Numerise Companion Privacy Notice
Table of contents
- Information about Numerise and Numerise Companion
- Information about this Privacy Notice
- How does Numerise Companion get personal information?
- What personal information is collected?
- How is personal information used?
- When is personal information shared?
- Where is personal information stored?
- How long is personal information stored for and what happens to it?
- Security of personal information
- Your rights
- How to contact us
Information about Numerise and Numerise Companion
Numerise is a new way to build confidence in maths at home. Personalised for each learner, a few short sessions will help you stay up to speed with maths whether you are in year 7 or have just started your GCSE course. Numerise Companion connects a supporting adult and their supported learner with a maths tutor from Numerise via a simple group messaging app which allows us to provide you with additional maths support.
Numerise and Numerise Companion are owned and operated by Sparx Limited (company number 07907042) (Sparx, we, us or our). Sparx is the entity responsible for the use of personal information for the purposes of providing Numerise and Numerise Companion. Sparx is registered with the UK’s Information Commissioner’s Office (ICO) under registration number ZA006725.
If you have questions, comments or requests regarding the personal information that we use to deliver Numerise or Numerise Companion to you, or this Privacy Notice more generally, please contact Sparx’s Data Protection Officer by email at [email protected]. Alternatively you can write to the Data Protection Officer, Sparx Limited, Oxygen House, Grenadier Road, Exeter, Devon EX1 3LH.
Information about this Privacy Notice
This Privacy Notice is for the supporting adult and supported learner users of Numerise Companion (Users or you). The Privacy Notice which relates to Numerise is available here.
This Privacy Notice was published in October 2020 and applies to the use of personal information by Sparx in connection with Numerise Companion from October 2020. It aligns with the requirements of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). We may make changes to this Privacy Notice from time to time, so you should review this Privacy Notice periodically in case changes have been made. We will get in touch with you to let you know about any particularly important changes that we need to make. This may include notifying you via Numerise Companion.
In this Privacy Notice:
- personal information is any information about a User which can identify that User. It does not include any information where the User’s identifying information has been permanently removed so that we can’t identify the User (this is known as anonymised information); and
- using (or any derivations of it such as use or uses) in the context of personal information includes (as applicable and without limitation) collecting, recording, organising, combining, storing, pseudonymising (temporary removal of personal information), anonymising (permanent removal of personal information) and deleting.
How does Numerise Companion get personal information?
Users provide personal information when they use Numerise and Numerise Companion. This is called User Data. Data is also generated through Users’ use of Numerise Companion. This is called App Data.
What personal information is collected?
User Data provided by Users:
- when they created their Numerise account, including the first names of the supporting adult and supported learner and the supporting adult’s email address (we refer to this as Customer Data in the Numerise Privacy Notice, which is available here);
- when registering their interest in Numerise Companion via the Numerise website, including the type of mobile device used by the supporting adult and supported learner and their operating systems (i.e. Apple or Android); and
- when they use Numerise Companion, including messages, comments, support requests or questions that Users provide to us when they interact with Numerise Companion.
App Data generated in connection with Numerise Companion includes:
- unique identifiers, such as access codes and tokens which we produce and send to Users to enable them to use Numerise Companion;
- which messages Users have read within Numerise Companion;
- when Numerise Companion is used and the time spent using it;
- the device used to access Numerise Companion; and
- other app analytics, including links clicked and journeys through Numerise Companion.
Numerise Companion does not contain any location-enabled services and therefore we do not use GPS technology to determine your current location.
How is personal information used?
We use personal information in order to provide Numerise Companion to Users. Our lawful bases for using personal information are:
|Lawful basis||Use of personal information|
|Consent||You will be asked to provide your consent to our use of your personal information when you access Numerise Companion for the first time. You can withdraw your consent at any time by ceasing to use Numerise Companion and deleting it from your device. Withdrawing your consent does not affect the lawfulness of our use of your personal information before you withdraw your consent.|
|Legitimate interests||We may use your personal information to evaluate and improve Numerise Companion, Numerise and other Sparx Family products and services.|
|Legal obligation||There may be times when we are required by law to share your personal information.Sparx connects and uses User Data and Usage Data in order to:|
Sparx connects and uses User Data and App Data in order to:
- Provide Numerise Companion to Users, including interacting with Users and sending push notifications;
- Set up and administer User accounts;
- Provide technical support and deal with help requests and enquiries;
- Connect User Data and App Data with Customer Data and Usage Data collected by Numerise in order to provide bespoke maths tuition via Numerise Companion;
- Evaluate and improve Numerise Companion, Numerise and other Sparx Family products and services; and
- De-identify User Data and App Data through aggregation and anonymisation. This creates anonymised information (that cannot be linked back to the relevant User) which we may use for research and product development and/or marketing and promotion purposes. Please see ‘How long is personal information stored for and what happens to it?’ for further information relating to anonymised information.
Personal information will never be sold or used to market or sell non-Sparx Family products or services (please see https://sparx.co.uk/ for more information about the Sparx Family). Numerise Companion does not contain any in-app advertising or marketing.
When is personal information shared?
Personal information may be shared with third parties in order to help us to deliver Numerise Companion to Users (Support Companies). A list of our Support Companies, including their location, is set out below. This list will be updated regularly.
|Support Company||Reason for personal information sharing||Location|
|Hotjar||User registration||Principally Europe|
|Expo||App creation platform||USA|
|Apple||Digital distribution platform||Europe|
There may also be times when we are required by law to share your personal information, such as with law enforcement agencies, in order to prevent or detect crime. We will only ever do this where we are subject to a legal obligation.
Where is personal information stored?
Messages sent and received within Numerise Companion are not cached on your device. Each time you open Numerise Companion, all previous messages will be re-downloaded from our servers.
Personal information used in connection with Numerise Companion will be stored in the European Economic Area (EEA) wherever possible. We will only transfer your personal information outside the EEA where it is necessary for us to do so (for example, because there is no reasonable alternative Support Company based in the EEA or with data centres available in the EEA). Countries outside of the EEA typically don’t have data protection standards that meet the data protection standards of EEA countries, so whenever we transfer your personal information out of the EEA, we ensure protection is afforded to it by ensuring that at least one of the following safeguards is implemented which ensure that your personal information is suitably protected:
- we will only transfer your personal information to Support Companies in countries that have been deemed to provide an adequate level of protection by the European Commission;
- where we use certain Support Companies, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe; or
- where we use Support Companies based in the US, we may transfer personal information to them where they have implemented standard contractual clauses, which requires them to provide similar protection to personal information shared between Europe and the US.
Further, in the case of all Support Companies used by Numerise Companion, we undertake detailed due diligence to ensure that each Support Company has good privacy safeguards and security features in place to prevent unauthorised access to or use of personal information we send it.
How long is personal information stored for and what happens to it?
Personal information is used for the duration of your use of Numerise Companion. Your personal information will be kept for a period of time once you cease to be active on Numerise Companion. This is so that you can restart your use of Numerise Companion if you choose to do so and to allow us to complete administrative and other tasks. When your personal information is no longer required for these purposes, it will be stripped of identifying information (meaning it will no longer be possible to identify you) and retained as anonymised information. Because re-identification is not possible, the anonymised information is not personal information and may be retained by us indefinitely and used for research and product development and/or marketing and promotion purposes.
Security of personal information
We are committed to protecting and respecting the privacy of our Users. We have appointed a Data Protection Officer who advises on, and oversees matters relating to, privacy and data security. Appropriate security measures have been put in place to prevent personal information from being lost, used or accessed in an unauthorised way and to keep your personal information safe and secure. We conduct regular penetration testing to make sure that our system has robust security and have obtained a Cyber Essentials certification. We limit access to personal information to only those employees, Support Companies and other third parties who have a legitimate need for access.
Numerise Companion does not place cookies on User devices. However, when Users access Numerise Companion for the first time, a token is placed on their device which allows them to access Numerise Companion without the need to re-enter an access code each time and see their conversation history.
Your rights in relation to your personal information are:
|Data Subject Right||How Numerise Companion caters to the Right|
|The right to be informed of processing||Providing a link to this Privacy Notice via Numerise Companion.|
|The right to access personal information by making a subject access request (i.e. a right to a copy of the information about you that we use)||Your full conversation history is visible in Numerise Companion. Other personal information records may be requested by contacting our Data Protection Officer ([email protected]).|
|The right to rectification where personal information is inaccurate or incomplete (i.e. the right to correct personal information about you that isn’t accurate)||Personal information correction requests can be made by contacting our Data Protection Officer ([email protected]).|
|The right to erasure, sometimes called ‘the right to be forgotten’ (i.e. the right to delete the data that we use about you)||Requests for erasure of User Data can be made by contacting our Data Protection Officer ([email protected]).
App Data will be retained as anonymised information so it is no longer considered to be personal information.
|The right to restrict processing (i.e. the right to limit our use of your personal data)||Data use can be restricted by ceasing to use Numerise Companion and deleting it from your device.|
|The right to data portability (i.e. the right to transfer your personal data to someone else)||Not applicable as we do not integrate with any other providers of independent education products.|
|The right to object to processing (i.e. the right to stop us using your personal information)||Data use can be stopped by ceasing to use Numerise Companion and deleting it from your device. Withdrawing your consent does not affect the lawfulness of our use of your personal information before you withdraw your consent.|
|The right not to be subject to a decision based solely on automatic processing (i.e. the right to stop us using algorithms or other computer programs to make decisions about you)||Not applicable as our we do not conduct automatic processing in connection with Numerise Companion.|
You also have the right to make a complaint at any time to the ICO regarding the use of personal information by Sparx in connection with Numerise Companion. However, we would appreciate being given the chance to help you with your concerns before you approach the ICO, so please contact us if you have a complaint. For more information about the ICO please visit https://ico.org.uk/for-the-public/.
How to contact us
If you have questions, comments or requests regarding the personal information that we use, or regarding this Privacy Notice more generally, please contact our Data Protection Officer by email to [email protected]. Alternatively you can write to the Data Protection Officer, Sparx Limited, Oxygen House, Grenadier Road, Exeter, Devon EX1 3LH.