Nessy Privacy Notice
This privacy notice describes the processing of personal data we undertake as a business, including the data processed by our cloud-based learning platform.
The following are our reasons for collecting your personal data, what we do with it and what your rights are under UK GDPR.
Who Are We?
We are Nessy Learning Limited, a company registered in England, registration number: 03845393, registered office address 10 Upper Belgrave Road, Bristol, United Kingdom, BS8 2XH.
You can contact us using the contact forms on our sites, or via the following email addresses:
• info@nessy.co.uk
• help@nessy.co.uk
We are registered as a Data Controller with the Information Commissioner’s Office (ICO – the UK’s regulator for data protection), registration number Z9268119.
Where we are processing personal data of teachers and pupils on behalf of a school or a tutor we do so as their data processor and you should contact them if you wish to know more about how and why they are processing your personal data, however, please see the Teachers & Pupils section below for information on our processor activities.
We have appointed a Data Protection Officer, who can be contacted at privacy@nessy.com
Purpose of Processing
We process your personal data for a variety of purposes as set out in the table below, which also shows our lawful bases under UK data protection legislation (UK GDPR) for doing so.
Where we are relying on our legitimate interests you are free to object to that at any time. In the case of direct marketing activities we will ensure that we cease to market our services to you should you object to our legitimate interests.
Where we are relying on your consent you are free to change your mind and withdraw your consent at any time.
Data We Collect
The table below gives information on the categories of personal data we process for each of the purposes shown above.
We use third party payment processors to manage payments (Stripe, Apple Pay, PayPal) we do not have access to payment card details.
Special Category Data
There are additional rules we must follow if we collect certain types of more sensitive data, known as Special Category Data. These include details of your ethnicity, beliefs, health and sexuality and in each case we must let you know what our additional lawful basis is for processing such data.
We do not routinely process any such special category data however, should we do so we will provide additional privacy information at that time.
How Long Do We Keep Your Data For?
Where we are relying on our legitimate interests to process your data then we will keep your personal data until you object to our legitimate interests and we agree with your objection, or until the following default periods have elapsed after our last contact with you.
We will retain your personal data by default for the following periods:
Do We Ever Share Personal Data?
We will share your data if we receive a legitimate request from a law enforcement agency.
When you submit your personal data online your data is shared with our partners who manage and host our websites.
If we are communicating with you via email or social media channels, we will be sharing your personal data with those email and social media providers.
We will share some information with our US-based sister company, Nessy Learning Inc.
We will share your details with our Swedish parent company, ILT Learning, who maintain and manage our centralised CRM system.
We also utilise external suppliers to provide several business support services. We always ensure that we have appropriate contracts in place to protect your rights when personal data are processed on our behalf by these third parties.
There is further information regarding these suppliers in the “Where Do We Process Data?” section.
How Do We Keep Your Data Secure?
We take sensible steps to keep your data secure and ensure we can uphold your rights and meet our obligations under UK GDPR:
• All data sent between your browser and our website are encrypted in transit.
• Access to personal data is role based: only those members of staff with a legitimate need will have access.
• Systems are password protected and multi-factor authentication is enabled where available.
• We ensure that appropriate contracts are in place with our suppliers who process your personal data to protect your rights, to ensure that they take appropriate security measures to safeguard your data and that any international transfers are done correctly under UK GDPR.
• Our employees are all subject to an obligation of confidentiality and receive training on data protection matters.
• We utilise appropriate technical and organisational measures to optimise the security of your personal data.
• We hold Cyber Essentials Certification.
Your Rights
You have a number of rights relating to the processing of your data, if you would like to use them or have any questions then please contact us.
We won’t charge you for doing any of the following, however, we may make a charge in the case of frequent repeat or unfounded requests.
Awareness: You have the right to be fully informed about why and how we process your information. This privacy notice is intended to meet that requirement, but please do contact us if you have any questions. If we obtain your personal data from a third party (e.g. a social media platform or recruitment platform) then we will tell you where we have obtained your information from.
Access: You have the right to a copy of the data we hold about you.
Rectification: If you think some of the data we hold is wrong then you have the right to ask us to correct it.
Erasure: You have the right to ask us to delete the data we hold about you. Where we are holding the data to fulfil a contract with you or your organisation then we will need to retain the data in accordance with the data retention requirements shown above.
Restriction: You have the right to ask us to restrict the processing of personal data whilst we check its accuracy, if you think the processing is unlawful, if you believe we no longer need to process the data but you need us to store it due to pending legal claims, or when you object to our processing based upon our legitimate interests and we are assessing the validity of that.
Object: Where we are processing your personal data based upon our legitimate interests you have the right to object to that. If your objection is valid (for instance in the case of any direct marketing activity) then we will stop processing your personal data for that purpose.
Data portability: You can request a copy of your data in a digital format which you can then supply to another provider when we are processing your personal data under the lawful basis of performing a contract with you or because we have your consent.
Automated decisions and profiling: You have the right, in certain circumstances, not to be subject to decisions based on automated processing (including profiling) if it has a significant or legal impact on you. This doesn’t apply if the processing is necessary to fulfil a contract with you, or if you have given us your consent to do so. We do not currently use any technology to make automated decisions about you.
How Do We Use Cookies On Our Website?
We utilise cookies on our website. Some are required for our site to work, these are known as essential cookies, and we also use others for analytics and marketing purposes.
We will ask for your consent to use any cookies which aren’t essential, and we won’t deploy any non-essential cookies without your consent. You should be aware that whilst we use non-essential cookies to help us understand how our website is performing, the author of the cookies (e.g. Google) may use the data obtained for their own purposes.
These are the non-essential cookies we use:
What Happens When I Follow Links to Other Sites?
If you follow a link from our site to another site then you should read the privacy notice on the other site prior to providing your data to them. We are not responsible for the cookies installed upon your device by other websites.
Where Do We Process Data?
Nessy partners with the following organisations, some of whom act as our processors (hosting and email providers) and some are independent controllers (e.g. payment providers, our parent and sister companies etc). Some of our processors are also sub-processors who are helping us provide our service to customers.
We may share your personal data with professional advisors from time to time, such as our accountants or legal advisors. We will always ensure that appropriate protections to your rights and freedoms are in place.
Teachers and Pupils
This section describes the data processed within our packages where we are acting as a Data Processor on behalf of another organisation such as a school or tutoring business.
We apply default retention periods in some packages, however the Data Controller can manually delete any of these data at any time or contact us and ask us to do this for them.
Important note for parents buying their own subscription: If you are buying our packages for your own family use then we will be acting as the Data Controller for the above data categories and our lawful basis for doing so is that it is necessary to perform the contract we have with you.
Making a complaint
Please contact us at the above address. You can also contact the Information Commissioner’s Office (ICO) on their helpline at 0303 123 1113 or online at www.ico.org.uk.
If you should contact the ICO they will normally ask you to contact us first.