Information for you about how we look after personal information about yourself and your child or children.
Policy version: 1 (12 Mar 2023)
ypts.co.uk (our website) is provided by ACET-UK Ltd. We are the controller of personal data obtained via our website, meaning we are the organisation that is legally responsible for deciding how and for what purposes it is used. The term Data Controller is applied to a business which determines how personal information about yourself and your child or children is used. We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).
This privacy policy is divided into the following sections:
• What this policy applies to
• Personal data we collect about you
• How your personal data is collected
• How and why we use your personal data
• Marketing
• Who we share your personal data with
• How long your personal data will be kept
• Transferring your personal data out of the UK and EEA
• Cookies and other tracking technologies
• your rights
• Keeping your personal data secure
• How to complain
• Changes to this privacy policy
• How to contact us
What this policy applies to
This privacy policy relates to your use of our website only.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. Additionally, tutoring sessions are recorded for flexibility, safety and feedback purposes. Recordings may include videos showing the tutor’s computer screen and possibly the webcam of the tutor and/or the student in addition to audio (if they were active). These recordings are kept on a device running an up-to-date operating system and anti-virus software.
It is important that you keep YPTs up to date with any changes to the personal information provided. Subject to that you have the right to ask YPTs, as appropriate, to correct or complete any inaccurate or incomplete data held about you or your children.
We will collect and use the following personal data about you:
• Your name, address and contact information, including email address and telephone number and company details
• Information to check and verify your identity, eg date of birth
• Your gender, if you choose to give this to us
• Location data if you choose to give this to us
• Your billing information, transaction and payment card or other payment method information
• Bank account and payment details
• Details of any information, feedback or other matters you give us by phone, email, post or via social media
• Your account details, such as username and login details
• Your activities on, and use of, our website
• Your personal or professional interests
• Your professional online presence, eg LinkedIn profile
• Information about the services we provide to you
• Your contact history, purchase history and saved items
• Information about how you use our website and technology systems
• Your responses to surveys, competitions and promotions
• Any files you upload to the website
• Any other information which may be provided, and which is relevant to the education of your child or children.
If you do not provide personal data we ask for where it is indicated to be ‘required’ at the point of collection, it may prevent us from providing services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
• Directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to us or to our website and complete customer surveys, and
• Indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below.
• On occasion, YPTs may seek student data for statistical purposes and to assist us in refining and further developing (i) employee training and (ii) the materials and instruction techniques. Our website processes the data in a statistical manner and no personally identifiable data is retained any longer than 24 months after your child or children have ceased to attend the programme without a legitimate reason to do so.
We will ensure that appropriate technical and organisation measures are in place such that this data is shared with our company and that it is stored in a secure way. YPTs will not provide personal information for use by anyone else without your explicit consent or unless this is necessary for health and safety reasons, to comply with child protection policies and procedures, or otherwise in relation to child welfare and child protection, for example in cooperating with local and public authorities to comply with legal requirements and those of regulators, for example Ofsted, or unless it is otherwise provided for in this Privacy Notice.
How and why we use your personal data
YPTs requires the personal information set out in this privacy notice to ensure that the YPTs programme can be safely and effectively delivered to you or your children and continually developed and improved for your benefit or the benefit of your children. Under data protection law, we can only use your personal data if we have a proper reason, eg:
• Where you have given consent
• To comply with our legal and regulatory obligations
• For the performance of a contract with you or to take steps at your request before entering into a contract, or
• For our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
There are certain uses to which YPTs will not put personal information without your explicit consent. Where such consent is requested it will be sought separately. The table below explains what we use your personal data for and why.
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What we use your personal data for |
Our reasons |
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Create and manage your account with us |
For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price |
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Providing services to you |
To perform our contract with you or to take steps at your request before entering into a contract |
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Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us |
For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us |
|
To enforce legal rights or defend or undertake legal proceedings |
Depending on the circumstances: To comply with our legal and regulatory obligations In other cases, for our legitimate interests or those of a third party, ie to protect our business, interests and rights or those of others |
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Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website |
Depending on the circumstances: |
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Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended |
Depending on the circumstances: |
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Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices |
Depending on the circumstances: |
|
Protecting the security of systems and data |
To comply with our legal and regulatory obligations |
|
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures |
For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price |
|
Updating and enhancing customer records |
Depending on the circumstances: |
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Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant and |
To comply with our legal and regulatory obligations |
|
Marketing our services to existing and former customers |
For our legitimate interests or those of a third party, ie to promote our business to existing and former customers |
|
External audits and quality checks, eg for the audit of our accounts |
For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards |
|
We may need to share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency |
Depending on the circumstances: |
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where it needs to be shared with others.
Marketing
We may use your personal data to send you updates (by email, text message, telephone, WhatsApp or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
• Contacting us at admin@ypts.co.uk
• Updating your marketing preferences on our website
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
For more information on your rights to object at any time to your personal data being used for marketing purposes, see ‘your rights’ below.
Who we share your personal data with
We routinely share personal data with:
• Third parties we use to help deliver our services to you, eg payment service providers, warehouses and delivery companies.
• Other third parties we use to help us run our business, eg marketing agencies or website hosts and website analytics providers
• Our banks
We or the third parties mentioned above may occasionally also need to share personal data with:
• External auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
• Professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
• Other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
• Information may also be provided to local or public authorities where welfare and child protection issues arise.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
• If you make a request to access a copy of the personal information which we hold about you or your children, we are required, in most circumstances, to provide a copy of the personal information without charge and within 30 days. You may also seek confirmation of the personal information that YPTs holds about either you or your children.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data.
Transferring your personal data out of the UK and EEA
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy .
It is sometimes necessary for us to share your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR.
• in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. In addition, EEA data protection laws provide that transfers of personal data to the UK are lawful under an interim arrangement (UK interim bridge) while the European Commission seeks to determine if the UK can be granted a longer-term adequacy decision.
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
• a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Change to this privacy policy’ below.
Cookies and other tracking technologies
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies and similar technologies on our website. These files help us recognise you and your device and store some information about your preferences or past actions.
For further information on cookies and similar technologies, you can visit www.aboutcookies.org
Your rights
You generally have the following rights, which you can usually exercise free of charge:
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Access to a copy of your personal data |
The right to be provided with a copy of your personal data |
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Correction (also known as rectification) |
The right to require us to correct any mistakes in your personal data |
|
Erasure (also known as the right to be forgotten) |
The right to require us to delete your personal data—in certain situations |
|
Restriction of use |
The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data |
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Data portability |
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
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To object to use |
The right to object: |
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Not to be subject to decisions without human involvement |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply and circumstances in which they do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner’s website www.ico.org.uk on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
• provide enough information to identify yourself (eg your full name, address and email) and any additional identity information we may reasonably request from you, and
• let us know what right you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
• the Information Commissioner in the UK, and
• a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via including a prominent link to a description of those changes on our website for a reasonable period.
How to contact us
You can contact us by email at admin@ypts.co.uk or post at First Floor, 243a Roundhay Road, Leeds, UK, LS8 4HS, if you have any questions about this privacy policy or the information, we hold about you, to exercise a right under data protection law or to make a complaint.
