Privacy Policy
1. SCOPE
1.1. Life on Time takes your privacy serious. We have prepared this privacy policy to explain to you how we treat your personal information. We encourage you to read this privacy policy carefully.
1.2. This privacy policy sets out how we look after your personal data if you are a:
1.2.1. Student using are software applications, including the YouHQ application (whether on a mobile application or by logging in on our website) (the Apps);
1.2.2. Member of staff at a school
1.2.3. Visitor to our website www.youhq.co.uk
1.2.4. Supplier or business contact of Life on Time.
1.3. If you have any questions about this policy, please contact us on info@lifeontime.co.uk.
1.4. It is important that you read this privacy policy together with any other policy or notice we may provide on occasions when we are collecting or processing your personal data, and that you understand it before you use our website, the Apps or contact us.
1.5. We keep our privacy policy under regular review. You can find the latest version on our website or by asking us for a copy.
1.6. 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),.
2.2. When we refer to ’’we’’, ’’our’’ or ’’Lifeontime’’ we are referring to Life on Time ltd the business.
3 WHAT DO WE DO
3.1 We provide our Apps to schools and other education establishments, to enable them to fulfil their personal, social, health and economic (PSHE) requirements while also giving them the opportunity to help improve student wellbeing and personal development.
3.2 In most cases, Lifeontime acts as a processor of personal data. We act on behalf of schools to collect information relating to the wellbeing of students, and provide the results in an easy-to-use format for teachers and staff. In these cases, we do not use the personal data we collect for our own purposes. In these cases, the school will be the controller and the person responsible for deciding how and when your personal data is collected and used, whilst we follow the instructions of the school. The school, will be a controller. The school should provide you with their privacy policy or privacy notice, setting out how the school uses your personal data.
3.3 Where we act as a processor, we have legally binding agreements in place with the school which restrict how we process your personal data, in accordance with data protection laws.
3.4 When you log in to our App, visit our website, or contact Lifeontime support, we will receive certain data directly from you, such as your name and login details. For this limited data only, we will be the person responsible for deciding how and when your data is used, and we will be the controller.
3.5 We are a controller when we collect information from suppliers and other third parties who interact with us.
4 THE PURPOSE OF THIS PRIVACY POLICY
The purpose of the remainder of this privacy notice is to set out how we use your personal data when we act as a controller.
This notice does not apply when we act as a processor. In those cases, our private agreement with the school will apply, and you should read the school’s privacy policy or privacy notice to understand what personal data is collected and how it is used and shared.
5 DATA PROTECTION OFFICER AND OUR RESPONSBILITIES
5.1 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:
Email: info@lifeontime.co.uk
By mail: Data Protection Trade Fair House | West Court | 2 Enterprise Road | Maidstone | Kent | ME15 6JD
5.2 The Managing Director is responsible for ensuring that this notice is made available to you before we collect or process your personal data.
5.3 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.
6 THIRD-PARTY LINKS
6.1 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.
6.2 When you leave our website, we encourage you to read the privacy policy of every website you visit.
7 THE PERSONAL DATA WE COLLECT OR PROCESS
7.1 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).
7.2 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.
• School Record Data: you class or year group.
• 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, your 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.
7.3 We do not collect “Special Categories” of personal data about you in our role as a controller.
8 IF YOU FAIL TO PROVIDE PERSONAL DATA
You can withhold your personal data from us, but we may not be able to provide our services to you if you do so.
9 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, contact us for support, or create an account with us or give us feedback.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, Google analytics, and other similar technologies. Please see our cookie policy for further details.
• 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.
10 HOW WE USE YOUR PERSONAL DATA
10.1 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.
10.2 When we are acting as a controller, we will use your personal data for the purposes set out in the table below.
10.3 The law sets our a number of different reasons for which we can collect and use your data. The legal grounds on which we collect and use your data are also set out in the table below.
10.4 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.
Marketing
10.5 If you are a business contact, such as a teacher or employee of an educational establishment, we may contact you in respect of our services and Apps. You can ask us 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 using the contact details given above.
10.6 We do not share your contact details with any third party for the purpose of that third party sending you marketing.
11 DISCLOSURES OF YOUR PERSONAL DATA
11.1 We may need to share your personal data when using your personal data as set out in the table above. We may share your personal data with the following third parties:
• Our professional advisers, including lawyers, auditors and insurers;
• Service providers who provide IT and system administration services, or who store data on our behalf. This includes our hosting provider (currently Amazon Web Services), and providers of marketing services, such as Mailchimp or Hubspot.
• 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 notice.
Please note: this is not applicable for users of our youHQ app. For users of the youHQ app, please refer to the service agreement signed by your school.
• HMRC and other regulators.
12 INTERNATIONAL TRANSFERS
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12.1 Some 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.
Please note: this is not applicable for users of our youHQ app. For users of the youHQ app, please refer to the service agreement signed by your school.
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 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. For more details of our specific retention period, please contact our data protection officer.
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 info@lifeontime.co.uk.
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 COMPLAINTS
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 described in section 11 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: info@lifeontime.co.uk
17 COOKIES
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