Privacy Policy

December 2018

PLEASE READ THIS POLICY CAREFULLY BEFORE USING RIPPLE EDUCATION LIMITED’S SERVICES

Protecting your data, privacy and personal information is very important to Ripple Education Ltd ("Ripple", “us”, " our" or “we”).

This policy (together with our terms of use and any other documents referred to in it), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by Ripple. Please read this privacy policy carefully to understand the types of information we collect from you, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to the personal data you provide to us.

When visiting Ripple’s website at pango.education (our “ Website”) or using any of the services offered via the Website (the “Services”), you acknowledge, and where applicable consent to, the practices described in this policy.

Our Website contains links to third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.

Information we may collect

We may collect and process the following data about you:

  • Information that you provide to us. You will be asked to provide us with your information when you:

- fill in forms on our Website, or correspond with us by phone, email or otherwise;

- register to use our Services;

- use the Services;

- report a problem with our Website or Services; or

- complete any surveys we ask you to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).

You must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.

For the avoidance of any doubt, any reference in this privacy policy to your data shall include data about other individuals that you have provided us with.

The information you will be asked to provide to us for these purposes will include your name, address, date of birth, email address, phone number, location, name of employer or place of work, and job title.

  • Information we collect about you. With regard to each of your visits to our Website we may automatically collect the following information:

- device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;

- technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and

- details of your visits to our website, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs).

  • Information we receive from other sources . When using our Services, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Services. This includes information the school or education provider you work for, where you have given us permission to do so, and any third party applications which are integrated with our Services.

Information we may collect about others. We may collect and process data about others that you provide us with, including (but not limited to) information that you provide by filling in forms on our Website or that you provide to us by email. This information might include, but is not limited to, any information you provide to us when using our Services such as names of colleagues you wish to invite to use the Services, and information regarding any students who may appear in your lesson plans, such as first names, educational needs or behavioral information. Although Ripple does not require and will not request that you provide us with such information when using the Services, if you do include it in lesson plans, it will then be collected and by us in accordance with this privacy policy. You should ensure that you have all necessary rights and permissions before sharing such personal data with us.

How we use your information and justification of use.

Use of personal information under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your information:

- Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);

- Contract performance: where your information is necessary to enter into or perform our contract with you;

- Legal obligation: where we need to use your information to comply with our legal obligations;

- Vital interests: where we need to use your information to protect your vital interests;

- Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and

- Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you or a third party.

We use information held about you (and information about others that you have provided us with) in the following ways:

Types of Information Collected

Uses of that Information

Use Justification

First and last name, email address, password, location, phone number, name of employer or place of work, job title

To provide you with access to our Website and any other information which you request from us, including registering for and managing a Ripple account in order to use the Services.

Legitimate interests (to manage user sign-up processes)

First and last name, email address, location, name of employer or place of work, job title

To ensure you receive information relevant to you.

Legitimate interests (to provide you with information about your account, information about the Services, and any other information you request from us)

First and last name, email address

For marketing, provided always that we: (i) only use aggregated and anonymised data; or (ii) only engage in direct marketing for products and/or services provided by Ripple that we believe will be of interest to you and only where you have explicitly consented to this (Please see ‘Marketing’ below)

Legitimate interests (to tailor marketing)

IP address, browsing details, operating system, and other technical information collected by cookies on our Website.

To ensure the content on our Website is presented in the most effective manner for you and your computer or mobile device.

Legitimate interests (to improve our Services and optimise your use of them)

First and last name, email address, password, location, name of employer or place of work, job title, IP address

To administer our Website and for internal operations, including research, data analysis and data statistics.

Legitimate interests (to optimise and improve the Website)

First and last name, email address, location

To notify you about changes to our Services.

Legitimate interests (to optimise and improve your use of the Services)

We will not sell your personal data (or any other data you provide us with) to third-parties; however, we reserve the right to share any data which has been anonymised and/or aggregated. You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymised data collected or created by us.

Marketing

We may use information for marketing products and services to you in the following ways:

Type of marketing activity

Use Justification

Newsletters and marketing emails relating to our own similar services and products. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.

Legitimate interests (to market our products and services – you have the right to unsubscribe at any time)

To send you details about our own unrelated services or products or special offers and discounts which are being provided by our selected business partners. Where required by law, we will ask your consent at the time we collect your data to conduct any of these types of marketing.

Consent (which can be withdrawn at any time)

We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us at support@pango.education.

Disclosure of your information

We may disclose your personal information to our service providers and business partners, including Microsoft Corporation, LogRocket, Inc. and The Rocket Science Group LLC, d/b/a Mailchimp (to assist us in performing any contract we enter into with them or you, including providing the Website and the Services it enables), analytics providers, including Google, Inc., Facebook, Inc. and Hubspot, Inc. (to assist us in the improvement and optimisation of the Website).

In addition, we may also disclose your personal information to third parties in the following circumstances:

Purpose of disclosure and third party(s) to which disclosure might be made

Use Justification

If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets

Legitimate interests (to dispose of our business)

If Ripple or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets

Legitimate interests (to uphold the contract in the context of a sale of our business)

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Ripple, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection

Legal obligation (to comply with our legal and regulatory obligations)

Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or accurate information is provided and fraud is identified or suspected, details may be passed to fraud prevent agencies.

Legitimate interest (to assist with the prevention of fraud and to assess your risk profile)

We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

Legitimate interests (to cooperate with law enforcement and regulatory authorities)

Security over the internet

No data transmission over the internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.

Sensitive information between your browser and our Website is transferred in encrypted form using secure socket layer (“SSL”) or equivalent cryptographic protocols using certificates issued by a trusted third party authority.

All information you provide to us is stored on our or our subcontractors’ secure servers, and accessed and used subject to our security policies and standards.

We use hosted servers (such as [insert]) in the course of our business, including for the permission of marketing and sales activity. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share your password with anyone.

Exports outside the EEA

Your personal information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) in which data protection laws may be of a lower standard than in the EEA. Regardless of location or whether the person is an employee or contractor, we will impose the same data protection safeguards that we deploy inside the EEA.

Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals, we will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient, unless we are permitted under applicable data protection law to make such transfers without such formalities.

Please contact us if you would like further details of the specific safeguards applied to the export of your personal data.

How long we retain your personal data

We will hold the above information for as long as is necessary in order to conduct the processing detailed in the table above, deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body. Once your account is terminated or deactivated, we shall delete the personal data relating to your account within 3 years. Some personal data may need to be retained for longer than this to ensure Ripple can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing.

If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.

We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the personal risk or harm from unauthorized use or disclosure, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights

Under the General Data Protection Regulation (EU) 2016/679, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at support@pango.education.

In certain circumstances, you have the following rights in relation to your personal data:

Rights

Details

Right of Access

You have the right to obtain from us information as to whether your personal data is being processed, and, where that is the case, access to such personal data.

Right to Rectification

We will use reasonable endeavors to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.

Right to erasure / ‘Right to be forgotten’

Asking us to delete all of your personal data will result in Ripple deleting your personal data without undue delay (unless there is a legitimate and legal reason why Ripple is unable to delete certain of your personal data, in which case we will inform you of this in writing).

Right to restriction of processing

You have the right to ask us to stop processing your personal data at any time.

Right to data portability

You have the right to request that Ripple provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so and the processing is based on consent or contractual performance.

Right to complain

You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage our customers to engage with us in the event they have any concerns or complaints.

Ripple will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.

Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use Ripple’s Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services.

Where you request Ripple to rectify or erase your personal data or restrict any processing of such personal data, Ripple may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right.

Changes to this policy

Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. We therefore encourage you to review it from time to time to stay informed of how we are processing your information.

Contact

Questions, comments and requests regarding this privacy policy are welcome and should be addressed to support@pango.education.

For the purpose of the relevant data protection legislation, the data controller is Ripple Education Ltd (company no. 11137591), with registered address at Third Floor, 20 Old Bailey, London, EC4M 7AN, UK.

Cookies

Ripple uses cookies to distinguish you from other users. This helps us provide you with a good experience when you use our Website, and also allows us to improve our Services. Please note that it is possible to disable cookies being stored on your computer by changing your browser settings. However, our Website may not perform properly or some features may not be available to you if you disable cookies.

For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.