This Privacy Policy explains how imoves active education ltd ("imoves", "we", "us" or "our") handles personal data when people visit our websites, contact us, purchase or administer a subscription, or use the imoves learning platform.
There are two different data-protection roles that can apply. In some situations imoves decides why and how personal data is used and is therefore a Data Controller. In other situations, particularly where a school or academy trust provides staff account details so that we can provide the subscribed platform, the school or trust is the Data Controller and imoves acts as its Data Processor.
1. Who we are
imoves active education ltd is a company registered in England and Wales under company number 07234665. Our registered office is 109 Rustlings Road, Sheffield, S11 7AB.
Privacy enquiries can be sent to ian@imoves.com.
2. When imoves is a Data Controller
imoves acts as a Data Controller where we determine the purposes and means of processing. This includes, for example:
· responding to enquiries from schools, teachers and other contacts;
· managing purchases, invoices, renewals and contracts;
· maintaining our own customer and prospect contact records;
· sending service information and, where permitted, marketing communications;
· administering our website and protecting our business, systems and legal rights; and
· meeting accounting, tax, legal and regulatory obligations.
3. When imoves is a Data Processor
When a school, academy trust or other subscribing organisation creates or provides staff user accounts for the imoves platform, that organisation normally determines which staff should have access and why. For that processing, the organisation is the Data Controller and imoves acts as its Data Processor.
Our processing in that role is governed by the subscription agreement and, where applicable, the imoves UK GDPR Data Processing Addendum. We process the relevant personal data only to provide, administer, secure and support the service, or as otherwise instructed by the Controller and permitted by law.
4. Personal data we collect
Depending on how you interact with us, we may process:
· name;
· school, academy trust or other organisation;
· job title or role;
· email address, telephone number and other business contact details;
· username, user ID and account status;
· login, lesson-view, usage and other platform activity information;
· IP address, browser/device information and similar technical logs;
· support enquiries and correspondence;
· billing, invoice, renewal and contract administration information; and
· marketing preferences and records of communications with us.
The standard school subscription is not designed to require schools to provide identifiable pupil data to imoves. Schools should not enter pupil names or other pupil personal data into the platform unless a specific feature expressly requires it and appropriate data-protection arrangements have been agreed.
We do not intend to collect special category personal data through normal use of the imoves platform. Please do not provide special category data unless it is necessary, lawful and specifically agreed with us.
5. How we obtain personal data
We may obtain personal data:
· directly from you when you contact us, register, purchase, renew or use the service;
· from your school, academy trust or employer when they create or administer your account;
· from publicly available education-sector sources where lawful and appropriate; and
· automatically through use of our websites and platform, such as account and technical usage information.
6. Why we use personal data and our lawful bases
Where imoves acts as a Controller, our lawful basis will depend on the purpose. We may rely on performance of a contract, steps taken at your request before entering a contract, our legitimate interests in operating and improving our services and communicating with schools, compliance with legal obligations, or consent where the law requires it.
Where imoves acts as a Processor, the relevant school, academy trust or other organisation is responsible for determining its lawful basis and for providing any privacy information required to its staff.
7. Quickbase - our platform sub-processor
For school and academy trust staff account information processed on behalf of subscribing organisations, imoves uses Quickbase, Inc. as its direct Sub-processor. Quickbase provides the cloud application and database technology used by imoves to store and manage authorised staff account information, account administration records and relevant platform usage data.
Quickbase states that its Quickbase platform is hosted in the United States and serves customers globally. Where UK personal data is transferred outside the UK, imoves requires an appropriate lawful transfer mechanism. Quickbase provides a Data Protection Addendum and states that it participates in the UK Extension to the EU-US Data Privacy Framework. Quickbase may use its own sub-processors in providing its service, subject to its data-protection commitments.
We do not sell school or academy trust staff account data to Quickbase, and Quickbase is not permitted to use that data for its own independent purposes except as permitted by its contract and applicable law.
8. Other sharing
We may share personal data where reasonably necessary with our employees and professional advisers, with service providers acting on our instructions, with regulators or public authorities where required by law, or in connection with a sale or reorganisation of all or part of our business. Where another organisation acts as our processor, we require appropriate data-protection terms.
9. International transfers
Some service providers may process personal data outside the United Kingdom. Where a restricted transfer takes place, we will use a transfer mechanism permitted by UK data-protection law, such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or an applicable adequacy arrangement such as the UK Extension to the EU-US Data Privacy Framework, together with any supplementary measures required by law.
10. Security
We use appropriate technical and organisational measures designed to protect personal data. Access to the imoves platform is controlled through user accounts and passwords, and access to administrative systems is restricted to authorised personnel. We also rely on the security controls of Quickbase for data stored and managed within that service.
11. Data retention
We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, including the period required to provide a subscription, deal with support or contractual matters, and meet legal, accounting or regulatory requirements. Processor data is deleted or returned in accordance with the applicable Data Processing Addendum and our normal backup and retention cycles.
12. Your rights
Where imoves is the Data Controller, you may have rights to access, correct, erase or restrict your personal data, to object to certain processing, and in some circumstances to data portability or to withdraw consent.
Where imoves is processing your personal data on behalf of your school or academy trust, you should normally direct your request to that organisation. We will provide reasonable assistance to the Controller in responding to valid requests.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data-protection regulator.
13. Marketing communications
You can ask us to stop sending marketing communications at any time by using the unsubscribe option in a marketing email or by contacting us. Service and account communications may still be sent where they are necessary to administer a subscription or respond to a request.
14. Cookies
Our websites may use cookies and similar technologies that are necessary for the website or platform to function and, where enabled, to understand how the service is used. Where the law requires consent for a cookie, we will ask for it before placing that cookie. Browser settings can also be used to manage cookies, although disabling necessary cookies may affect functionality.
15. Links to other websites
Our websites may contain links to third-party websites. We are not responsible for the privacy practices of those third parties, and you should review their privacy information when visiting their sites.
16. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our services, suppliers, legal requirements or data-protection practices. The latest version will be published on the imoves website with its revision date.
17. Contact
For privacy questions or requests, contact: Ian Pickles, imoves active education ltd, 109 Rustlings Road, Sheffield, S11 7AB, email: ian@imoves.com.