Privacy Policy

Last updated: 21st September 2020.

You can find summarised guides of our privacy policy in our help center.

• Guide for students
• Guide for parents
• Guide for teachers

This Privacy Policy explains how we use the personal information that Seneca Learning Ltd collects or generates both in relation to this website and our products and services. The list below sets out what is covered in this Privacy Policy and you can click on the headings below to go to a specific section.

• BACKGROUND
• THE PRODUCTS AND SERVICES WE PROVIDE
• THE TYPES OF PERSONAL DATA WE COLLECT
• HOW WE USE YOUR INFORMATION
• DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
• INTERNATIONAL TRANSFERS OF PERSONAL DATA
• HOW WE SAFEGUARD YOUR INFORMATION
• HOW LONG WE KEEP YOUR PERSONAL DATA
• YOUR RIGHTS
• DESIGNATED REPRESENTATIVE
• QUESTIONS AND CONCERNS

BACKGROUND

Seneca Learning Ltd with its registered office at Seneca Learning Ltd, Tintagel House, 92 Albert Embankment, London SE1 7TY [and other companies in the Seneca group] collect(s) and use(s) certain Personal Data. Seneca is responsible for ensuring that it uses that Personal Data in compliance with data protection laws. At Seneca we respect the privacy of our clients and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Seneca in the course of carrying on commercial activities. We use the following definitions in this Privacy Policy: “Seneca”, “we or “us” means Seneca Learning Ltd [and other companies in the Seneca group]. “Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Seneca (or its representatives or service providers or [any other companies in the Seneca group]). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Seneca or any other person in respect of an individual.

THE TYPES OF PERSONAL DATA WE COLLECT

Many of the services offered by Seneca require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described at paragraph 2.1 above, we will collect and process the following Personal Data about you:

Information that you provide to Seneca.

This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):

• basic Personal Data (such as first name; family name; school name; email address); and
• any information that you choose to share on Seneca which may be considered Personal Data.

Information that we collect or generate about you.

This includes (by way of non-exhaustive list):

• a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you;
• any information that you provide through the Website which may include contact information, or information relating to Seneca Products that you acquire or express interest in; and
• activity data relating to your use of the Website or your use of any Seneca Products or Services.

Information we obtain from other sources

• Cookies. When you visit Seneca’s Website, cookies are used to collect technical information about the services that you use, and how you use them. [For more information on the cookies used by Seneca please see our Cookie Notice].
• [Anonymized data. In addition to the categories of Personal Data described above, Seneca will also process further anonymized information and data that is not processed by reference to a specific individual.]

HOW WE USE YOUR INFORMATION

Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• for ongoing review and improvement of the information provided on Seneca’s Website to ensure that the Website is user friendly and to prevent any potential disruptions or cyber attacks;
• to allow you to use and access the functionality provided by the Seneca Products;
• to assess your application for Seneca Products, where applicable;
• to set up customers to use Seneca Products;
• to set up users to use the Website, Seneca Products and Seneca Services;
• to understand feedback on Seneca Products and to help provide more information on the use of those products and services quickly and easily;
• to communicate with you in order to provide you with services or information about Seneca and Seneca Products;
• to understand your needs and interests;
• for the management and administration of our business;
• in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; and/or
• for the administration and maintenance of databases storing Personal Data.
• for the administration and maintenance of databases storing Personal Data.

However we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:

• we need to do so in order to perform contractual obligations with our customers;
• we have obtained your consent;
• we have legal and regulatory obligations that we have to discharge;
• we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

The use of your Personal Data as described is necessary for our legitimate business interests, such as:

• allowing us to effectively and efficiently manage and administer the operation of our business;
• maintaining compliance with internal policies and procedures;
• monitoring the use of our copyrighted materials; and
• enabling quick and easy access to information on Seneca Products and Seneca Services.
• We will take steps to ensure that the Personal Data is accessed only by employees of Seneca that have a need to do so for the purposes described in this Privacy Policy.

DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

[We may share your Personal Data within the Seneca group of companies for the purposes described above.] We may also share your Personal Data outside of Seneca or [outside of the Seneca group] for the following purposes:

• with our business partners. For example, this could include our partners from whom you or your company or your organisation purchased the Seneca Product(s). Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
• with third party agents and contractors for the purposes of providing services to us (for example, Seneca’s accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Policy;
• to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
• if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
• if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

Seneca operates on a global level. Our customers and our operations are spread around the world. As a result we may collect and transfer Personal Data on an international basis whilst at all times ensuring that we adhere to European GDPR legislation. That means that we may transfer your Personal Data to locations outside of your country. Where we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:

• the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
• in other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.
• You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in paragraph 11 below].

HOW WE SAFEGUARD YOUR INFORMATION

• We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.
• As a condition of employment, Seneca’s employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by a Seneca employee is prohibited and may result in disciplinary measures.
• When you contact a Seneca employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.

HOW LONG WE KEEP YOUR PERSONAL DATA

How long we will hold your Personal Data for will vary and will be determined by the following criteria:

• the purpose for which we are using it – Seneca will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

YOUR RIGHTS

In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Seneca;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
• You can exercise your rights by contacting us using the details listed in paragraph 11 below.
• If you are not active on Seneca for a period of 6 years, all personal & account data will be deleted automatically.

DESIGNATED REPRESENTATIVE

Seneca’s registered office may be contacted using the following contact information.

• Address: Seneca Learning. Tintagel House, 92 Albert Embankment, London SE1 7TY.
• Email Address: learnmore@seneca.io

We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Privacy Officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction, which in the UK is the Information Commissioner’s Office (“ICO”). Upon request, Seneca’s Privacy Officer will provide you with the contact information for that regulator.