By using Numerise, you acknowledge that your personal information (referred to in this Privacy Notice as Customer Data and Usage Data) will be used by Sparx and shared with other companies who support Sparx (referred to in this Privacy Notice as Support Companies) in providing Numerise to you.
We need to use personal information in order to provide personalised maths learning through Numerise. It is always used responsibly, transparently and securely. We will never sell personal information nor use it to market or sell non-Sparx Family products or services (please see https://sparx.co.uk/ for more information about the Sparx Family). Numerise does not contain any in-platform advertising or marketing. We are compliant with the Data Protection Act 2018 and GDPR.
Table of contents
- Information about Numerise
- Information about this Privacy Notice
- How does Numerise 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
Numerise is 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. 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 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 following categories of Numerise user groups (Users):
- Unsupported learners: Users who are at least 13 years old and have created their own Numerise account;
- Supported learners: Users who are under 18 years old whose Numerise account has been created for them by a supporting adult; and
- Supporting adults: Users who are at least 18 years old and have created a Numerise account for their supported learner(s).
This Privacy Notice was published in September 2020 and applies to the use of personal information by Sparx in connection with Numerise from September 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.
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 get personal information?
Users provide personal information when they create and use their Numerise account. This is called Customer Data. Data is also generated through Users’ use of Numerise. This is called Usage Data.
What personal information is collected?
Customer Data provided by Users in order to create a Numerise account or when a User uses or interacts with Numerise includes:
- If you are an unsupported learner: your name, your date of birth, your country of residence, your email address and your password.
- If you are a supported learner: your name, your date of birth, your country of residence, your username and your password.
- If you are a supporting adult: your name, your date of birth, your country of residence, your email address and your password.
- If you are an unsupported learner or supporting adult who takes out a paid subscription to use Numerise: payment card details (card number, expiry date, security code and the name on the card), location (the country or region from which you will primarily access Numerise) and your postcode.
- All Users:
- Comments and ratings that you provide to us when you respond to our requests for feedback on Numerise (but we will not identify you as the person who gave the feedback unless you have told us it is OK to do so);
- Support requests, comments or questions regarding Numerise that you submit to us;
- Your social media handle/username if you interact with us on social media (for example by messaging us directly); and
- Your contact details and other required information if you enter into one of our competitions.
Usage Data collected in connection with Numerise includes:
- Unique identifiers, such as Numerise user IDs;
- Answer history and results which are used to create maths attainment profiles;
- Use of features (e.g. what videos you have watched on Numerise);
- When Numerise is used and the time spent using it;
- The platform, browser type and device used to access Numerise; and
- Platform analytics, including pages viewed, links clicked, journeys through Numerise and platform session recordings – i.e. how you have interacted with Numerise when using it.
How is personal information used?
We use personal information in order to provide personalised maths learning through Numerise and undertake our research. Our lawful bases for using personal information are:
|Lawful basis||Use of personal information|
Sparx connects and uses Customer Data and Usage Data in order to:
- Provide personalised maths learning through Numerise;
- Set up and administer User accounts;
- Conduct invoicing, payment processing and undertake for other accounting purposes;
- Provide technical support and deal with help requests and enquiries;
- Build performance and progress profiles;
- Display performance and progress information via dashboards made available to Users;
- Populate algorithms which recommend personalised maths tasks to Users;
- Evaluate and improve Numerise and other Sparx Family products and services;
- Ensure Users are complying with our Numerise Terms and Conditions;
- De-identify such data through aggregation and anonymisation. This creates anonymised information (i.e. we can’t tell that the information is about you) which we use for research and 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);
- Evaluate the usage of Numerise for the purposes of competitions and other events; and
- Provide marketing information about Numerise and other Sparx Family products and services to you, and others recommended by you (for example ‘refer a friend’ promotions, but these will only be sent with your consent).
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 does not contain any in-platform advertising or marketing.
When is personal information shared?
Personal information may be shared with third parties in order to help us to deliver Numerise to Users (Support Companies). A list of our Support Companies, including the location of their servers, can be found here. This list will be updated regularly. We may also share personal information in the event that we enter into certain types of business partnership arrangements with other third parties (such as an acquisition agreement or joint venture). We may share anonymised and/or pseudonymised information with third parties for our research and development (in order to evaluate and improve Numerise) and/or marketing and promotion purposes (in order to investigate user trends and inform marketing activity) provided that such third party agrees not to attempt to identify Users from this information.
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 required to do so by law.
Where is personal information stored?
Personal information used in connection with Numerise 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.
- 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.
- In the case of all Support Companies used by Numerise, 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 subscription to Numerise. When your subscription ends, your personal information will be kept for a period of time in order to allow us to complete administrative and other tasks. In order to provide continuity of learning in case you decide to renew your subscription, your Customer Data and Usage Data will be retained for a period of one year (although if you do not renew within one year, we cannot guarantee this continuity). Personal information relating to payment will be retained for a period of six years for accounting and audit purposes. 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.
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.
In order to provide Numerise via a web browser, Sparx and our Support Companies place cookies and pixels on Users’ devices. Cookies are files that are placed on your device when you access Numerise and are used to collect standard internet log and user behaviour information about Users when they subscribe to and interact with Numerise. This information is used to arrange Numerise content, ensure security, track use of Numerise and to compile statistical reports. These cookies are not used to target Users with online advertising. Details of the cookies used by Numerise can be found below. For further information, you may wish to visit www.aboutcookies.org. Pixels are placed by third party websites for the purposes of marketing and can be managed through settings on the third party website.
|Cookie Source||More information|
|Sparx||Set for authentication purposes|
Your rights in relation to your personal information are:
The right to be informed of processing
How Numerise caters to the Right: Providing a link to this Privacy Notice on our website and as part of our subscription process.
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)
How Numerise caters to the Right: Your full question history is visible in Numerise. 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)
How Numerise caters to the Right: 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)
How Numerise caters to the Right: Requests for erasure of Customer Data can be made by contacting our Data Protection Officer ([email protected]). Usage 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)
How Numerise caters to the Right: Data use can be restricted by ending your Numerise subscription.
The right to data portability (i.e. the right to transfer your personal data to someone else)
How Numerise caters to the Right: 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)
How Numerise caters to the Right: Data use can be stopped by ending your Numerise subscription.
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)
How Numerise caters to the Right: Our maths tasks are suggested based on User profiles and answer history. This is an automated process which is fundamental to how Numerise works. However no significant adverse privacy effects arise from this use. Automatic processing can be stopped by ending your Numerise subscription.
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. 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.