Privacy Notice for Educators
At Learning Labs Ltd we are committed to protecting and respecting your privacy.
This Privacy Notice exists to ensure that you are aware of how personal information is used by our products and services and the rights you have regarding said information. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Who are we?
Learning Labs Limited is a company incorporated the UK. Our Company Number is 06176270 and our address is iCentrum Building, Innovation Birmingham Campus, Holt Street, Birmingham, B7 4BP. Our ICO Registration Number is ZA279313
If you would like to contact us with any queries regarding this Privacy Notice, please contact us at dpo@flashacademy.com.
What do we do?
Learning Labs Ltd are responsible for the creation of FlashAcademy. As the UK’s No.1 EAL platform, FlashAcademy helps over 1000 schools and 250,000+ learners to accelerate their EAL skills from 45+ home languages
We also provide access to services and platforms to support schools, pupils, and consumers with MFL and ESOL.
FlashAcademy has additional features that allow schools to conduct assessments and provide custom lessons and activities for classroom, independent, and remote learning. Our digital EAL proficiency assessment helps teachers to digitally baseline their pupils’ English skills and track progress over time.
Scope of this notice:
This notice (together with our end-user licence agreement as set out at www.flashacademy.com/eula and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:
• The FlashAcademy Application (App) either downloaded from the Google/Apple stores or accessed or streamed via www.flashacademy.com (App Site) including web.flashacademy.com and edu.flashacademy.com.
• Any of the services accessible through the FlashAcademy platform that are available on other sites of ours (Services Sites), unless the EULA states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.
We will only process personal information in accordance with UK Data Protection Legislation, including but not limited to the UK GDPR and the Data Protection Act 2018.
Where you are a school, you will be the data controller and we will be the data processor.
We may change the Privacy Policy from time to time by amending this page, you will be notified if this occurs.
Information we collect from you:
We may collect, process, store, or transfer information as part of the services we provide. This includes the following:
- Personally Identifiable Information (Identity Data): The information we collect will change depending on your arrangement with us.
Schools can be distinguished by being MIS Integrated and not MIS Integrated (“Manual”). The categories of data subject here are any users authorised by a school, such as staff and students.
All Schools (MIS Integrated and Manual): We collect staff names, staff emails and student names, student date of birth. Optionally, we can collect parent names and emails.
MIS Integrated Schools: We also collect pupil year group, pupil form group.
Optional for MIS Schools: Gender and ethnicity information.
The App also records test results and collects written text and voice recordings submitted as answers by students.
- Technical Information: By using the App or any of the Services, you agree to us collecting and using the following technical information about the devices you use the App on and related software, hardware, and peripherals to improve our products and to provide any Services to you:
- Cookies: We use cookies to distinguish you from other users of our App and services. This helps us to provide you with an improved experience when you use the App or browse any of the sites, and it also allows us to improve the App and our sites.
- We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Our Sites may contain links to content maintained by third parties that we do not control. We are not responsible for the privacy practices of these third parties, nor do we endorse them, and the information practices of these third parties are not covered by this Privacy Policy.
- When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
How long we keep your data for:
We keep personal information for no longer than 6 months past the end of contract date. After this point it is anonymised in our systems and stored securely.
We will keep staff contact data for as long as you do not opt out of receiving communications from us, to allow for contact regarding late-renewal and marketing in the event of subscription lapse.
We may also keep personal data for any time periods by law where we are under a legal obligation or entitlement to retain your data for longer, such as accounting and litigation purposes.
Disclosure of your information:
We will disclose some or all of the data we collect from you when you download or use the App to the following third parties who provide us with services that we use as part of providing you with our Services: Google Play Services; Apple App Store/ iTunes Connect; Amazon Web Services; MongoDB; MixPanel; Salesforce; Wonde. We may also disclose your information for educational reporting purposes or where legally required to, to educational bodies, such as the DfE, Local Authorities, Multi-Academy Trusts, Education Partnerships or Education Federations.
We may disclose your personal information to any member of our group which means our subsidiaries, our ultimate holding company, and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may also disclose your personal information to third parties to investigate potential breaches.
Legal basis and purposes for processing your information:
Each of the following data types is processed in order to fulfil our obligations under contract, to provide you with the service, with aggregate data being the exception.
| Type of Data | Purpose | Legal Grounds |
Technical Information | To process data analytics and stored information to continuously improve our services and user experience. | Necessary for our legitimate interest, so that we can improve our service. |
| Forenames/Surnames/E-mail Addresses | To allow account creation on the Teacher Dashboard. To communicate with staff members using the platform. | Necessary for our legitimate interest, this is necessary for the use of the platform and to support users. Staff name and email is also needed to allow us to enter a contract with schools. Account creation is needed for us to fulfil the obligations of such contract. |
| Pupil Year/Form/DoB | To facilitate adding pupils onto the platform in bulk and to facilitate features tailored towards pupils by age. | Necessary for our legitimate interest, to allow streamlined user admin. |
| Optional: Gender & Ethnicity Data | To allow for for detailed reporting using useful metrics for senior leadership in schools/trusts. | Consent: By accepting these optional permissions, we understand a school has opted to share this information and have sought consent to do so where necessary. |
| Aggregate data (collated information that is not personally identifiable i.e., # of lessons complete by primary schools in the north of England) | We may gather statistics to see how our platform is being used, trends, and how we can improve the service. We may also use this for marketing purposes. | Necessary for our legitimate interest, to improve our services. |
Where we store your personal data:
The data that we collect from you is stored securely in the cloud with Amazon Web Services encrypted servers. The physical location of these servers is in London. Learning Labs Ltd retain control over the encryption key.
Data is not transferred outside the UK. In the event that data must be transferred outside the UK, we will contact the relevant parties and use an International Data Transfer Agreement to facilitate this.
Any payment transactions carried out by our chosen third-party provider of payment processing services detailed above will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features (i.e. encryption, two-factor authentication, SSO, password protection) to try to prevent unauthorised access. We may collect and store personal data on your Device using application data caches and browser web storage (including HTML 5) and other technology.
For staff only, certain Services (such as our Help Centre) may include social networking or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected, or used by other users.
Your rights:
You have the right to ask us not to process your personal data to contact you regarding account usage and engagement.
We will seek consent to contact you for marketing purposes. At any point you have the right to withdraw this consent.
We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at Learning Labs Limited, Birmingham Science Park, Holt Street, Birmingham, B7 4BB, England or dpo@flashacademy.com.
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Access to and update of your information:
You have the right to access a copy of all personal data held about you free of charge. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent to dpo@flashacademy.com.
Deleting your information:
You can ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where you have withdrawn consent for us to process it (as explained below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
How you can object to us using your data:
You can ask us to limit the way in which we are using your information or object to certain types of processing. We will do our best to comply with your request unless we must use the information for legitimate business or legal purposes.
Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing you with our service.
Any queries or concerns about the way in which your data is being used can be sent to dpo@flashacademy.com.
Moving your information to another organisation:
You have the right to request that we send a copy of the personal data we hold about you to another organisation in electronic format, for example when you are dealing with a different service provider. If you would like us to move, copy, or transfer your information to another organisation please let us know at dpo@flashacademy.com. We will respond to you within one month after assessing whether this is possible, taking into account the technical compatibility with the other organisation in question.
Withdrawing consent:
You have the right at any time to withdraw any consent you have given us to process your personal data. Please note, if you withdraw your consent, it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent.
Should you wish to do so you can contact us at any time via email to dpo@flashacademy.com.
Changes to privacy notice:
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. The new terms may be displayed on-screen, and you may be required to read and accept them to continue your use of the App or the Services.
Contact and your right of complaint:
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Learning Labs Limited, Birmingham Science Park, Holt Street, Birmingham, B7 4BB, England or dpo@flashacademy.com.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or by calling 0303 123 1113.