By using The Student Wellbeing Ambassador Programme (SWAP), you acknowledge that your personal information (referred to in this Privacy Notice as Customer Data and Usage Data) will be used by WellSenz Ltd and shared with other companies who support WellSenz Ltd (referred to in this Privacy Notice as Support Companies) in providing the SWAP to you.
We need to use personal information in order to provide personalised learning through the SWAP. It is always used responsibly, transparently and securely. We will never sell personal information nor use it to market or sell non-WellSenz products or services. We are compliant with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).
Who we are and how to contact us
The SWAP is owned and operated by WellSenz Ltd (referred to as, we, our or us). WellSenz Ltd is a company incorporated in England and Wales with company number 12483456. Our registered office is at PHYLANDEAS & CO FIRST FLOOR, 10 HAMPDEN SQUARE, LONDON, N14 5JR We are registered with the Information Commissioner’s Office under registered number CSN3913076.
You can contact us about the SWAP by:
- Clicking ‘Help’ tab and submitting your query;
- Emailing email@example.com
This Privacy Notice is for the following categories of SWAP user groups (Users):
- Group Leaders: These are teaching and support staff employed by a school in the UK
- Subscribers: These are students enrolled onto the SWAP by Group Leaders from the school they attend
This Privacy Notice was published in February 2021 and applies to the use of personal information by WellSenz in connection with the SWAP. It aligns with the requirements of the Data Protection Act 2018 and GDPR. We may make changes to this Privacy Notice from time to time, so you should review this Privacy Notice periodically in case changes have been made. We will get in touch with you to let you know about any particularly important changes that we need to make.
In this Privacy Notice:
Personal information is any information about a User which can identify that User. It does not include any information where the User’s identifying information has been permanently removed so that we can’t identify the User (this is known as anonymised information); and
using (or any derivations of it such as use or uses) in the context of personal information includes (as applicable and without limitation) collecting, recording, organising, combining, storing, pseudonymising (temporary removal of personal information), anonymising (permanent removal of personal information) and deleting.
How does the SWAP get personal information?
Users provide personal information when they create and use their SWAP account. This is called Customer Data. Data is also generated through Users’ use of the SWAP. This is called Usage Data.
What personal information is collected?
Customer Data provided by Users in order to create a SWAP account or when a User uses or interacts with SWAP includes:
- Your name, your username, your email address and your password;
- Comments and ratings that you provide to us when you respond to our requests for feedback on the SWAP (but we will not identify you as the person who gave the feedback unless you have told us it is OK to do so);
- Support requests, comments or questions regarding the SWAP that you submit to us;
- Your social media handle/username if you interact with us on social media (for example by messaging us directly);
Usage Data collected in connection with the SWAP includes:
- Unique identifiers, such as SWAP usernames;
- Progress through the SWAP;
- Answer history and results for all quizzes taken;
- The platform, browser type and device used to access SWAP; and
- Platform analytics, including pages viewed, links clicked, journeys through the SWAP and platform session recordings – i.e. how you have interacted with the SWAP when using it.
How is personal information used?
We use personal information in order to provide the SWAP and to undertake research and marketing. Our lawful bases for using personal information are:
- To supply you with the SWAP: we use personal information so we can deliver the SWAP to subscribers (on your own behalf) and Group Leaders (on your own behalf and also on behalf of your subscribers) when you pay for student access the SWAP;
- Set up and administer User accounts;
- Conduct invoicing, payment processing and undertake for other accounting purposes;
- Provide technical support and deal with help requests and enquiries;
- To contact you: to interact with you when you contact us, for example for support purposes or to supply password re-set links;
- Build performance and progress profiles;
- Display performance and progress information via the Group management and report pages;
- Ensure Users are complying with our SWAP Terms and Conditions;
- For research: we undertake research to evaluate and improve the SWAP;
- For marketing: we use personal information to investigate user trends and inform marketing activity;
- To comply with the law: we may be obliged to process personal information to comply with statutory or legal obligations, for example in the unlikely event we are required to assist police with a fraud investigation.
Personal information will never be sold or used to market or sell non-WellSenz products or services.
Location and Security of personal information
All personal information is stored by Automattic, owners of WordPress.com. WellSenz Ltd has a Data Processing Agreement with Automattic. This is a contract that documents Automattic’s compliance with the GDPR requirements that apply to them as a data processor for the SWAP.
Your rights in relation to your personal information are:
The right to be informed of processing
Providing a link to this Privacy Notice on our website
The right to access personal information by making a subject access request (i.e. a right to a copy of the information about you that we use)
Personal information records may be requested by contacting firstname.lastname@example.org
The right to rectification where personal information is inaccurate or incomplete (i.e. the right to correct personal information about you that isn’t accurate)
Requests to rectify personal information records should be sent to email@example.com
The right to erasure, sometimes called ‘the right to be forgotten’ (i.e. the right to delete the data that we use about you)
Requests for erasure of Customer Data can be made by contacting firstname.lastname@example.org
The right to restrict processing (i.e. the right to limit our use of your personal data)
Data use can be restricted by contacting email@example.com and requesting that your account be deleted
The right to object to processing (i.e. the right to stop us using your personal information)
Objections to processing can be submitted by contacting firstname.lastname@example.org and requesting that your account be deleted
You also have the right to make a complaint at any time to the ICO regarding the use of personal information by WellSenz in connection with the SWAP. However, we would appreciate being given the chance to help you with your concerns before you approach the ICO, so please contact us if you have a complaint. For more information about the ICO please visit https://ico.org.uk/for-the-public/.
How to contact us
If you have questions, comments or requests regarding the personal information that we use, or regarding this Privacy Notice more generally, please contact email@example.com