1. Your personal data – what is it?
According to the General Data Protection Regulation 2016/679 (the “GDPR”), ‘personal data’ relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by GDPR.
2. Who are we?
Elevate Education (Elevate) helps students develop proven and effective study habits. Students are often expected to know “how to study”, but rarely are they able to develop best practice study skills on their own. Elevate’s mix of high impact student, faculty and parent workshops help schools create an environment of best practice, leading to lasting behavioural change for students.
Founded in 2001, Elevate has become an award-winning, global provider of study skills programs. Working with over half a million students across the US, the UK, Australia, South Africa, and Singapore, Elevate Education has developed a proven track record of engaging students, fostering critical thinking skills, and improving student outcomes through an integrated process that works.
In terms of data processing, Elevate Education is the data controller, this means, as indicated in the GDPR, that Elevate determines the purposes and means of the processing your personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
3. About the data that Elevate collects?
3.1 Elevate’s primary reason for collecting personal information is to supply customers or users with the products and services it or its suppliers and partners offer. Elevate only collects personal information where the information is necessary for Elevate to perform its functions or activities.
3.2 Elevate will process personal information from individuals only if is lawful. Fully complying with Article 6 of the GDPR.
4. When is the data collected?
Elevate collects information in the following ways:
• From information that you provide us when purchasing goods or services from the company or enquiring into their purchase;
• Online contact forms;
• Account registration process;
• When financial transactions are conducted with Elevate through its website;
• Through subscription to a company mailing list; or
• Through website cookies used to collect website usage information.
5. How do we process your personal data?
Elevate complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
5.1 Elevate uses the information collected for the primary reason of providing its goods and services to you. The use of the information includes administration and billing, account management, communication to you about Elevate’s goods and services, account keeping and other related functions.
5.2 Elevate may use your information to communicate offers of Elevate goods and services to you or one of its related entities.
5.3 Elevate may also use your information:
• To manage our candidates, employees and contractors;
• To maintain our own accounts and records;
• To operate the Elevate’s website and deliver the services that individuals have requested;
• To inform individuals of news, events, activities or services running at Elevate; and
• To contact individuals via surveys to conduct research about their opinions of current services or of potential new services that may be offered.
6. What is the legal basis for processing your personal data?
Elevate complies with the lawfulness of processing describe in Article 6 of the GDPR. The legal basis for processing your personal data are:
• The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract;
• Processing is necessary for compliance with a legal obligation to which controller is subject;
• Processing is necessary for the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.
7. Disclosure of your information
The information that Elevate collects is disclosed to third parties when you have:
• Consented to the use or disclosure of the information;
• When third party financial transactions are required to be processed to provide Elevate’s goods or services;
• Where we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone’s health or safety or the public’s health or safety;
• Where we reasonably suspect that unlawful activity has been, is being or may be engaged in and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities;
• Where such use or disclosure is required under or authorised by law;
• Where we reasonably believe that the use or disclosure is necessary for prevention, investigation, prosecution and punishment of crimes or wrongdoings or the preparation for, conduct of, proceedings before any court or tribunal or the implementation of the orders of a court or tribunal by or on behalf of an enforcement body.
8. Security of your information
8.1 Elevate places a great importance on the security of all information associated with our customers. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control.
9. How to access, correct, update, or erase your information?
9.1 Elevate is committed to maintaining accurate, timely, relevant and appropriate information about our customers and website users;
9.2 As long as your request for your personal information is reasonable and you provide us with a proper reason as to why you want to access the information, we will give you access to that information by contacting us at firstname.lastname@example.org;
9.3 We will attempt to correct inaccurate information upon receiving advice from you. To ensure confidentiality, details of your personal information will only be passed on if we are satisfied that the information relates to you;
9.4 If we refuse to provide you with access or correct the personal information held about you by us, then we will provide reasons for such refusal.
10. How long do we keep your personal data?
Elevate retains the information you provide to us to enable us to verify transactions and customer details and to retain adequate records for legal and accounting purposes.
Elevate will keep some forms of information for longer than others.
We are would hold your data for a period no longer than two years, unless there are specific requirements; or if any request in line with the Article 17 indicates otherwise.
When data is no longer required it is appropriately destroyed. A Data Retention Policy exists, which outlines the procedure to be used for retention and the disposal of personal information.
11. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing.
12. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
• The right to request a copy of your personal data which Elevate holds about you;
• The right to request that Elevate corrects any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary for Elevate to retain such data;
• The right to withdraw your consent to the processing at any time;
• The right to request that Elevate provides you with the data it retains, orwhere possible, to transmit that data directly to another data controller, (where applicable) [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable) [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]
• The right to lodge a complaint with the Information Commissioners Office.
13. How to contact Elevate?
14. Accepting our Policies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For more information visit: https://uk.elevateeducation.com/cookies
You can set your browser to not accept cookies (To learn how to remove cookies visit www.allaboutcookies.org). However, in a few cases some of our website features may not function as a result.
16. Changes to our Privacy Notices
For browsers of our websites, we may change this Privacy Notice from time to time and you should check it regularly. Your continued use of Elevate websites will be deemed an acceptance of the Privacy Notice on the website or service at the time of each use.
Where this Privacy Notice has been provided to you together with additional terms for the use of a product or service that you have subscribed to or registered for, the notice provisions of those terms will apply.