Privacy Policy

Privacy Notice – Think Academy International Education Limited

1.Introduction

Please read this privacy notice carefully as it sets out how and why Think Academy International Education Limited (“TAL”, “we”, “us”, “our”) uses your personal data when you access our website and/or services, as well as explaining certain legal rights that you have under data protection laws.

At TAL, we provide online tutoring and education services for school children in years 1 to 6 (typically aged between 5 and 11) (the “Services”). In accordance with the Data Protection Act 2018, TAL is registered on the public Register of Data Controllers as maintained by the UK’s data protection regulator, the Information Commissioner’s Office (ICO). This means that TAL is legally responsible for handling your and your child’s/dependant’s personal data.

If you have any questions or comments about this privacy notice, please see section 13 “How can you contact us?” for the relevant contact details.

We may change this privacy notice from time to time by updating this page. This privacy notice does not apply to any third-party websites to which you may be directed from our website and we encourage you to read the privacy statements on the other websites you visit. We do not accept any responsibility or liability for the privacy practices of such third parties and your use of them is at your own risk.

2.What personal data do we collect about you?

a.Registration data

In order to provide our Services, we will need to collect and use certain data about you such as:

  • your name;
  • email address;
  • telephone number; and
  • payment details (see Payment card information below).

b.Your child’s/dependant’s personal data

In addition, and due to the nature of the services, we will need to collect certain personal data about your child/dependant. Personal data about children is afforded extra protection under data protection laws and so we ask for the explicit consent of the child’s parent/guardian before collecting the following information:

  • your child’s/dependant’s name;
  • your child’s/dependant’s age/date of birth;
  • which school they attend and which academic year they are currently in;
  • the subjects/materials you are interested in for your child/dependant;
  • any questions, comments and/or feedback provided by child/dependant during an online class; and
  • video and audio recordings of your child/dependant obtained in the course of recording our lessons (see section 2(c) below for more information on online recording).

For more information about the legal bases which we rely on to use your or your child’s/dependant’s personal data, please see section 4 of this privacy notice.

Note that we will obtain this data either directly from you when you sign up to use our Services through this website, or from third parties such as your child’s/dependant’s school (which will only be the case where we are entering into a contract directly with the school, rather than with you). In such circumstances, your explicit consent will still be obtained before we collect your child’s/dependant’s personal data, i.e. the school/educational body cannot provide consent on your behalf.

c.Online recordings

In line with our safeguarding obligations, and to optimise your child’s/dependant’s learning experience by enabling them to play back lessons, we record our online classes. This means that if your child/dependant attends one of our online classes, their participation will be recorded both on audio and video. However, we will specifically ask you during the sign-up process whether you agree to your child’s/dependant’s participation being recorded in such a manner. If you are happy for the audio recording to take place but do not wish your child/dependant to appear on video, please ensure that the video camera on your device is turned off before the start of the online class. Due to the nature of the platform that we use, we are unable to exclude your child’s/dependant’s participation altogether from the recording, so if you do not consent to the audio recording either, then unfortunately your child/dependant will not be able to attend our online classes.

Please be assured that TAL takes its commitment to child safeguarding extremely seriously, and the relevant access controls and policies are in place. To this end, recorded lessons will only be accessible on our website for three months before they are automatically deleted.

d.Payment card information

Where you are purchasing our Services, i.e. paying TAL for your child/dependant to attend one of our online classes/tutorials, we will need to collect and use your payment information, including your credit/debit card or PayPal account details. This type of information is processed strictly in accordance with relevant payment card industry standards.

e.Automated interactions

As you interact with our website, we may automatically collect information from your device by using cookies and other similar technologies. Processing such information is necessary for us to pursue our legitimate interests in improving our website and providing a more relevant service to our customers. This information is not used to develop a personal profile of you. For further details, please see our cookies policy.

3.How do we use your personal data?

Your personal data will be used so that we can provide our Services to you. This includes assessing which courses are most suitable for your child/dependant and the provision of tutoring and feedback. We will also use your personal data to communicate with you, either in the course of delivering our Services, or to promote our business (see section 5 on Marketing). Your personal data may also be used for internal administration purposes, e.g. responding to your enquiries/complaints, to improve our website and Services and to comply with any legal and/or regulatory requirements placed on TAL, including our child safeguarding obligations.

4.On what legal basis does TAL process your personal data?

There are a limited number of grounds on which an organisation is permitted to handle personal data, known as the “legal basis for processing”. In general, we need this information because it is necessary in order for TAL to enter into and perform its contract with you. In addition, it is in TAL’s legitimate interests to collect your personal data in order to provide our Services, but only in circumstances where these interests are not outweighed by the need to protect your privacy or that of your child/dependant.

Furthermore, we rely on obtaining your explicit consent for handling your child’s/dependant’s personal data, including for video and audio recordings of our online classes (see section 2(c) above). Please note that you may withdraw consent at any time after you have given it, although this would not affect the lawfulness of TAL’s prior use of that personal data. However, due to the specific nature of our business, it is necessary for us to collect and use your child’s/dependant’s personal data, to be able to provide appropriate tutoring and courses relevant to their educational needs. So please note that withdrawing your consent will directly impact our ability to engage with them.

5.Does TAL use your personal data for marketing purposes?

TAL may use your personal data for marketing purposes, i.e. to form a view on which of our Services may be of interest to you.

You will receive marketing communications from us if you have requested to receive information from us, interacted with one of our advertisements on social media or have signed up to use our Services and you have not opted out of receiving that marketing.

In line with direct marketing rules, where we send marketing messages to you by email and/or SMS, you can ask us to stop at any time by following the unsubscribe link in the email and/or SMS. If you have received marketing material from TAL via social media and do not wish to do so, please adjust your social media advertisement/privacy settings.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of signing up to/engaging with our Services.

6.Who do we share your personal data with?

We may share the personal data that you have provided to us as necessary with service providers acting on our behalf, who will only use the data to provide that service under appropriate contractual arrangements with TAL. However, we will retain control of your data and any third-party service provider that we use must act in accordance with our instructions and the Data Protection Act 2018. We may also share your and/or your child’s/dependant’s personal data with a purchaser or potential purchaser of our business.

In some circumstances, we may have to disclose your and/or your child’s/dependant’s personal data for legal or regulatory purposes, such as where we have to report a safeguarding issue to a relevant authority or where a court, the police or other law enforcement agency or regulatory body has asked us for it.

7.Is your personal data transferred overseas?

As part of TAL’s global business and IT infrastructure, it may be necessary to send your personal data outside of the UK, most notably to Hong Kong and Mainland China. We have put in place appropriate, contractual protections to ensure that your data is safeguarded in accordance with applicable data protection laws.

8.What rights do you have concerning your personal data?

You may have various legal rights in relation to your personal data, such as the right to complain to the UK’s Information Commissioner’s Office (see section 9 below). This privacy notice does not list every right that you have under the Data Protection Act 2018, but we have set out the ones we consider most relevant to the handling of your personal data by TAL in the context of providing our Services to you.

You may have the right to ask TAL to:

  • provide a copy of your or your child’s/dependant’s personal data;
  • correct any inaccuracies in your or your child’s/dependant’s personal data;
  • withdraw your consent at any time to TAL handling your or your child’s/dependant’s personal data, where we rely on consent as the legal basis to do this (see section 4); and
  • delete your or your child’s/dependant’s personal data, where there is no lawful justification for TAL to retain it.

You may also have the right to object to TAL using your or your child’s/dependant’s personal data, where we do this for the purposes of our legitimate interests as outlined in section 4 above. If you lodge such an objection, we will stop using the relevant data unless we identify compelling legitimate grounds for continuing to use your personal data which override your or your child’s/dependant’s rights and interests.

To exercise or enquire about the above rights, please see section 13 below.

9.Complaining to the Information Commissioner’s Office

If you are unhappy with the way TAL is handling your personal data, please let us know.

Alternatively, if you do not agree with the way we have processed your data or responded to your concerns, you have a right to submit a complaint to the ICO:

https://ico.org.uk/make-a-complaint/

10.How long do we retain your personal data for?

We will hold your and your child’s/dependant’s personal data for as long as is necessary:

  • for performance of the Services you have requested; or
  • as required by law; or
  • for accounting or regulatory purposes; or
  • as otherwise described in this privacy notice.

Recordings of online classes are kept for three months as per section 2(c) “Online recordings” above.

11.Children

Due to the nature of the Services being provided, we will be processing the personal data of children under the age of 13. In line with data protection laws and as set out in section 4 above, all processing of your child’s/dependant’s personal data will only take place after obtaining the consent of the child’s parent or legal guardian.

12.How do we keep your personal data secure?

We are committed to ensuring that any personal data that you provide to us in the course of using our Services is kept securely. This includes implementing appropriate physical and technological security measures, such as access controls and careful selection of staff and third-party service providers. Where data is sent overseas, appropriate contractual provisions are in place to ensure the continued security of your personal data, as per section 7 above.

13.How can you contact us?

If you have any queries relating to this Privacy Notice, please contact Head of Marketing Nick HUANG (huangxiaoliang@tal.com).