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jumpAgrade​​ Privacy ​​Policy

This privacy policy is for this website jumpAgrade (“Our Site”) and served by jumpAgrade CLG and governs the privacy of its users who choose to use it. This Privacy Policy tells you about your privacy rights and sets out how We, as a Data Controller, collect and process personal data. Furthermore, the way this website processes, stores and protects user​​ data ​​and ​​information​​ will ​​also​​ be​​ detailed​​ within​​ this ​​privacy ​​policy​​ (the ​​“Privacy​​ Policy”).

We at jumpAgrade CLG ("jumpAgrade," "We," "Us," "Our”) know that you care about how your personal data is used and shared, and We take your privacy seriously. By accessing or using the Service (including without limitation the mobile version of the jumpAgrade.com website (the “Mobile Site”) and the jumpAgrade mobile application(s) available via the Apple App Store and the Android Marketplace (collectively, the “Mobile Application”), you acknowledge that you accept the practices and policies outlined in this Privacy Policy. Remember that your use of jumpAgrade’s services is at all times subject to the Terms and Conditions, which incorporates this Privacy Policy. Any terms We use here without defining them have the definitions ​​given ​​to ​​them ​​in ​​the ​​Terms and Conditions.

This Privacy Notice should be read in conjunction with Our Cookie Policy.

What​​ information ​​does ​​jumpAgrade process?

"Personal data" means any information about an individual from which that person can be identified. Some of the information We process may constitute personal data.

Information ​​You​​ Provide ​​to ​​Us

We receive and store any information you knowingly enter when using Our Service, whether via computer, mobile phone, other wireless device, or that you provide to Us in any other way. This information may include, without limitation, personal data such as your name, username, email address, Student Username, Student User email address (if any), qualifications, phone number, school affiliation, billing and payment information, and any other information necessary for us to provide the Service. Through the functionality of the ​​Service,​​ you ​​may ​​also​​ be​​ permitted ​​to ​​input​​ an​​ email​​ address​​ or​​ phone ​​number. We also receive and store the content of messages sent and received via Our Site chat function.

Information ​​Collected ​​Automatically

We receive and store certain types of information whenever a Site User interacts with Our Site (“Usage Information”); this Usage Information is not personal data. For example, jumpAgrade automatically receives and records information on Our server logs from your browser including your IP address, jumpAgrade cookie information, and the page you requested.

We also record the details of activity of Site Users on Our Platform, and the number and frequency ​​of​​ visitors ​​to ​​Our ​​Site ​​and​​ its ​​components.

When you download Our Mobile Application, We automatically collect information on the type of device, name and version of the operating system, name and version of the application, whether the currently logged in user is a Teacher User or Student User, the numerical mobile device user ID, as well as actions performed by the currently logged in user in accessing the Mobile Application (“Mobile Usage Information,” which is considered part of Usage Information as​​ described ​​above).

We also use mobile analytics software to allow Us to better understand the functionality of Our Mobile Application and Mobile Site on your phone. This software may record information such as how often you use the Mobile Application, the events that occur within the Mobile Application, aggregated usage information, performance data, and where the application was downloaded​​ from; ​​this​​ information ​​is​​ considered​​ Mobile​​ Usage ​​Information.

The Service may also contain electronic images known as web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyse how Our ​​Service is ​​used.

Information ​​That ​​We May Collect From You

As​​ part​​ of ​​your​​ use ​​of​​ the Service, ​​We​​ may​​ collect ​​and​​ process ​​the ​​following ​​data ​​about​​ you:

  • Information about your use of Our Site, Our Mobile Site and/or Our Mobile Application including details of your visits such as pages viewed and the resources that you access. Such ​​information ​​includes​​ traffic​​ data, ​​location​​ data ​​and​​ other​​ communication​​ data.
  • Information provided voluntarily by you. For example, when you register for information or book a lesson, communicate through Our Site, Our Mobile Site and/or Our Mobile Application,​​ or​​ when ​​you ​​contact ​​us ​​by ​​email​​ or ​​telephone.
  • Information provided by Teacher Users. For example, weekly updates on Student Users’ progress in their classrooms.
  • Technical information used to identify you, such as login information, your IP address, the device, browser or operating system used to access Our Site, Our Mobile Site and/or Our Mobile​​ Application.
  • We also work with some third parties (including, for example, business partners, sub-contractors in technical delivery services, analytics providers, search information providers) and may receive information about you from​​ them.

Legal Bases and Purposes of Processing

We will only use your personal data for the purposes and legal bases set out below:

Purpose(s) for Processing Legal Basis
To carry out Our obligations arising from any contracts entered into between you and Us and to provide you with the information, products and/or services that you request from Us To perform Our contract with you
We will collect and store your Personal Data in order to manage Our relationship with you and provide the Service To support Our legitimate interests in providing and improving the Service provided such interests are not overridden by your interests and rights - you have the right to object at any time
To provide you with information, ​​send​​ Service updates, notify you of changes to the Service To support Our legitimate interests in providing and improving the Service provided such interests are not overridden by your interests and rights - you have the right to object at any time
To communicate with you effectively should you try to contact us via Our Site, Our Mobile Site and/or Our Mobile Application, including verification of any claims you may make To support Our legitimate interests in providing and improving the Service provided such interests are not overridden by your interests and rights - you have the right to object at any time
To ensure that content from Our Site, Our Mobile Site and/or Our Mobile Application is presented ​​in​​ the ​​most ​​effective ​​manner​​ for​​ you ​​and ​​for ​​your ​​computer​​ or​​ mobile​​ device To support Our legitimate interests in providing and improving the Service provided such interests are not overridden by your interests and rights - you have the right to object at any time
To administer Our Site, Our Mobile Site and/or Our Mobile Application and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey​​ purposes To support Our legitimate interests in providing and improving the Service provided such interests are not overridden by your interests and rights - you have the right to object at any time
To improve Our Site, Our Mobile Site and/or Our Mobile Application and to ensure that content is presented in the most effective manner for you and for your computer or mobile​​ device To support Our legitimate interests in providing and improving the Service provided such interests are not overridden by your interests and rights - you have the right to object at any time
To keep Our Site, Our Mobile Site and/or Our Mobile Application safe ​​and​​ secure To support Our legitimate interests in protecting against fraud and abuse

We may combine information We receive from other sources with information you give to Us and information We collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information received by Us).

We never give your details to third parties to use your data to enable them to provide you with information​​ regarding​​ unrelated​​ goods​​ or​​ services.

Cross-border Data Transfers

In operating Our Site, Our Mobile Site and/or Our Mobile Application it may become necessary to transfer data that We collect from you to locations outside the European Economic Area ("EEA") for processing and storing. By providing your personal data to Us, you agree to this transfer, storing and processing.

We will ensure appropriate safeguards are in place to protect the transfer of your personal data to these non-EEA countries, including ensuring that Our suppliers will take all reasonable steps to put in place a mechanism for international data transfers with its sub-processors in compliance with data protection laws. To obtain more information concerning these safeguards see Contact Us below.

How is ​​personal​​ information of​​ minors collected?

Where a Student User is under the age of 16, a ​​parent ​​or​​ legal​ ​guardian must ​​give ​​consent ​​for ​​them ​​to​ access ​tuition. We will make reasonable efforts to verify, where a child is below the age of 16, that consent is given / authorised by the holder of parental responsibility over the child.

Mobile​​ Usage ​​Information

This information is used to determine the device capabilities and usage trends which allows Us to better understand which devices We should support and what features are most frequently used.

Push​​ Notifications

If you use the Mobile Application, We will send push notifications to your mobile device in order to make you aware of certain activities that may occur within your account, such as when new material has been entered on Our Platform. You may opt-out of receiving such communications by ​​turning​​ them ​​off ​​at ​​the​​ device ​​level​​ or​​ emailing ​​Us ​​at [email protected].

Disclosure of your information

We will not disclose your personal data to any other party other than in accordance with this​​ Privacy​​ Policy ​​and ​​in​​ the ​​circumstances​​ detailed​​ below:

  • Where ​​We ​​are ​​legally ​​required ​​by ​​law​​ to​​ disclose ​​your​​ personal​​ information.
  • To​​ further​​ fraud ​​protection ​​and ​​reduce ​​the ​​risk ​​of ​​fraud.
  • Disclosure to a third party who provides a service to Us (including Our Internet Service Provider who records data on Our behalf and is bound by confidentiality provisions).
  • Disclosure of monthly reports to Sponsors that detail Student Users’ information such as their name, subject and engagement in the programme.

Third​​ Party​​ Links

On occasion We include links to third party websites on Our Site. Where We provide a link, it does not mean that We endorse or approve that third party websites policy towards visitor privacy.​​ You​​ should ​​review ​​their​​ privacy ​​policy ​​before​​ sending​​ them ​​any ​​personal​​ data.

Your Rights

You have the right to request access to, rectification, or erasure of your personal data, or restriction of processing, or to object to the processing of your personal data, as well as the right to data portability. In each case, these rights are subject to restrictions as laid down by law. The following is a summary of your rights:

The right of access enables you to receive a copy of your personal data

The right to rectification enables you to correct any inaccurate or incomplete personal data We hold about you

The right to erasure enables you to ask Us to delete your personal data in certain circumstances

The right to restrict processing enables you to ask Us to halt the processing of your personal data in certain circumstances

The right to object enables you to object to Us processing your personal data on the basis of Our legitimate interests (or those of a third party), including processing for direct marketing purposes or where We are performing a task in the public interest. Your objection will be upheld, and We will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for the exercise or defence of legal claims that may be brought by or against Us.

The right to data portability enables you to request Us to transmit personal data that you have provided to Us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible.

When We process personal data you provide to Us based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You have the right to lodge a complaint with the Supervisory Authority (as defined in data protection legislation), in particular in the Member State of your residence, place of work or place of an alleged infringement, if you consider that the processing of your personal data infringes the General Data Protection Regulation (“GDPR”).

If you wish to exercise any of these rights, please contact Us (see Contact Us below). We will respond to your request within one month. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse your request where there is a basis to do so in law, or if it is manifestly unfounded or excessive, or to the extent necessary for important objectives of public interest.

Data Retention and Security

We will store your personal data only for as long as necessary for the purposes of providing access to Our Site and related services to you; as required by law or regulatory guidance to which We are subject, and for the exercise or defence of legal claims that may be brought by or against Us.

We retain personal data from closed accounts in order to comply with legal obligations, enforce Our Terms and Conditions, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with ​​any ​​investigations ​​and​​ take​​ other​​ actions​​ as​​ permitted​​ by ​​law.

We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of Our database, nor can We guarantee that information you supply will not be intercepted while being transmitted to Us over the Internet. We have implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of Our organisation. We will continue to revise policies and implement additional security features as new technologies become available. Where We have given you a password which enables you to access certain parts of Our Site, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.

Although We will do Our best to protect your personal data, We cannot guarantee the security of your personal data transmitted to Our Site. Any transmission of personal data is at your own risk. Once We receive your personal data, We use appropriate security measures to seek to prevent unauthorised access or disclosure.

Changes to this Privacy Notice

We reserve the right to change this Privacy Notice from time to time at Our sole discretion. If We make any changes, We will post those changes here and update the “Last Updated” date at the bottom of this Privacy Notice. However, if We make material changes to this Privacy Notice, We will notify you by means of a prominent notice on Our Site prior to the change becoming effective. Please review this Privacy Notice periodically for updates.

Contact​​ Us

Please do not hesitate to contact Us regarding any matter relating to this Privacy Policy. All requests will be dealt with promptly and efficiently. Contact can be made via email at [email protected].

Last Updated: October 2022