We ask that you read this Privacy Policy carefully as it contains important details about what personal data Alpha Gen Learning (also referred to as "we," “AGL”, "us" or "our") collects and processes when you use our services, including the choices we offer you to access, maintain and control it.

1. Your Account and Service Data

1.1. When you register for and use our services or sign up to our competitions or free giveaways, we will collect and process your personal data, supplied by you, in order to be able to provide our services, competitions, giveaways, prizes and gifts to you.  Below is a table to inform you clearly of:

 

Data Collected	Purpose for Processing	Lawful Basis of Processing
Email address	- To manage registration, perform account management and provide customer services - To identify you within our services and service usage - Administrative - To contact you about events, services, prizes, gifts and free giveaways - Security	Contractual obligation, legal obligation, consent and legitimate interest
Username	-  To manage registration, perform account management and provide customer services -  To identify you within our services and service usage -  Administrative -  Security	Contractual obligation, legal obligation and legitimate interest
Password	- Security	Contractual obligation, legal obligation and legitimate interest
Country	- To manage registration, perform account management and provide customer services - Administrative (i.e. financial, legal and regulatory compliance) - To provide service personalisation and service improvement	Contractual obligation, legal obligation and legitimate interest
Occupation	-  To provide service personalisation and service improvement	Legitimate interest

 

1.2. We may also collect additional personal data if you supply it to us, become a paid subscriber or contact us. The consequences of not providing this personal data may be that you the services we provide to you will not be as customised, effective, or secure. Please refer to the description below:

Data Collected	Processing Purpose	Lawful Basis of Processing
First and Last Name	-       Provide a record keeping & prevention of crime -       Service personalisation and service improvement -       Security -       To contact you about products, events, services, prizes, gifts and free giveaways	Contractual obligation and consent
Full Address	-       Provide a delivery of prizes won and free gifts -       Record keeping & prevention of crime -       Service personalisation and service improvement -       Security -       To contact you about products, events and services	Contractual obligation and consent
Phone number	-       Customer services -       Security -       To contact you about products, events and services	Consent
Gender	-       Service personalisation and service improvement -       Security	Consent
Date of Birth	-       Service personalisation and service improvement -       Customer services -       Security	Consent
Profile Information	-       Service personalisation and service improvement -       Customer services -       Security	Consent
County	-       Service personalisation and service improvement -       Customer services -       Security	Consent
Profession	-       Service personalisation and service improvement -       Customer services -       Security	Consent
Enquiry and Correspondence Data	-       Customer services -       Account management -       To offer, market and promote products, events and services	Legitimate interests
Transactional Data (i.e. your payments)	-       To process information on your membership -       To provide good administration -       Business reporting	Contractual obligation and legitimate interest

 

1.3. Where legitimate interest is the lawful basis of processing your personal data, the legitimate interests we are pursuing are as follows: -

• Providing you any products or services you have requested.


• Analysing your use and measuring the effectiveness of our services to better understand how the service is being used so we can improve, engage, and retain users.


• Sending users information about our products, events and services, special offers and similar information (where your consent is not required).


• To enable and support our employees and sub-contractors.


• Analysing your use of our services and interaction with our communications, to tailor and customize our marketing communications.


• Diagnosing problems in our services.


• Conducting surveys and market research about our customers, their interests, the effectiveness of our marketing campaigns, and customer satisfaction (unless we need consent is required, then appropriate communications will take place)


• Investigating and responding to any queries or complaints that we may receive.


• In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with legal process or litigation).

1.4. Where contractual and legal obligations are the lawful basis of processing your personal data, the consequence of failing to provide your personal data will be that we are unable to provide our service to you.

1.5 We may process information relating to you where this has been provided by a charity, school of third party.  To elaborate, your employer may have provided us with your work contact details so that we can communicate with you and set up your school account; or your email may have been provided to our school referral service by someone who thought our service may be of interest to you and your school. or a charity that is working with yourself may have passed us your details in order to assist you. In every case, we will provide you with the appropriate details from where we obtained your personal data in accordance with data protection laws.   

2. Your Alpha Gen Learning Service Usage Data

2.1. When you interact and make use of our services, we may capture and process usage data and may use this data to provide rewards and incentives either randomly or as part of a programme and we may publicly publish your success in achieving these rewards or incentives. This data is ultimately processed with the purpose of delivering reliable, secure, and accurate services and to consistently enhance, improve and optimise your experience of using our services. We do not sell this data to third parties. Our legal basis for this processing is that of legitimate interest. Examples include: IP address; browser type and version; operating system used; website speed, website navigation paths and actions; and patterns of service use.

3. Sharing Your Personal Data

3.1. We will disclose your personal data to our employees to enable them to process your data.

3.2. Your personal data may also be disclosed to other companies in the AGL group, and to our agents, sub-contractors, data processors and suppliers (3rd parties) to enable them to process your personal data on our behalf.

3.2. When we supply any of your personal data to our agents, sub-contractors, data processors and suppliers (3rd parties), we protect your personal data by ensuring reasonable contractual arrangements are in place that stipulate compliance with this Privacy Policy.

3.3 Where your access to our services is granted under a school membership account, we shall, upon request, share your usage data (which shall include your downloads and login data) with the school or organisation that manages the relevant school membership account. This is normally done by providing the information to the Account Administrator of the relevant school membership account.  

4. Marketing and Product Preferences

4.1. We may use account, service, and usage data to provide you with information about our products and services. Our purpose is to provide you with a service to help meet your needs. Our lawful basis for processing this data is consent. You are free to withdraw your consent at any time. The consequences might be however, that we cannot offer you certain things, such as offers and promotions or resource alerts, which may be beneficial to you.

4.2.  You may change your preferences or opt-out at any time by either accessing ‘Your Contact Preferences’ within your AGL account or by unsubscribing from AGL marketing emails by using the 'unsubscribe' link at the end of the email received. Please note that as an AGL user or subscriber you are unable to unsubscribe from customer service emails (such as service updates) as these are required to provide our service to you and the lawful basis of processing is contractual or legitimate interests depending on the circumstances.

4.3. If you have signed up for a competition or gift without being a service subscriber, you may opt-out at any time by using the unsubscribe link at the end of the email received. 

5. Our Use Of Cookies and Stored Device Data

5.1. A cookie is a small text file that is downloaded onto a computer or smartphone when the user accesses a website. It allows the website to store and retrieve information about how the device is using the website.

5.2. The AGL website uses cookies and stored device data for the following purposes:

-      To ensure the correct technical functionality of the services we provide and optimise global performance - for example, to help you find the most relevant content and get that content to you quickly and accurately

-      To maintain website security, prevent website abuse and ensure legislative/regulatory compliance - for example, to prevent cyber-attacks

-      To compile, and enrich, internal business data regarding website traffic and activity - for example, to help us to understand our most popular website pages, visit sources and time-of-day traffic

-      To advertise AGL services to you across our website and on 3rd party websites - for example, to market and remarket AGL services to you using Google AdWords when using Google Search

-      To help to improve our services to you and better meet your future needs

5.3.    If at any point you wish to withdraw consent for the use of cookies you can clear these from your browser by clearing your website history and configure your browser to block cookies. Some of our website features may not function correctly and/or you may not receive the best website experience if you disable/do not consent to the use of cookies.

5.4 We use AdWords re-marketing to attract you back to our website with content that may be of interest to you. To do this we advertise using Google search and Google recommended websites. Google uses cookies to track your activity and show you adverts that may be of interest to you and they use this data to show you relevant messages.

6. How We Protect Your Personal Data

6.1. We have put in place several security procedures and technical organisational measures to safeguard your personal data. These measures are reviewed regularly and updated, when necessary, in order for us to meet business needs and in accordance with changes in technology and regulatory requirements.

6.2. We will use all reasonable efforts to safeguard your personal data. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from you or to you via the Internet.

7. Overseas Transfers

7.1. The personal data you provide may be transferred to countries outside the United Kingdom and the European Economic Area ('EEA') that do not have similar protections in place regarding your data and restrictions on its use as set out in this Privacy Policy. However, transfers outside of the UK and EEA will be protected by us imposing appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission to ensure the security of your data or via, independent privacy schemes approved by regulators. 

7.2. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your data, you consent to these transfers for the purposes specified above.

8. Your Rights Under Applicable Data Protection Law

8.1. We respect and value your right to access and control your data. You can exercise your rights, subject to appropriate identity verification procedures, by using  the following method:

• - By contacting our customer services team using admin@studybank.co.uk

9. Data Retention

9.1. We retain personal data for as long as we reasonably require it for legal or business purposes. When determining data retention periods, we take into consideration applicable laws, contractual obligations and the expectations and requirements of our customers. When we no longer need personal data, we securely delete or destroy it.

9.2. If you have signed up for competitions and/or free giveaways and are not registered for and use our services, data will be retained for 30 days after the prizes or giveaways have been dispatched unless you have consented to being contacted for more information on Twinkl services or for receiving marketing emails. 

10. Sale of Business

10.1. If Alpha Gen Learning is sold or integrated with another business your personal data may be disclosed to our advisers, or any prospective purchasers and their advisers, and will be passed on to the new owners of the business.

11. Your Consent

11.1. By using or interacting with our service, or by signing up to competitions and free giveaways, you are consenting to:

-      the use of cookies and other technologies

-      the transfer of your data outside of the country where you live

-      the transfer of your data outside of the European Economic Area

-      the collection, use, sharing, and other processing of your information as described in this Privacy Policy.

11.2. In each case, you consent to the processing of data by Alpha Gen Learning, as data controller. If you don't agree with the terms of this Privacy Policy, then please don't use our service.

11.3. Where the lawful basis of processing your data is consent, you have the right to withdraw your consent at any time. To withdraw your consent, please contact our Data Protection Officer using the details below.

12. How do we use social media?

12.1 We may use social media and social networking services for promoting our business, communicating with you, and supporting the teaching community. To do this, we require the use of third-party service providers, such as Facebook, Twitter, LinkedIn, Instagram, and YouTube. 

12.2 Our social media pages, groups, feeds, and channels are administered by these third parties:

-      Our Facebook page is administered by Facebook, in accordance with Facebook's Data Policy available here, and is accessible by Facebook users who have already consented to Facebook's Data Policy.

-      Our Twitter account is administered by Twitter, in accordance with Twitter's Privacy Policy.

-      Our Instagram account is administered by Instagram in accordance with Instagram’s Privacy Policy.

-      Our YouTube channel is administered by YouTube, in accordance with their privacy policy.

-      Our LinkedIn page is administered by LinkedIn, in accordance with their privacy policy.

12.3 We may message you directly through social media when you contact us through these platforms. Our lawful basis is that of consent.

12.4 We may export your social media profile information or content (such as your name or social media username) to our own systems if there is a reasonable need to do so, in order to review and record whether they have broken our social media page or group rules. Our purpose is to effectively manage our social media platforms and ensure that they are managed in accordance with our social media group and page rules. Our lawful grounds are based on legitimate interests. Our legitimate interests are to protect our business, employees, sub-contractors, and followers.

Protecting our Intellectual Property Rights

12.5 In order to protect our intellectual property, our brand and business, we may collect or use your personal details where we have reason to believe that you or any organisation you represent is infringing on our intellectual property rights. We may obtain your personal details from:

-      you or your organisation’s website or social media profiles,

-      Companies House,  

-      The Charities Commission,  

-      The Intellectual Property Office,  

-      Social media,  

-      Other public body,  

-      Any other publicly listed source.  

12.7 We may use your personal information to:

• review any potential infringement of our intellectual property.


• provide you with a cease-and-desist communication.  


• take legal action or notify a third party that our intellectual property rights are being infringed.   

12.8 Our lawful grounds are based on legitimate interest. Our legitimate interest is to protect our business.

13. Changes to this Policy

13.1. We keep this policy under regular review. If we change the content of our Privacy Policy we will post the changes on this page.