CONTENTS

1. Important information and who we are

2. The data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary of terms

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Introduction

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Welcome to Trinity Learning Ltd's privacy policy.

Trinity Learning Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and/or provide us with data when you purchase a product or service, and tells you about your privacy rights and how the law protects you.

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1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Trinity Learning Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service.

We understand that where we collect personal data of children, enhanced protections should be in place. Accordingly, and where necessary, we will notify parents / guardians of the personal data that we collect.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

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Children's Privacy

Trinity Learning Ltd is committed to protecting the privacy of children who use our services or visit our website. We recognise that children require specific safeguards and enhanced protections regarding their personal data.

In accordance with applicable data protection laws, we require verifiable parental or guardian consent before collecting, using, or disclosing personal data from any child under the age of 13 (or under 16 where required by applicable local law).

To obtain and verify parental consent, we implement appropriate verification procedures, such as requesting a signed consent form, verifying identity through payment details of the parent or legal guardian (which are not stored as the child's personal financial data), or direct confirmation via email or phone with the parent or legal guardian. If we learn that we have collected personal data from a child without the necessary verifiable parental consent, we will take immediate steps to delete that information from our servers.

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Trinity Learning Ltd ensures that all services are developed and executed in full compliance with the Information Commissioner's Office (ICO) Age-Appropriate Design Code, also known as the Children's Code. We maintain that the best interests of any child remain our paramount priority throughout all data processing activities. To ensure maximum protection, child account settings are configured to High Privacy by default. As the controller, Trinity Learning Ltd ensures these default settings reflect our commitment to managing your data responsibly. We prohibit the use of children's personal data for any form of commercial profiling, behavioural monitoring, or targeted advertising. Any processing of a child's information is strictly limited to the essential data required to facilitate the delivery of the educational products or services requested.

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Controller

Trinity Learning Ltd is the controller and is responsible for your personal data (collectively referred to as "Trinity Learning Ltd", "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager responsible for overseeing questions about this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

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Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Trinity Learning Ltd

Email address: lindaquinn@trinitylearning.co.uk

Postal address: Glynde Combe BN86RP

Telephone number: 08006889960

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

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Changes to the privacy policy and your duty to inform us of changes

We review our privacy policy regularly.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

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Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

• We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth, gender, occupation and nationality.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Profile Data includes your username and password, purchases or orders you make, your interests, preferences, feedback, and survey responses.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from our third parties and us and your communication preferences.

• Educational Data includes lesson attendance records, academic progress reports, tutor-student interaction logs, and notes taken during or about educational sessions.

We also collect, use, and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law, as it will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data and use it in accordance with this privacy policy.

 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

 

A specific clarification regarding the personal information of children: regardless of the groupings defined previously, Trinity Learning Ltd does not obtain, handle, or maintain any Financial or Transactional details pertaining to minors. All such fiscal activities must be executed by a parent or legal guardian. Furthermore, any Profile, Technical, or Usage information associated with individuals below the age of 13 is either subjected to rigorous anonymisation or processed exclusively for essential system functionality, and is strictly prohibited from use in developing commercial marketing profiles.

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If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

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3. How is your personal data collected?

We use different methods to collect data from and about you, including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

1. Apply for our products or services;

2. Create an account on our website;

3. Subscribe to our service or publications;

4. Request marketing to be sent to you;

5. Enter a competition, promotion or survey; or

6. Give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using cookies, server logs, and similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

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Technical Data from the following parties:

(a) analytics providers such as Google based outside the UK;

(b) advertising networks such as Google based outside the UK; and

(c) search information providers such as Google based outside the UK.

• Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services such as Global Pay or WeChat Pay, which may be based outside the UK.

• Identity and Contact Data from data brokers or aggregators which may be based outside the UK.

 

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data and the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.​​