Frog Education is registered with the ICO | Our registration number is Z706603X
Frog Education Ltd - Privacy Policy
1 Who we are
This website is operated by Frog Education Limited (Registered Number 3935677). If you have any concerns regarding your data and privacy you can contact us at dataoffice@frogeducation.com or by mail at 3rd Floor G Mill, Dean Clough, Halifax, West Yorkshire HX3 5AX.
References to the “Company”, “we”, “us”, “our” and “ours” in this privacy policy means Frog Education.
2 Purpose of this privacy policy
The privacy of your data is important. We are committed to the security, privacy and confidentiality of information provided by you or on your behalf to us or which is data that we assist you with through the provision of data processing and/or data storage services. This privacy policy describes our current policies and practices with regard to any personal information collected by us whether from you directly, through the website or, if you are a Parent, Guardian or Carer, provided to us by a School with which we work.
Personal information (or ‘personal data’) means any information which identifies you, and may include information such as your name, email address, telephone number and position.
3 How we manage Data Protection compliance
Having regard to our responsibilities to comply with the General Data Protection Regulation and other applicable laws, we have appointed the appropriate personnel to oversee and to assure compliance of our business with all data protection and e-privacy rules. You may contact dataoffice@frogeducation.com should you have any queries or require further information.
4 Notification of changes to our privacy policy
We are continually improving our methods of communication and adding new functionality and features to this website and to our existing services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data protection practices will change from time to time. If and when our data protection practices change, we will update this privacy policy to describe our new practices. We encourage you to check this page regularly. This policy was last updated on 20th March 2020.
We have updated this policy to recognise the responsibilities we will have under the General Data Protection Regulation and related UK data protection laws, and the Privacy Act 1988 (Cth) and related Australian Privacy Principles (‘Australian privacy law’).
5 The Information we collect
We only hold personal data which is directly relevant to our dealings with a given data subject and where any processing we may subsequently undertake of that data can be carried out by us lawfully – for example in pursuance of our legitimate interests as explained within this Policy or for purposes relating to the entering into of a contract with an organisation and the subsequent performance of that contract. That data will be held and processed in the way we describe within this Policy.
In particular, we may collect your:
- name and contact details;
- authentication details;
- academic information;
- employment details
You may have been directed to this Policy through a weblink we provided you with. We make individuals aware of our policy in relation to our holding and any processing of that person's data at the point of collection of the personal data concerned.
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, are seeking.
6 How we collect personal information
We may collect your personal information at the point you make an enquiry of Frog Education. This includes any telephone enquiry you may make and enquiries that we receive at trade fairs and in other marketing activities we conduct. We will only take your information on a basis that entitles us to thereafter hold and use that personal data with an express consent provided by you to us holding the data and for each purpose that we then intend to use that data.
We collect and hold personal information concerning users of our products and services where an enquiry or request for assistance has been made to us.
If you sign up for any training event or conference we also require personal information so that we can communicate with you about the event.
If you register as a participant in any forum that we provide we will hold your data for the purpose of administration of the forum. Any further data that you provide such as teaching materials, opinions and commentary will be retained and available to other registered users in accordance with the rules applicable to and displayed upon the relevant forum.
There may also be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you. For example, if you provide personal information to your school that is our customer, that school may provide us with your personal information (or the personal information of your child) to enable us to provide our services to that school. However, we rely on schools to let you know if they are providing your details to us.
7 Our use of your personal information
We collect and use your personal information for the purposes set out below.
For our marketing purposes
If you indicate now or at a future time that you consent to our doing so, we will maintain the personal information you provide us with so that we may:-
- contact you to inform you of new services and products we will be providing;
- send you requested information about our services or products; or
- contact you with updates in the further development of any products and/or services you have expressed interest in.
We consider that we may use your personal data in the course of pursuing our legitimate interests as a business engaged in and committed to the success of the education sector.
Our communications provided on the basis above will always have an opt-out option in respect of further communications.
If you are outside of the UK this means that we are likely to transfer your personal information outside your country.
For Purposes of entering into contracts and the management and administration of the contract
We will use the personal information we hold to note enquiries that may be raised in any way that is provided for under our contract with you. This includes use by users of our products or services of any helpline facility that we provide.
For the purpose of providing services as required by our contracts with schools and other customers.
We hold information about certain persons for purposes associated with the administration of contracts that we hold with schools and other customers of our business. We will hold that information for so long as we have a contract with the organisation concerned or until we are advised of any change in the person or persons we are to work with in the administration and management of the contract in which case details of the previous individual will be deleted immediately unless we are then provided with a consent by that person to continue to communicate in relation to our products and services.
We hold a record of individuals who call any helpline services that we provide (this will include circumstances where individual contacts us by another means but is referred to the helpdesk).
We will hold details of your Data Protection Officer or if you do not have one the individual you have identified as responsible for data protection matters.
We will also have access from time to time to personal and other data that a School that is our customer is the data controller of. This data will be provided by the School either directly or via a third party that is commonly referred to as a data extractor. Please refer to the privacy policy of any school that you may be interested in to understand how it expects us to operate with them as a data processor.
To administer events that we organise
We will use information provided at the point of registration for any event that we organise such as training workshops, seminars and events we organise at Trade Fairs to keep you advised of the event prior to it being held. We may also contact you afterwards to provide you with information about the day, offers and services and/or to encourage you to provide us with feedback relating to the event you have attended.
To administer Forums that we provide
Your personal data provided at registration and other data and materials that you subsequently upload to a forum are shared with other registered users of the forum in accordance with the rules of the relevant forum which are displayed prominently on the webpage related to the forum. We will process that data through publishing the same on forum pages and through creating backups for security purposes.
We remind users that the public forum and webinar areas can be accessed by all subscribers to our forums.
For the purpose of providing services as required by our contracts with schools and other customers.
‘Upon entering a licence agreement with Frog for the provision of one or more Frog products we also process certain data on behalf of our customers. Full details of this are covered in our Terms and Conditions and Data processing policies which can be found here.
8 How we may share your information
Many of our schools have a Frog server on their premises but we also provide hosting for some schools and some central data centre services accessed by your platform under subcontract.
8.1 Services hosted in the UK
In the UK these services are hosted and are provided under subcontract in the Manchester data centre run by Equinix whose registered address is at 8 Buckingham Avenue, Slough SL1 4AX, United Kingdom. (https://www.equinix.co.uk).
Equinix is tier-1 data centre; ISO 27001 certified, PCI-compliant and secured to UK government IL4 standards. The facilities made available by Equinix are provided through a sub-contract we hold with Exa Networks Limited. The privacy policy of Equinix may be viewed here https://www.equinix.co.uk/company/legal/privacy/
8.2 Services hosted in Australia
In Australia services are provided under sub-contract
For schools in Sydney, NSW within a data centre run by Equinix whose registered address is at 47 Bourke Road, Alexandria, Sydney. (https://www.equinix.com.au).
Equinix’ SY3 is an ISO 27001 certified, PCI-compliant and SOC 1 & 2 Type II standards. The facilities made available by Equinix are provided through a sub-contract we hold with Civica International.
The privacy policy of Equinix may be viewed here https://www.equinix.com.au/company/legal/privacy/.
For commercial organisations in Sydney, NSW within a data centre run by Nextdc whose registered address is at Level 6/100 Creek Street, Brisbane, Queensland 4001 (https://www.nextdc.com/) S1 Sydney has received Uptime Institute Tier III certification for design and construct as well as Tier III Gold Certification for Operational Sustainability, meaning S1 operates at the highest possible operational levels to ensure efficient and reliable performance 24/7. S1 Sydney is certified as a NABERS 5-Star rated data centre infrastructure facility, the only data centre in New South Wales to achieve a 5-Star rating for energy efficiency.
The privacy policy of Nextdec may be viewed here https://www.nextdc.com/privacy-policy.
9 How long do we hold your personal information?
If you make any enquiry of us that does not lead to our providing you with a proposal to provide any of our products and/or services, we shall delete the information we have or if we wish to retain information for the purposes of the further development of our products and services retain the information without any of the same constituting personal data immediately thereafter.
We hold information relating to individuals who are nominated by Schools and other customers as authorised to work with us in contract management and administration for so long as that authorisation is in place or until the contract with us with comes to an end if earlier. Information about customers out of contract shall be retained for a reasonable period afterwards whilst negotiation is still in place to try to renew the relationship. Failure to secure renewal shall lead to the data being anonymised or deleted entirely.
We shall process on behalf of a School data (including personal data) where we provide data service centres for so long as we are required to do so in our contract with that party and for a reasonable period of time afterwards for the purposes of renewal discussion.
If you register for or attend any event that we organise or participate in and we receive your personal information relating to that, we reserve the right to send you information to market products and services to you thereafter in which case your personal information will continue to be held as explained earlier in this Policy. In all other cases your information will be deleted by no later than 24 months after the event.
If you participate in a forum on our website, the Frog community or within our products, personal information will be shared with other users and held for so long as you remain a registered user. If you wish to deregister you will need to contact the data office using the address stated at the beginning of this document.
Where Australian privacy law applies, we will destroy or de-identify your personal information once we no longer need it for any purpose for which we use or disclose your personal information (as described in this Policy) and we are not otherwise required to retain it under Australian law, or an Australian court or tribunal order.
10 Unsubscribe
Where you have consented to contact being made by us with you for any of the purposes mentioned above but you no longer wish to receive emails from us or wish to change your selections as to how or what our contact with you should follow the ‘unsubscribe’ option contained within the email or by emailing us at the address given in section 1 with “Email Unsubscribe” in the subject heading. We will act upon this as soon as practicable, and if you are in Australia, within 5 business days.
You may also wish to write to us at the address given at the beginning of this Policy.
If you choose to unsubscribe from our mailing lists we will only make contact with you again in circumstances where you have consented to our being re-provided with your information and that contact is authorised by you, or if we need to contact you in relation to the products or services we provide to you.
11 Anonymous data collected through this website
In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our website. For example, our web server automatically logs which pages of our website our visitors view, their IP addresses and which web browsers they use. This technology does not personally identify you – it simply enables us to compile statistics about our visitors and their use of our website.
Our website contains hyperlinks to other pages on our website. We may use technology to track how often these links are used and which pages on our website our visitors choose to view. Again this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.
Having viewed our website, if you go on to place an official enquiry with us to request further information and provide us with your name and contact details it is possible that your IP address will be linked to the anonymous browsing of the pages to assist us in understanding what you are interested in. Upon request this data can be deleted, requests should be made to our data office as detailed in section 1 of this policy.
12 Cookies and similar technologies
In order to collect the anonymous data described in the preceding paragraph, we may use cookie technology on our website.
A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device. Cookies do not damage your computer.
You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through our website may not function properly if your cookies are disabled.
We use two types of cookies on our website:
Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser.
Performance cookies (e.g. Google Analytics)
These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to continually improve the site.
We may also use your IP address to help diagnose problems with our server, to administer our website and to improve the service we offer to you. An IP address is a numeric code that identifies your computer on a network, or in this case, the internet. Your IP address might also be used to gather broad demographic information.
We may perform IP lookups to determine which domain you are coming from (i.e. aol.com, yourcompany.com) to more accurately gauge our users’ demographics.
Information from these types of cookies and technologies or about website usage is not combined with information about you from any other source. None of the cookies or technologies that we use will personally identify you.
Consent
To comply with current legislation, we need to ask for your consent to set the performance cookies described above. When you arrive on our website a banner appears asking for your consent to place performance cookies on your device. By continuing to use our website or by clicking ‘OK’, we assume that you consent to cookies being placed on your device. If you do not agree please leave our website immediately. Once your consent has been provided, this message will not appear again when you revisit. If you, or another user of your computer, wish to withdraw your consent at any time, you can do so by altering your browser settings.
13 Security
We store your personal information in different ways, including in paper and in electronic form. The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from interference, misuse, loss, unauthorised access, modification or disclosure, including electronic and physical security measures.
You are entitled to make a request that we provide you with any personal information that we hold concerning you by making a Subject Access Request (SAR). If we do hold information about you we will:
- give you a description of it;
- tell you why we are holding it;
- tell you who it could be disclosed to; and
- let you have a copy of the information in an intelligible form,
in all circumstances save where you request multiple copies of the information requested.
Where Australian privacy law applies, we may decline a request for access to personal information in circumstances prescribed by that Act, and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).
We will also correct, amend or delete any personal information that you tell us is inaccurate and notify any third-party recipients of the necessary changes. You may update any information you have given to us by contacting us at our registered address or the email address given above.
We expect Schools, under their agreement with us to ensure that personal data they provide is updated as required so as to maintain its accuracy.
Where Australian privacy law applies and we refuse to correct your personal information, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
14 Disclosure of your personal information
We do not share, sell or distribute your personal information with unrelated third parties, except as otherwise provided for in this privacy policy and in circumstances in which you have expressly consented to the sharing and the purpose for which the sharing is to be undertaken.
We may share, transfer or disclose minimal information with approved 3rd party applications which your school subscribe to and wish to facilitate single sign on (SSO) from Frog products. You will always be asked to provide consent for this – either asking us to set up the SSO for you or by following links and instructions to 3rd party sites and completing relevant consent.
We may also share, transfer or disclose the information in our databases and server logs to comply with any legal requirements, or in the event of our flotation on a stock exchange, sale, merger, reorganisation, dissolution, disposal of all or part of our assets or similar event. We will inform you of any such transfer or disclosure if required by applicable law.
Where Australian privacy law applies, in addition, we may also disclose personal information about you for the purpose for which it is collected (as set out above).
15 Data access and corrections
Requests to delete personal information are subject to any applicable legal and ethical reporting or document retention obligations imposed on us by applicable law.
16 Links to other websites
Our website may contain hyperlinks to websites that are not operated by us. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures. We urge you to review any privacy policy posted on any site you visit before using the site or providing any personal information about yourself.
17 Transfer of data abroad
If you are visiting this website from a country other than the country in which our servers are located (currently United Kingdom), the various communications will necessarily result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to the processing and transfer of your personal information as set out in this privacy policy.
18 If you wish to complain
If you have any concerns about the way Frog Education handles your personal data please do contact us at dataoffice@frogeducation.com. We will take any concerns you have seriously. In the alternative you are entitled to contact the relevant privacy authority in your jurisdiction and we provide the contact details below:-
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United Kingdom https://ico.org.uk/concerns/ Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Tel: 0303 123 1113
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Australia http://www.oaic.gov.au/privacy/privacy-complaints Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW 2001 Ph: 1300 363 992 |
