We take your privacy very seriously and are committed to protecting the safety and security of your personal information. In order to deliver our products and a range of services to meet your needs, we need to collect personal information as well as data on how you use our websites.
By using the site or requesting the provision of services you will be deemed to have read and understood this Policy. If you do not agree with this Policy, please do not use the site.
This Policy contains details on the following:
- Information we collect and how we use it
- Who we will share your personal information with
- How we store your personal information
- Your rights, including opt-in and opt-out
- Your rights to access your personal information, keep it up to date and ask us questions
- Cookies – what they are and how we use them
- Why we link to other websites
- How long we hold your information
We may post changes to this Policy from time to time, so do review it regularly. This Policy was last reviewed on 17 May 2018. If you have any questions about this Policy or the information that we hold, please contact us by e-mailing firstname.lastname@example.org or write to us at Twig Education Limited, 4th Floor, 14 North Claremont Street, Glasgow, G3 7LE.
1. Information we collect and how we use it
We collect and use your personal data, service usage data and other information provided for our legitimate interests so that we can make our services available to you, provide services you request, administer the services and suggest similar products to you that you may be interested in.
We do not believe that our collection and use of your personal information for these purposes will unduly prejudice your rights and freedoms.
Please note that schools who are subscribers and their employees are the owners of the data from their systems that is stored on our cloud services and Twig Education is the data processor for the purposes of the General Data Protection Regulation (GDPR).
We prefer that schools (or agents and distributors) do not email attachments containing teacher and student data to Twig Education. Should you choose to do so, it is the responsibility of the sender to comply with their organisation’s internal data protection protocols and ensure encryption or secure protection of any attachments.
- Information collected on your visit to our site
We automatically collect certain non-personally identifiable information when you visit our site such as the type of browser you are using, the type of operating system you are using, and the domain name of your Internet service, your IP address. This enables us to review site usage, e.g. information on which pages are more popular than others, which allows us to improve the design and content of our site.
- Information collected when you register or contact us
We collect personally identifiable information about you, e.g. your name, address, telephone number, email, etc., only when you choose to complete and submit a registration application to us or if you contact us directly. This information enables us to:
- administer your registration and manage accounts including password resetting etc.
- provide you with the personalised features and the particular site service(s) for which that registration was necessary
- use the personally identifiable information you provide to us when you contact us directly to respond to your specific inquiry or to administer the relevant site activity to which it relates e.g. to enter you into a site competition or to supply information, quotes or services you have requested
- contact you with relevant information about changes and enhancements to the service as well as additional resources and content suggestions to improve your experience of our products and services
- contact you with marketing material on products and services that may interest you where you have opted in to receive this material; you may opt out of these communications at any time.
- Information collected when you post on our sites
You should be aware that you may be making available personally identifiable information about yourself when you submit material to be posted to the site e.g. for forums or other interactive elements of the site. Please take care when doing so. You can always contact us if you wish to remove any such information (see Your rights section below)
- Information we collect from third parties
We may collect information from third parties about you from time to time. This information is necessary for us to recognise you as a registered subscriber.
2. Who we will share your personal information with
- We do not and will not sell your personal data to any third party, however we may share your personal information with our current or potential commercial partners e.g. agents, investors and sponsors etc.
- When you provide your registration application, and in some cases when you supply personally identifiable information directly to us from certain parts of the site, we may provide you with the opportunity to opt-in to certain uses e.g. to provide you with information about the site or other services that you may find of interest.
- We will only use your personally identifiable information for marketing purposes or share your personally identifiable information with anyone else for marketing purposes if you have specifically consented to that. Remember that you can opt-out of these again at any time - see Your rights section below. In all cases the information will be securely stored with our CRM and marketing systems (Salesforce and Pardot). Data kept for marketing purposes can be updated at any time by clicking on the unsubscribe link that appears in all our email communications. You will have the option to update your marketing preferences linked to your email address or deselect yourself from all non-account based email communications.
- Please be aware that it is possible, though unlikely, that we might be forced to disclose personally identifiable information in response to legal process or when we believe in good faith that the law requires it.
3. Where we store your personal information
Your information is stored in secure database servers and we employ appropriate technical and organisational security measures to prevent unauthorised access to information that we collect online. Twig Education aims to ensure that any data uploaded to our systems is secure in transit and at rest on our servers. To ensure this we make use of SSL certificates for transfer of data to and from our websites.
Our underlying technology and data storage provider is Amazon Web Services. Information on their position on GDPR can be found here: https://aws.amazon.com/compliance/gdpr-center/
We also make use of:
- If you reside in the EEA, personal information you provide to us will, in general, be stored within the EEA. In the event that we need to store your personal data outside of the EEA, we will ensure that any service providers are compliant with the GDPR.
- Your personal information will only be stored as long as we need to use it to service your usage of our websites or services.
- Anonymisation of data is carried out on a regular basis as appropriate.
4. Your rights, including opt-in and opt-out provisions:
- You have the option at any time to request that we provide a copy of the personal information we hold relating to you and we shall try to provide this information to you within one month of your request.
- You have the right to ask us to update or remove any such personal information. Please note that when we delete personal information from our system your access to the website will be restricted and some areas will not be available to you.
- You have the right to ask us to stop contacting you where we do this in accordance with your previous consent.
- You have the right to complain to the ICO if you do not think we have handled your data in accordance with this policy.
5. How you can access your personal information, keep it up to date and ask us questions about this policy
To contact us please email email@example.com or write to us at Twig Education Limited, 4th Floor, 14 North Claremont Street, Glasgow, G3 7LE.
- A cookie is a text-only string of information that a website transfers to the cookie file of the browser on a user's computer hard disk so that the website can remember who the user is. A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.
- When you visit our site we send you a cookie. Cookies may be used in the following ways:
- To enable the personalisation features on our site, which give you the ability to recall recently viewed pages and see information which you have provided online.
- To compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our site. We cannot identify you personally in this way.
- Two types of cookies may be used on this site, session cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site, and persistent cookies, which remain in the cookie file of your browser for much longer, though how long will depend on the lifetime of the specific cookie.
- You have the ability to accept or decline cookies by modifying the settings in your browser. You may not, however, be able to use all the interactive features of our site if cookies are disabled.
7. Third party services
- You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
- You can find more information about the individual services we use and the purposes for which we use them in the table below:
|Twigscotland.com||This service is used when you register and login. This is necessary to allow you to use the logged in features and to enable our site to remember your preferences.|
We use New Relic in order to monitor the performance of our website’s servers.
New Relic recognises your browser and tells us how and when pages in our website are visited by returning or new visitors and by how many people.
|Google Analytics||Google Analytics is used to track usage patterns and the audience who use our site. We use Google Analytics Demographics and Interest reporting.||To opt out: Google Opt-Out|
|Google Advertising||Google Advertising tracks which of our adverts performs the best.||To opt out: Google Opt-Out|
|Visual Website Optimizer||This service allows us to perform A/B, multivariate testing and customisations on our site so we can test new features and improve the functionality of our site.||To opt out: Visual Website Optimizer Opt-Out|
8. How long we keep your personal data
- We retain personal information for as long as it is needed to provide access to the website or to manage your account. We take reasonable steps to delete the personal information we collect three years after your subscription lapses or if it remains inactive (i.e. no log-in) for three years. We will delete your personal data if you opt out of receiving further communications from us or if you ask us to delete your information. We may however retain and use personal information to comply with our legal obligations, to resolve disputes and to enforce our agreements.
- We may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytic purposes and for product and service improvement.