Employees and Staff of Life on Time who interact with your information are responsible for ensuring that this notice is drawn to your attention and that your consent to process your data is secured or the legal basis for processing your data has been communicated clearly.
4 THIRD-PARTY LINKS
4.1 This website may include links to third-party websites, plug-ins and applications (like the App Store and Mailchimp). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
4.3 There is more information at 11.4 to 11.8 regarding situations in which we may disclose your personal data to third parties.
5 THE PERSONAL DATA WE COLLECT OR PROCESS
5.1 Personal data, or personal information, means any information about you which can lead to you being identified. It does not include data where the identity has been removed (anonymous data).
5.2 The personal data we collect falls into different categories (sometimes more than one), and these categories are:
• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• 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 this website.
• 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 website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
5.4 We do not collect most categories Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We may have to collect information about your health due to the nature of the services we provide, but we will only do so with your explicit consent
5.5 The kind of data we collect will also depend on whether you are registered with us and we have provided differentiated information throughout this policy based on this fact.
Information on Registered youHQ Data Subjects
Information on Non-Registered youHQ Data Subjects
6 IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you or your school, and you fail to provide that data when requested, we may not be able to perform the contract we have. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
7 HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you register for our services, create an account with us or give us feedback.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
o Contact and Identity Data from your school based within the UK;
o Technical Data from analytics providers such as Google based outside the UK;
o Identity and Contact Data from data brokers or aggregators such as Mailchimp based outside the UK.
o Identity and Contact Data from publicly available sources such as the Electoral Register based inside the UK.
8 HOW WE USE YOUR PERSONAL DATA
8.1 We will only use your personal data when the law allows us to do so, such as where we need it in order to perform our agreement with you or your school, where we have a legitimate interest or where we need the information to comply with a legal obligation we may have.
8.2 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. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You have the right to withdraw consent to marketing at any time by contacting us.
8.3 Most often, we will use your data for the purposes set out at 8.4 and 8.6 below, depending on whether you are a Registered Data Subject or a Non-Registered Data Subject. You can find general information on our legal basis for using all data we obtain at 8.8 below.
8.4 Legal basis for processing Registered Data Subjects data
Students – Our legal basis for processing your data is the Contract which we have in place with your school. They may have a different legal basis for collecting your information originally which they will be able to provide. youHQ is committed to the age appropriate design of all our platforms.
Teachers / Staff Members – Our legal basis for processing your data is the Contract which we have in place with your school. They may have a different legal basis for collecting your information originally which they will be able to provide.
8.5 You may object to this processing by contacting your school directly. Your school will then work with us to block any future data coming through to our system. We will then remove / anonymise all your personal data on our system within 28 days of the request being made.
8.6 Legal basis for processing Non-Registered Data Subjects data
We are processing your personal data based on either Explicit Consent or for one of the legitimate reasons listed in clause 8.8 below.
8.7 Legal basis for use of all data
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 bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
8.8 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
9 OPTING OUT
9.1 You may opt out of this processing at any time by contacting us directly on:
9.2 Once you have opted out, we will no longer contact you with information about Life on Time products and all of your personal data will be deleted and/or anonymised within 28 days. Any legitimate interests for, in particular, non-registered data subjects is pursued by us, or third parties we use, are as follows:
10 CHANGE OF PURPOSE
10.1 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.
10.2 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.
10.3 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.
11 Disclosures of your Personal Data
11.1 We may have to disclose your personal data without your consent in some circumstances. For example:
• if we have to investigate a complaint, we will need to share personal information with the organisation concerned and with other relevant bodies;
• service providers such as IT and system administration services may have access to your data in performing their services;
• professional advisers such as lawyers, auditors and insurers may need access to your data to provide their services to us;
• M Revenue & Customs, regulators and other authorities based in the United Kingdom may require reporting of processing activities in certain circumstances.
11.2 If you want to get more information on what we consider when deciding whether information should be disclosed, please contact us.
11.3 You can also get further information on
• agreements we have with other organisations for sharing information
• circumstances where we can pass on personal data without consent, for example, to prevent and detect crime and to produce anonymised statistics
• our instructions to staff on how to collect, use and delete personal data; and
• how we check that the information we hold is accurate and up to date.
11.4 Except as set out in this policy, we will never pass on your personal data to new third parties without first obtaining your consent. All third parties will have in place agreements consistent with GDPR requirements.
11.5 We will never sell your data to third parties.
11.6 The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:
Safe Guards in place to protect your data
We store data needed to manage and run customer accounts. 123 Reg is committed to keeping its customers' data secure, and all data we hold on you is protected by appropriate measures, including encryption. The only 123 Reg employees who can access your data are those who need to access your data for business, such as our support teams helping you over the phone, and all such access is logged. In addition to this, all staff who need to access your data have been trained on respecting your rights, and wider data protection issues.
Purpose - Email hosting
Safe Guards in place to protect your data
Please see their data security information here https://mailchimp.com/about/security
Purpose - Marketing
Safe Guards in place to protect your data
Please see their data security information here https://aws.amazon.com/compliance/data-privacy-faq/
Purpose - Software hosting
11.7 In addition, your use of our website and services gives us your consent to use media channels such as Facebook, Twitter and Google to provide company updates and product information, but only with appropriate safeguards and procedures.
11.8 We require all third parties to respect the security of your personal data and to treat it in accordance ith the law. 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.
12 International transfers
12.1 Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
12.2 Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
12.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
13 Data security
13.1 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.
13.2 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.
14 Retention period
14.1 Life on Time will process and store personal data for students, teachers and school staff members for the duration of the school’s license with Life on Time. If you leave the school during an active license with your school we will delete/anonymise your personal data within 28 days of your account being deleted by your school.
14.2 For non-Life on Time users we will process and store personal data while we are in contact with you with relevant information on our services.
14.3 If you have opted out to your data being processed we will delete your data within 28 days of your opt out being received.
14.4 By law, we also have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
15 Your rights as a data subject
15.1 At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review – in the event that Life on Time refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.7 below.
• Right to withdraw consent – you have the right to withdraw your consent at any time where 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
15.2 All of the above requests will be forwarded on should there be a third party in the processing of your personal data.
15.3 If you wish to exercise any of the rights set out above or would just like to request more information, please contact us on email@example.com.
15.4 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.
15.5 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.
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.
16.1 In the event that you wish to make a complaint about how your personal data is being processed by Life on Time (or third parties as described in 11.4 to 11.8 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Life on Time’s Data Protection Officer.
16.2 The details for each of these contacts are:
Supervisory authority contact details
Name: Information Commissioner’s Office (ICO)
Contact details: https://ico.org.uk/concerns/
Data Protection Officer (DPO) contact details
Name: Life on Time DPO
Contact details: firstname.lastname@example.org