Privacy Policy

Introduction
Welcome to the Steiner Waldorf School Fellowship Limited's privacy policy.

SWSF respects your privacy and is committed to protecting your personal data. This privacy policy will inform you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy
This privacy policy sets out the basis on which any personal data we collect from you, or that you provide through your use of:

  • the SWSF Digital Planning Tool mobile application, available on our website (the App); or
  • any other website that displays this privacy policy (the Website); and
  • any updates or supplements to them,

will be processed by us.

For you use of the App only, this policy (together with our end-user licence agreement (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

  • the App, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
  • Any of the services accessible through the App (Services) that are available on the Website or other sites of ours. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
  • This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller
Steiner Waldorf School Fellowship Limited is the controller and responsible for your personal data (collectively referred to as "SWSF", "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Steiner Waldorf School Fellowship Limited
Email address: admin@steinerwaldorf.org
Postal address: 35 Park Road, London NW1 9XT
Telephone number: +44 (0)2045249933

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 27th September 2022. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
The App and Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App or Website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Device Data includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.
  • Financial Data includes bank account and payment card details.
  • Location Data includes details of your current location disclosed by GPS technology.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data (such as statistical or demographic data) for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law. This is because this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • create an account on our App or Website;
    • apply for our products or Services;
    • subscribe to our Service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our App or Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out:
    • Technical Data from the following parties:
      • analytics providers such as Google based outside the UK; and
      • search information providers.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    • Identity and Contact Data from data brokers or aggregators.
    • Identity and Contact Data from publicly available sources.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform a contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Please refer to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Except for use of the App, we generally do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To install the App and register you as a new App user (a) Identity
(b) Contact
(c) Financial
(d) Device 		Consent
To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App 		(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Device
(f) Marketing and Communications
(g) Location 		Consent

Necessary for our legitimate interests (to develop our products/Services and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing (a) Identity
(b) Contact
(c) Device 		Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To manage our relationship with you including notifying you of changes to the App or any Services (a) Identity
(b) Contact
(c) Financial
(d) Profile
(e) Marketing and Communications 		Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To process in-App purchases and deliver Services including managing payments and collecting money owed to us (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Device
(f) Marketing and Communications
(g) Location 		Consent

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical 		Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Necessary to comply with a legal obligation
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical 		Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage 		Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications 		Necessary for our legitimate interests (to develop our products/services and grow our business)
To enable you to participate in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Device
(d) Profile
(e) Marketing and Communications 		Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies
We use cookies to distinguish you from other users of the App or Website and to remember your preferences. This helps us to provide you with a good experience when you use the App or Website, and also allows us to improve the App and Website.

If you use our Website, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For more information about the cookies we use, please see our cookie policy below.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation on how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with selected third parties in accordance with this policy, including:

  • any individual or organisation we have a contract with to the extent this is necessary for the providing them with the App or Website and/or content;
  • any member of our group of companies, including our subsidiaries and ultimate holding company;
  • service providers (for example, IT services and CRM services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or the organisation, but also when providing you with marketing communications;
  • analytics and search engine providers that assist us in the improvement and optimisation of the App and the Website;
  • government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information);
  • in the event that we sell any business or assets or receive investment into our business, in which case we may disclose your personal data to the prospective buyer or investor;
  • if the App, Website or substantially all of its assets are acquired by a third party, in which case personal data held by us, including your personal data, will be one of the transferred assets; and
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Terms and Conditions for the App or the Website terms of use or any other contract between you and us; or to protect the rights, property or safety of the App, the Website, our users, and others.

INTERNATIONAL TRANSFERS

The personal data that we collect from you may be transferred to, processed and stored at, destinations outside the UK or European Economic Area (EEA). Where we transfer, process or store your personal data out of the UK or EEA, we ensure that a similar degree of protection is afforded to it by ensuring that one of the following safeguards is implemented:

  • we will only transfer your personal data to countries that, under law, have been deemed to provide an adequate level of protection for personal data; or
  • we may use specific contracts approved under UK and/or EEA law which give personal data the same protection it has under law.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How long will you use my personal data for?
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 privacy policy or in accordance with our legal rights and obligations. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Unless we inform you otherwise (or you request that we erase your personal data), we will retain your personal data (whether you are a user or your data is recorded in our database in order for us to provide the App or Website on record for as long as we provide the App. This helps us maintain records to demonstrate our contractual compliance and may assist us in analysing how we provide the App or Website in the future.

Even if you request that we erase your data, we may still need to keep it (please see below).

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the following rights with regard to your personal data:

  • Access. You have the right to access data we hold about you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • 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). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Correction. You have right to request a correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Data portability. You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Restriction. You also have the right to restrict us from processing your personal data: (i) if you want us to establish the data's accuracy; (ii) the processing is unlawful but you do not want us to erase it; (iii), where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Object / Change of preferences. You have a right to request that we stop processing your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes. For example, if you have given your consent to receive updates from us about new products or services, but have changed your mind, you have the ability to opt out from receiving such communications going forward by contacting us using the details provided below or clicking the relevant link in any communications you receive. Please note, if you submit a request for us to stop processing your personal data in a certain way and this type of processing is required in order to facilitate your use of the App or Website, you will no longer be able to use the App or Website following your request for us to stop the relevant processing.
  • 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 ICO. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
  • Automated decision making. We do not currently carry out decisions based solely on automated processing, including profiling. If we change our practices to do this in a way which has legal or similarly significant effects on you, you may have the right to object. If this becomes relevant in the future, we will update this policy to provide further information.

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 to facilitate your use of any of the App or Website you may not be able to use the App or Website as you did before. This does not include your right to object to direct marketing, which can be exercised at any time without restriction. Please allow at least 3 working days for your request to be actioned.

Please note that the rights mentioned above do not extend to non-personal data. Please also note that it is likely to be necessary to retain your personal data for the purposes of assessing and verifying data that is submitted and/or held on the App or Website and to manage the App or Website, so therefore your rights under applicable law to request erasure may be limited accordingly.

If you would like to exercise any of the rights mentioned above, please contact us at Steiner Waldorf Schools Fellowship Ltd, 35 Park Road, London NW1 9XT or by email at admin@steinerwaldorf.org. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee to comply with your request. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Cookie Policy

Our App and Website use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our App or Website and also allows us to improve our Services.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

By clicking “agree” on the cookie consent box when you access the App or Website you accept our use of the cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website or the App.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of the App and the Website. They include, for example, cookies that enable you to log into the App.
  • Analytical/ performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the App and the Website when they are using it. They also enable us to see how users use the App. This helps us to improve the way the App and the Website work.
Website Cookie Purpose Expiry
artofteaching.org.uk .AspNet.ApplicationCookie Store user logged in status End of user session
artofteaching.org.uk __RequestVerificationToken Validate user input End of user session
artofteaching.org.uk cookie_consent_user_accepted Cookie message acknowledged 62 days
artofteaching.org.uk cookie_consent_level Store individual cookie preferences 62 days
artofteaching.org.uk cookie_consent_user_consent_token Agreement to use cookies 400 days

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.

To deactivate the use of third party advertising cookies, you may visit the consumer page to manage the use of these types of cookies.

You can choose which analytical, functionality and targeting cookies we can set by updating your cookies preferences and clicking on the toggles(s):

Functionality cookies Active/Inactive
Tracking cookies Active/Inactive
Targeting and advertising cookies Active/Inactive

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.