21C Privacy Notice (Effective Date 1st August 2024)
This Privacy Notice sets out how 21st Century Digital Teaching Limited (“21C”) processes personal data in connection with our 21C business, including the provision of our website at https://www.21c.digital/ (“Site” or “Platform”) and the services we offer, including through our Platform (our “Services”).
The Privacy Notice applies whether you are using the Service (i) via your school or other organisation (for example, as a teacher, student, or sometimes as a parent/guardian) or whether (ii) you sign up directly with us and have your own subscription and account (for example, as a parent, child, or tutor). Different parts of the Privacy Policy apply in different ways to these two scenarios. This will be explained further below, especially in sections 2 and 8.
We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to stay up to date on how we use your personal data.
PURPOSE OF THIS PRIVACY NOTICE
This Privacy Notice explains our approach to any personal data that we might collect from you or which we have received or obtained about you from a third party, as well as the purposes for which we process your personal data and how we share it with others. This Privacy Notice also sets out your rights in respect of our processing of your personal data.
When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual, such as their name, address, an identification number, location data, an online identifier (such as an IP address), or other factors specific to them.
This Privacy Notice is intended to assist you in making informed decisions when using our Platform and our Services. Please take a moment to read and understand it. It should be read in conjunction with the relevant 21C contract with your school or other organisation (if you are accessing through their account) or in conjunction with our Terms and Conditions and our Cookie Policy.
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third-party websites over which we have no control or you purchase goods or services from those third parties).
ABOUT US AND OUR ROLE
The Platform and our Services are made available by 21ST CENTURY DIGITAL TEACHING LIMITED (known as “21C”, “we”, “us”, “our”). 21ST CENTURY DIGITAL TEACHING LIMITED is an English company (No: 13527420) with its registered office at Suite 117, Worlds End Studios, 132-134 Lots Road, London, England, SW10 0RJ.
If you are accessing and using the Service via your school or other organisation (for example, as a teacher, student, or sometimes parent), that organisation to which you are affiliated is the relevant Data Controller (and you should review their privacy notices), and 21C is their Data Processor. In this situation, we only have access to and use your Personal Data under the relevant Data Controller’s instruction and to fulfil our contract with that organisation, i.e., to provide you with access to the Services they have contracted us to provide. We have no independent rights regarding your personal data.
If you sign up directly with us and have your own subscription and account (for example, as a parent or child, or a tutor), 21C is the Data Controller, and we have broader permissions (and obligations) in relation to your Personal Data, as detailed below.
Different parts of the Privacy Policy apply in different ways to these two scenarios. This will be explained further below.
HOW TO CONTACT US
If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us using the following methods:
On-Site: Contact us via https://www.21c.digital/contact-us/
Email: Send us an email at info@21c.digital
Post: Write to us at Suite 117, Worlds End Studios, 132-134 Lots Road, London, SW10 0RJ
WHO WE COLLECT OR ARE PROVIDED WITH PERSONAL DATA ABOUT
We collect, receive and process personal data about the following people:
Site Visitors: If you browse our Site and/or register with us in any way, we will collect and process your personal data in connection with your interaction with us and our Platform.
Teachers/Staff at Educational Establishments, and Parents/Guardians if they use that account: If your organisation buys or uses our Services for its students, and you have responsibility for placing orders and/or administering your organisation’s account, or otherwise use that service via the organisation’s account, we will receive and process your (and the students’) personal data in connection with your organisation’s relationship with us.
Parents/Guardians/Tutors: If you subscribe directly to use our Services, including on behalf of a student, and you have responsibility for administering your account with us, we will collect and process your, and your students’, personal data in connection with your and the student’s subscription relationship with us.
Students: If your educational establishment buys or uses our Services and/or creates an account or login for you, we will receive and process your personal data in connection with them and your relationship with us.
Children: If your parent/guardian or tutor buys or uses our Services and/or creates an account or login for you, we will receive and process your personal data in connection with their and your relationship with us.
Customers: If you otherwise purchase our Services, we may collect and process your personal data in connection with the supply of goods or services to you.
Enquiries: If you contact us with an enquiry through our Platform, submit a complaint or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us.
Event Attendees: If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form or other document relating to the event.
RESPONSIBILITY FOR STUDENTS/CHILDREN’S DATA
The Platform enables educational establishments and/or parents and guardians (and tutors) to make the services on the Platform available to students/children via their subscription agreement. The students/children will only be able to access the Platform if the educational establishment or parent/guardian or tutor has provided the student/children with the appropriate login or ID access code.
The educational establishment/teacher or parent/guardian or tutor will need to provide the following data on behalf of the students/children: Identity Data and Registration Data (see below for what this means). Additional information which will be collected from students/children in connection with signing into the Platform will be username and password only, or they may log in via Microsoft or Google accounts, etc.
Students should refer to their educational establishment’s privacy policy to understand more about how the personal data provided or captured in relation to the Services is used in the course of the provision of education by that establishment, and also see Section 9 below about “Sharing Personal Data”.
It is the responsibility of each educational establishment and/or teacher or tutor to ensure that in relation to any students to whom they intend to provide a login or an ID access code (including, without limitation, students under the age of 13), they have been provided with all necessary consents and permissions (including from a parent and/or guardian) to use the Platform and for 21C to receive, collect and process any personal data. The educational establishment and/or teacher and/or the parents and guardians or tutors acknowledge and warrant that they have and will provide all requisite authority from, and on behalf of, the student/child, including, where relevant, the parent/guardian of the student.
When a student/child reaches the age of 13, there is a legal requirement to retake consent directly from the student/child, and 21C relies on the relevant educational establishment and/or the parents and guardians or tutors to secure that consent.
WHAT PERSONAL DATA WE COLLECT OR RECEIVE
The types of personal data we collect or receive and process depend on who you are and how you use our Platform and Services and may include the following:
Type of Data | Examples | Applies to |
Identity Data | First name; last name. | Teachers/Staff; Parents/Guardians/Tutors; Students/Children |
Contact Data | Address; email address; telephone number. | Teachers/Staff; Parents/Guardians/Tutors |
Registration Data | First name; last name; gender; country; nationality; username; educational establishment; any other personal data that may be provided when registering. | Teachers/Staff; Parents/Guardians/Tutors; Students/Children |
Financial Data | Bank account details; payment card details. | Parents/Guardians/Tutors (If you have subscribed for your own account) |
Transaction Data | Details about payments made; details of products purchased. | Parents/Guardians/Tutors (If you have subscribed for your own account) |
Profile Data | Account username; password; profile picture or avatar; purchase/order details; interests and preferences; contact preferences. | Teachers/Staff; Parents/Guardians/Tutors; Students/Children |
Behavioural Data | Data relating to your browsing activity or interaction with the Platform, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any products you viewed or purchased through the Platform. | Teachers/Staff; Parents/Guardians/Tutors; Students/Children |
Technical Data | IP address; browser type and operating system; geolocation to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device. | Teachers/Staff; Parents/Guardians/Tutors; Students/Children |
Marketing and Communications Data | Marketing preferences; service communication preferences. | Teachers/Staff; Parents/Guardians/Tutors |
Please note that we receive and process data about ethnicity if you have consented. 21C relies on the relevant educational establishment and/or the parents and guardians or tutors to secure that consent. Consent can be withdrawn at any time by notifying us.
Otherwise, we will not process any special (or sensitive) categories of personal data (relating to race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sex life, sexual orientation) or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
HOW WE COLLECT AND RECEIVE PERSONAL DATA
We collect and receive personal data using different methods:
Method of Collection | Description | Applies to |
Personal data you provide to us | You may give us your personal data directly, for example, when you register or purchase on our Platform, contact us with enquiries, complete forms on our Platform, subscribe to receive our marketing communications, or provide feedback to us. | Teachers/Staff; Parents/Guardians/Tutors |
Personal data others provide to us about you | Other people or organisations may give us your personal data directly; for example, when they register you on our Platform, contact us with enquiries, or complete forms on our Platform. | Students/Children; Parents/Guardians; Teachers/Staff (if you access through an organisation’s account) |
Personal data we collect using cookies and other similar technologies | When you access and use our Platform, we will collect certain Behavioural Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the “Insight, analysis and retargeting through Cookies” section below). | Teachers/Staff; Parents/Guardians/Tutors; Students/Children |
Personal data received from third parties | We may receive personal data about you from third parties. Such third parties may include analytics providers, data brokers, third-party directories, and third parties that provide technical services to us so that we can provide our Platform and our Services. | Teachers/Staff; Parents/Guardians/Tutors |
Publicly available personal data | From time to time, we may collect personal data about you (Identity Data, Contact Data, or Profile Data) that is contained in publicly available sources (including open-source data sets or media reports) or that you or a third party may otherwise make publicly available (for example, through speeches at events or publishing articles or other news stories or posts on social media platforms). | Teachers/Staff; Tutors |
HOW WE USE YOUR PERSONAL DATA
We use personal data for the purposes set out in this section. This use by us will depend on whether we are using your Personal Data only under the instruction of your educational establishment (we act as their Data Processor) – usually relating to teachers and students (and sometimes parents/guardians); or whether you have signed up and subscribed directly (therefore we are the Data Controller) – usually parents/guardians and their children, or tutors.
Purpose of Use | Description | Types of Data Used |
When an account is created on our Platform | You will be required to have or be associated with an account to use the Platform. We will use your identity/contact/registration, etc. data to set up your account or associate you with your educational establishment/school’s or parent/guardian’s or tutor’s account. Once the account is set up/associated for you, we will process your data to identify you when you log in to the account and access secure areas of our Platform. We will also process the data so that we can administer the account and contact you about the account. We will also collect and process behavioural/technical data when you use certain features and functionality on our Platform. This data helps us understand how you use our Platform so that we can improve it. | Identity Data, Contact Data, Registration Data, Profile Data, Behavioural Data, Technical Data |
If you purchase Services or other items via our Platform | We collect and maintain personal data that you submit to us for the purpose of supplying Services or other items that you have requested via our Platform. We process this information so that we can fulfil the supply of Services, process any returns, maintain our user databases, and keep a record of how our Services are being used. | Identity Data, Contact Data, Registration Data, Profile Data, Financial Data, Transaction Data |
When you browse our Platform/website | When you browse our Platform, we collect and process personal data to help us understand how you are using and navigating our Platform. We do this so that we can better understand which parts of our Platform are more or less popular and improve the structure and navigation of our Platform. | Behavioural Data; Technical Data |
If you use any interactive/chat/messaging features on our Platform | We will collect and use personal data about you when you use certain features on our Platform. For example, depending on the nature of your interaction, we may process your personal data when you use the Enquiry Form or Chat function to get in touch with us. | Identity Data, Contact Data, Registration Data, Profile Data, Behavioural Data, Technical Data |
If you contribute to our Platform or post content or comments on our Platform | If you submit any content to us, including via our Platform, we may process any personal data comprised within that content for the purposes of making available the Services via our Platform. | Identity Data; Contact Data |
If you log in with or otherwise link to social media sites and interact with our social media pages | If you log in with or click on one of the social media links on our Platform or otherwise interact with our social media pages such as on LinkedIn or Twitter (including interacting with any ‘like’ or similar embedded features on our Platform or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the “Insight, analysis and retargeting through Cookies” section below. The relevant social media platform may also be a controller with respect to the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details on how the relevant social media platform uses your personal data, please see their privacy policies. | Behavioural Data; Technical Data |
If you have a general question or need help with any issue concerning our Services | If you make an enquiry or have a technical issue, we will collect and process your personal data that is relevant to your enquiry and help us diagnose the technical issues you are experiencing. | Identity Data, Contact Data, Profile Data, Transaction Data, Behavioural Data, Technical Data |