Unifrog Education Limited (company number 08231699) ("Unifrog" / "we" / "our" / "us") takes your privacy very seriously and is committed to protecting and respecting your privacy.
sets out the basis on which any personal data we collect about you, including through the Unifrog Website and/or the Unifrog Platform (each as defined below), will be processed by us.
Where we refer to the “Unifrog Website” in this Policy, we mean the website which can be accessed at https://www.unifrog.org, and where we refer to the “Unifrog Platform” we mean the parts of the Unifrog Website which you can only access if you have an account with us (including any updates or supplements to them).
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Unifrog is the data controller and is registered with the UK Information Commissioner’s Office with registration number Z357522X. Its registered office is Grand Union House, 20 Kentish Town Road, Camden, London, England, NW1 9NX. The Data Protection Officer is Alex Kelly who can be contacted at firstname.lastname@example.org.
Who Does This Policy Apply To?
This Policy applies to:
- “Visitor(s)” to the Unifrog Website, i.e. someone who visits and/or uses the Unifrog Website but who does not access the Unifrog Platform;
- “Student(s)” using the Unifrog Platform, i.e. someone who uses the Unifrog Platform to help plan their further education or career, for example, to search and compare educational courses, apprenticeships and training opportunities and to draft and upload personal statements and CVs;
- “Teacher(s)” using the Unifrog Platform, i.e. someone who uses the Unifrog Platform in a teaching or supervisory capacity, for example, to provide feedback, opinions or comments on Students (and review feedback, opinions or comments provided by other Teachers), to review Students’ academic performance, activities and/or comments, and to set target actions for Students;
- “Other School Staff”, i.e. someone who has been given administrative access rights to the Unifrog Platform and is using the Unifrog Platform to administer Students’ use of the Unifrog Platform and carry out supervisory tasks.
If you are a Student, Teacher or Other School Staff, Unifrog will have entered into an agreement with your school or college (“your School”) for the use of the Unifrog Platform (the “School Agreement”).
WHICH PROVISIONS OF THIS POLICY APPLY TO YOU?
Unless we say otherwise, the provisions of this Policy apply to all Visitors, Students, Teachers and Other School Staff.
DATA WE COLLECT FROM AND ABOUT YOU
We will collect the following data:
Data you give us.
You may give us data about you:
- when you complete a registration to use the Unifrog Platform (or request a demonstration of the Unifrog Platform);
- when you use the Unifrog Platform, for example, if you upload any data files or information that contains personal data (see further detail below);
- if you complete a survey or questionnaire at our request (including any survey or questionnaire we commission from a third party provider e.g. SurveyMonkey);
- if you provide feedback on the Unifrog Website or Unifrog Platform;
- when you report a problem with the Unifrog Website or Unifrog Platform; and
- if you contact or correspond with us (for example, by phone, e-mail or otherwise) for any other reason.
We will clearly set out which information you must provide us with in order to sign up and use the Unifrog Platform. If you do not provide us with this information, you will not be able to use the Unifrog Platform. All other information is optional.
If you are a Student, you:
- must provide us with your name, email address, gender and postcode;
- may provide us with details of your academic performance (including achieved and predicted grades) and any feedback, opinions or comments on your academic performance;
- may provide us with information about yourself (whether in a personal statement or CV, a record of an interaction with your Teacher, or otherwise), for example, your work experience, what educational courses, apprenticeships or training programmes or other activities you wish to undertake, any goals or skills that you wish to develop, your interests, hobbies and anticipated career path;
- may provide details of any further education you undertake, for example, where you go to university and the course you study, and details of any apprenticeships and/or employment you undertake;
- may provide information about yourself when you complete a survey or questionnaire at our request; and
- may agree to participate in a video “case study” about the Unifrog Platform for our promotional purposes, to be used on the Unifrog Website.
If you are a Teacher, you:
- must provide us with your name and email address;
- may tell us which Students and/or group of students you are responsible for;
- may provide us with information about yourself, Students, Teachers and others, for example, in feedback, opinions or comments you provide about Students, in records of interactions you have with Students or in target actions you require Students to complete; and
- may provide information about yourself when you complete a survey or questionnaire at our request; and
- may agree to participate in a video “case study” and/or provide written feedback on the Unifrog Platform for our promotional purposes, to be used on the Unifrog Website.
Data we collect about you.
If you are a Student:
- When you use the Unifrog Platform, details of your usage (including the date, time, location or duration of the usage).
Whether you are a Visitor, Student, Teacher or Other School Staff:
- If you visit the Unifrog Website or use the Unifrog Platform, we will automatically collect certain technical information, for example, the type of device (and its unique device identifier) you use to access the Unifrog Website or the Unifrog Platform, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform.
- We will automatically collect information about your visit to the Unifrog Website including the full Uniform Resource Locators (URL), clickstream to, through and from the Unifrog Website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Data provided by your School.
If you are a Student:
- we will obtain information about you from your School, for example which tutor group and/or year group you are in and which Teacher(s) teach you to verify your eligibility to access and use the Unifrog Platform and to allow your School and your Teachers to identify you when they use the Unifrog Platform;
- we may obtain other information about you from your School, for example your ethnicity, socioeconomic background and/or socioeconomic markers and whether you are a “looked-after” child; and
- we may obtain from your School details of any further education you undertake, for example any university you attend and course you study, and details of any apprenticeships and/or employment you undertake.
If you are a Teacher or Other School Staff:
- we may obtain information about you from your School, for example if you are a Teacher, the tutor group for which you are responsible, to verify your eligibility to access and use the Unifrog Platform.
USES MADE OF THE DATA
We will use the above personal data held about you:
- to enable you to use the Unifrog Platform;
- if you are a Student or Teacher or Other School Staff, to carry out our obligations under the School Agreement and to provide you with information and services that you request from us;
- if you are a Student, Teacher or Other School Staff, to help us identify you and any accounts you hold with us (including verifying your eligibility to access and use the Unifrog Platform);
- if you are a Student, to carry out research and statistical analysis, for example, so that we can provide your School with an analysis of Students’ use of the Unifrog Platform;
- if you are a Student, to make suggestions and recommendations to you about educational courses, open days, internships, apprenticeships, job opportunities and other similar services and opportunities offered by third parties (including universities, other educational establishments and employers) that may be available to you and/or interest you. For example, we may use our databases to analyse the subjects you are studying and/or your academic performance, in order to propose university courses, internships, apprenticeships or job opportunities to you. We will only contact you by e-mail with such information if you have specifically consented to this. More information about this is set out below under the headings “Marketing” and “Legal basis for processing”;
- if you provide personal data when you complete a survey or questionnaire at our request, to obtain your views and opinions on education;
- to deal with any enquiries, correspondence, concerns or complaints you have raised;
- for our internal operations, including data analysis, testing, research, statistical purposes and troubleshooting;
- to ensure that content on the Unifrog Website and Unifrog Platform is presented in the most effective manner for you and for your device;
- as part of our efforts to keep the Unifrog Platform secure; and
- to notify you about changes to any element of the Unifrog Website or Unifrog Platform.
If you are a Student, as mentioned above we would like to send you information by email and/or notifications on the Unifrog Platform about services and opportunities from relevant third parties such as universities, other educational establishments and employers which may be of interest to you.
We will ask whether you would like us to send you these emails and/or notifications when you complete your registration on the Unifrog Platform for the first time.
You can also manage your preferences by changing the privacy settings of your Unifrog Platform account.
We will not provide your personal data to any other third party businesses for marketing purposes, but if you agree, we may provide some of your personal data to your School for its alumni programme (please see below).
DISCLOSURE OF YOUR PERSONAL DATA
If you are a Student, we may share your personal data as set out below.
We will share some of your personal data with your School (including your Teacher(s) and Other School Staff) so that you can make the most of using the Unifrog Platform. For example, your Teacher(s) will be able to see some of your personal data, including your name, academic performance, personal statement and CV, details of courses and/or universities which you have searched for, and feedback, opinions and comments about you from other Teachers. We may also share details of any educational courses, open days, internships, apprenticeships, job opportunities and other similar services and opportunities offered by third parties (including universities, other educational establishments and employers) that are available to you with your School.
The information we share with your School may also be used by your School and by us for analytical purposes and to administer and facilitate your School’s use of the Unifrog Platform, for example to give your School an impression of how it is supporting its Students.
Your School and/or your Teacher(s) may choose to upload certain types of information to the Unifrog Platform which they do not want to share with you, for example, notes on your progress for other Teachers. This information may include personal data about you. Please see the section headed “Your rights” below for details on your right to access any personal data which we hold about you.
If you agree (by clicking the relevant button when you register to use the Unifrog Platform), we may share with your School some of your personal data after you have left school, being your name, email address, year of leaving school, and the course, university or apprenticeship you joined, so that your School can contact you about its alumni programme, for example to send you school news; invitations to events, reunions and networking opportunities; information about work experience, job opportunities and fundraising; and requests to speak at its events. We will rely on your consent as the legal basis for sharing this personal data with the School. You can withdraw your consent at any time by changing the privacy settings of your Unifrog Platform account, by emailing us at email@example.com, or by notifying the School, either by email or by using the unsubscribe link at the bottom of its messages.
If you are a Student or Teacher and you complete a survey or questionnaire, our survey provider, e.g. SurveyMonkey, may collect certain technical information, including data about your device or browser (such as your geographic location based on your device IP address) and data about pages you’ve visited and files you’ve viewed on their website or app to analyse your usage patterns, and for troubleshooting and bug fixing, for example.
Our survey provider, e.g. SurveyMonkey may also collect personal data contained in (or connected with) your survey or questionnaire responses, but this data will be aggregated and anonymised before being processed any further so that it cannot be linked to you.
Whether you are a Visitor, Student, Teacher or Other School Staff, you agree that we may share your personal data with the following categories of selected third parties in accordance with this Policy:
- analytics and search engine providers that assist us in the improvement and optimisation of the Unifrog Website and the Unifrog Platform; and
LEGAL BASIS FOR PROCESSING
- For some of the uses of your personal data (as described above) there is a legal basis under applicable data protection laws for us to use such personal data without your consent. This includes, for example, where it is necessary for us to use the information in order to provide the Unifrog Platform to you or where we have a legitimate interest to use it (a) to understand how the Unifrog Platform is used and by whom; (b) to improve the Unifrog Platform and ensure it is secure; (c) for statistical and analytical purposes; (d) for testing and troubleshooting or (e) to carry out surveys and research. Where this is the case, this Policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you or your School, by giving you appropriate notice and explanation of the way in which your personal data will be used.
- Where consent is required for our use of your personal data, by ticking the appropriate consent box or otherwise communicating your consent (for example, by email), you consent to our use of that personal data as set out in this Policy. For example, we will only process your personal data for marketing purposes if we have your consent to do so.
- You can always change your mind about our processing of your personal data. If you change your mind you can update your account settings within the Unifrog Platform, or contact us by email at firstname.lastname@example.org, or in respect of marketing messages you can unsubscribe by using the unsubscribe link at the bottom of those marketing messages.
If you are a Student or a Visitor under the age of 13, we will need consent from your parent (or someone with parental responsibility for you) (“your Parent”) to our use of your personal data as set out in this Policy. Your School is responsible for obtaining the necessary consent from your Parent. You will be unable to use the Unifrog Platform without the consent of your Parent. If your Parent changes their mind about our processing of your personal data, your Parent should inform your School, and your School will contact us to let us know.
WHERE WE STORE YOUR PERSONAL DATA
If your School is based outside the European Economic Area ("EEA"), we will process and store the information that we collect from you on our systems in the EEA, and we will also transfer personal data back to you (or your Students or Teachers) in your own country, in order to provide the Unifrog Platform to you and/or to fulfil our obligations in the School Agreement. We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Policy.
If your School is based in the EEA, we will only process and store your personal data in the EEA.
All information you provide to us is stored on secure severs. We will use technical and organisational measures to safeguard your personal data.
Where we have given you (or where you have chosen) a password which enables you to access the Unifrog Platform, you are responsible for keeping that password confidential. We ask you not to share your password with anyone else.
Unfortunately the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the Unifrog Platform; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
RETAINING AND DELETING PERSONAL DATA
We will retain the personal data we receive or collect about you for the period reasonably required for us to use it in accordance with this Policy or in accordance with our legal rights and obligations. We may need to retain some of your personal data for 6 years after you stop using the Unifrog Platform, for legal reasons, for example, in case you or your School make a complaint.
We may store your non-personal information indefinitely.
If you are a Student or Teacher, unless we inform you otherwise (or you request that we erase your personal data), we will retain your personal data on record for as long as you continue to use the Unifrog Platform. If you do not use the Unifrog Platform for 4 years then we will delete your information. We hold onto your information for this 4 year period so that you can continue to access useful information, such as personal statements and CVs, after you or the Students you teach have left school.
If the School Agreement terminates, we may delete some or all of your information from the Unifrog Platform. We will tell your School before we do so, so that you can download your information if you wish.
You have the following rights with regard to your personal data:
- Access. You have the right to obtain confirmation as to whether or not your personal data is being processed, and, if it is, request access to that personal data. We will need you to prove your identity before we release any personal data to you.
- Rectification or erasure. You have the right to request that we rectify or delete any personal data that we hold about you (unless we have the legal right to retain it).
- Restriction. You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful or we no longer need your personal information for the purposes of the processing.
- Change of preferences. You can change your data processing preferences at any time. For example, if you have given your consent to us to making suggestions and recommendations to you about educational courses, job opportunities, internships, open days, etc, but have changed your mind, you can contact us using the details provided below or clicking the relevant link in any communication you receive.
- Complaints. If for any reason you are not happy with the way that we have handled your personal data, please contact us. If you are still not happy, you have the right to make a complaint to the UK’s Information Commissioner’s Office.
- Data portability. In some circumstances, you have the right to request a copy of the personal data we hold about you, in a structured, electronic format, and to transmit such data to another organisation.
Please note that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed for you to use the Unifrog Platform you may not be able to use the Unifrog Platform as you did before. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.
If you would like to exercise any of the rights mentioned above, please contact us by emailing us at email@example.com.