Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of

our website visitors and service users; in other words, where we determine the purposes and means of

the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the

provision of our website and services, we will ask you to consent to our use of cookies when you first

visit our website.

1.4 In this policy, “we”, “us” and “our” refer to PE Planning Limited. For more information about

us, see Section 11.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific

categories of that data;

(d) the legal bases of the processing.

2.2 We may process data about your use of our website and services (“usage data“). The usage data

may include your IP address, geographical location, browser type and version, operating system,

referral source, length of visit, page views and website navigation paths, as well as information about

the timing, frequency and pattern of your service use. The source of the usage data is our analytics

tracking system. This usage data may be processed for the purposes of analyzing the use of the

website and services. The legal basis for this processing is our legitimate interests, namely

monitoring and improving our website and services.

2.3 We may process your account data (“account data“). The account data may include your name

and email address. The source of the account data is you or your employer. The account data may be

processed for the purposes of operating our website, providing our services, ensuring the security of

our website and services, maintaining back-ups of our databases and communicating with you. The

legal basis for this processing is our legitimate interests, namely the proper administration of our

website and business.

2.4 We may process your information included in your personal profile on our website (“profile

data“). The profile data may include your name, email address, school name, and year group. The

profile data may be processed for the purposes of enabling and monitoring your use of our website

and services. The legal basis for this processing is our legitimate interests, namely the proper

administration of our website and business.

2.5 We may process your personal data that are provided in the course of the use of our services

(“service data“). The service data may include your job title or role and the age range of children

you work with. The source of the service data is you or your employer. The service data may be

processed for the purposes of operating our website, providing our services, ensuring the security of

our website and services, maintaining back-ups of our databases and communicating with you. The

legal basis for this processing is our legitimate interests, namely the proper administration of our

website and business.

2.6 We may process information that you post for publication on our website or through our

services (“publication data“). The publication data may be processed for the purposes of enabling

such publication and administering our website and services. The legal basis for this processing is our

legitimate interests, namely the proper administration of our website and business.

2.7 We may process information contained in any enquiry you submit to us regarding goods and/or

services (“enquiry data“). The enquiry data may be processed for the purposes of offering,

marketing and selling relevant goods and/or services to you. The legal basis for this processing is

providing information to you as requested by you.

2.8 We may process information relating to our customer relationships, including customer contact

information (“customer relationship data“). The customer relationship data may include your

name, your employer, your job title or role, your contact details, and information contained in

communications between us and you or your employer. The source of the customer relationship data

is you or your employer. The customer relationship data may be processed for the purposes of

managing our relationships with customers, communicating with customers, keeping records of those

communications and promoting our products and services to customers. The legal basis for this

processing is our legitimate interests, namely the proper management of our customer relationships.

2.9 We may process information relating to transactions, including purchases of goods and services,

that you enter into with us and/or through our website (“transaction data“). The transaction data

may include your contact details, your card details and the transaction details. The transaction data

may be processed for the purpose of supplying the purchased goods and services and keeping proper

records of those transactions. The legal basis for this processing is the performance of a contract

between you and us and/or taking steps, at your request, to enter into such a contract and our

legitimate interests, namely the proper administration of our website and business.

2.10 We may process information that you provide to us for the purpose of subscribing to our email

notifications and/or newsletters (“notification data“). The notification data may be processed for the

purposes of sending you the relevant notifications and/or newsletters. The legal basis for this

processing is consent.

2.11 We may process information contained in or relating to any communication that you send to us

(“correspondence data“). The correspondence data may include the communication content and

metadata associated with the communication. Our website will generate the metadata associated with

communications made using the website contact forms. The correspondence data may be processed

for the purposes of communicating with you and record-keeping. The legal basis for this processing

is our legitimate interests, namely the proper administration of our website and business and

communications with users.

2.12 We may process any of your personal data identified in this policy where necessary for the

establishment, exercise or defense of legal claims, whether in court proceedings or in an

administrative or out-of-court procedure. The legal basis for this processing is our legitimate

interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights

of others.

2.13 We may process any of your personal data identified in this policy where necessary for the

purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional

advice. The legal basis for this processing is our legitimate interests, namely the proper protection of

our business against risks.

2.14 In addition to the specific purposes for which we may process your personal data set out in this

Section 2, we may also process any of your personal data where such processing is necessary for

compliance with a legal obligation to which we are subject, or in order to protect your vital interests

or the vital interests of another natural person.

2.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our

subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary

for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as

reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing

risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether

in court proceedings or in an administrative or out-of-court procedure.

3.3 We may disclose your account details to our suppliers or subcontractors insofar as reasonably

necessary for the proper administration of our website and business.

3.4 Financial transactions relating to our website and services may be handled by our payment

services providers. We will share transaction data with our payment services providers only to the

extent necessary for the purposes of processing your payments, refunding such payments and dealing

with complaints and queries relating to such payments and refunds. You can request information

about the payment services providers’ privacy policies and practices by contacting us. See Section 11

for contact information.

3.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose

your personal data where such disclosure is necessary for compliance with a legal obligation to which

we are subject, or in order to protect your vital interests or the vital interests of another natural

person. We may also disclose your personal data where such disclosure is necessary for the

establishment, exercise or defense of legal claims, whether in court proceedings or in an

administrative or out-of-court procedure.

4. Retaining and deleting personal data

4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help

ensure that we comply with our legal obligations in relation to the retention and deletion of personal

data.

4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is

necessary for that purpose or those purposes.

4.3 We will retain your personal data as follows:

(a) The information provided to us by you or your employer will be retained for a minimum period

of 1 year following the expiry of your subscription, and for a maximum period of 3 years following

the expiry of your subscription.

4.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where

such retention is necessary for compliance with a legal obligation to which we are subject, or in order

to protect your vital interests or the vital interests of another natural person.

5. Amendments

5.1 We may update this policy from time to time by publishing a new version on our website.

5.2 You should check this page occasionally to ensure you are happy with any changes to this

policy.

5.3 We may notify you of significant changes to this policy by email or through the private

messaging system on our website.

6. Your rights

6.1 In this Section 6, we have summarized the rights that you have under data protection law. Some

of the rights are complex, and not all of the details have been included in our summaries.

Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full

explanation of these rights.

6.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

6.3 You have the right to confirmation as to whether or not we process your personal data and,

where we do, access to the personal data, together with certain additional information. That additional

information includes details of the purposes of the processing, the categories of personal data

concerned and the recipients of the personal data. Providing the rights and freedoms of others are not

affected, we will supply to you a copy of your personal data. The first copy will be provided free of

charge, but additional copies may be subject to a reasonable fee. You can access your personal data

when logged into our website.

6.4 You have the right to have any inaccurate personal data about you rectified and, taking into

account the purposes of the processing, to have any incomplete personal data about you completed.

6.5 In some circumstances you have the right to the erasure of your personal data without undue

delay. Those circumstances include: the personal data are no longer necessary in relation to the

purposes for which they were collected or otherwise processed; you withdraw consent to consent-

based processing; you object to the processing under certain rules of applicable data protection law;

the processing is for direct marketing purposes; and the personal data have been unlawfully

processed. However, there are exclusions of the right to erasure. The general exclusions include

where processing is necessary: for exercising the right of freedom of expression and information; for

compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

6.6 In some circumstances you have the right to restrict the processing of your personal data. Those

circumstances are: you contest the accuracy of the personal data; processing is unlawful but you

oppose erasure; we no longer need the personal data for the purposes of our processing, but you

require personal data for the establishment, exercise or defense of legal claims; and you have

objected to processing, pending the verification of that objection. Where processing has been

restricted on this basis, we may continue to store your personal data. However, we will only

otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for

the protection of the rights of another natural or legal person; or for reasons of important public

interest.

6.7 You have the right to object to our processing of your personal data on grounds relating to your

particular situation, but only to the extent that the legal basis for the processing is that the processing

is necessary for: the performance of a task carried out in the public interest or in the exercise of any

official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third

party. If you make such an objection, we will cease to process the personal information unless we can

demonstrate compelling legitimate grounds for the processing which override your interests, rights

and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

6.8 You have the right to object to our processing of your personal data for direct marketing

purposes (including profiling for direct marketing purposes). If you make such an objection, we will

cease to process your personal data for this purpose.

6.9 You have the right to object to our processing of your personal data for scientific or historical

research purposes or statistical purposes on grounds relating to your particular situation, unless the

processing is necessary for the performance of a task carried out for reasons of public interest.

6.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in

order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal

data from us in a structured, commonly used and machine-readable format. However, this right does

not apply where it would adversely affect the rights and freedoms of others.

6.11 If you consider that our processing of your personal information infringes data protection laws,

you have a legal right to lodge a complaint with a supervisory authority responsible for data

protection. You may do so in the state of your habitual residence, your place of work or the place of

the alleged infringement.

6.12 To the extent that the legal basis for our processing of your personal information is consent,

you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of

processing before the withdrawal.

6.13 You may exercise any of your rights in relation to your personal data by written notice to us, in

addition to the other methods specified in this Section 6.

7. About cookies

7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web

server to a web browser and is stored by the browser. The identifier is then sent back to the server

each time the browser requests a page from the server.

7.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be

stored by a web browser and will remain valid until its set expiry date, unless deleted by the user

before the expiry date; a session cookie, on the other hand, will expire at the end of the user session,

when the web browser is closed.

7.3 Cookies do not typically contain any information that personally identifies a user, but personal

information that we store about you may be linked to the information stored in and obtained from

cookies.

8. Cookies that we use

8.1 We use cookies for the following purposes:

(a) authentication – we may use cookies to identify you when you visit our website and as you

navigate our website;

(b) status – we may use cookies to help us to determine if you are logged into our website;

personalize the website for you;

(d) security – we may use cookies as an element of the security measures used to protect user

accounts, including preventing fraudulent use of login credentials, and to protect our website and

services generally;

(e) advertising – we may use cookies to help us to display advertisements that will be relevant to

you;

(f) analysis – we may use cookies to help us to analyze the use and performance of our website and

services; and

(g) cookie consent – we may use cookies to store your preferences in relation to the use of cookies

more generally.

9. Cookies used by our service providers

9.1 Our service providers may use cookies and those cookies may be stored on your computer when

you visit our website.

9.2 We may use Google Analytics to analyze the use of our website. Google Analytics gathers

information about website use by means of cookies. The information gathered relating to our website

is used to create reports about the use of our website. Google’s privacy policy is available at:

https://www.google.com/policies/privacy/.

9.3 We may publish Google AdSense interest-based advertisements on our website. These are

tailored by Google to reflect your interests. To determine your interests, Google will track your

behavior on our website and on other websites across the web using cookies. You can view, delete or

add interest categories associated with your browser by visiting: https://adssettings.google.com. You

can also opt out of the AdSense partner network cookie using those settings or using the Network

Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org.

However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your

browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a

particular browser, you may wish to consider using the Google browser plug-ins available at:

https://support.google.com/ads/answer/7395996.

10. Managing cookies

10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for

doing so vary from browser to browser, and from version to version. You can however obtain up-to-

date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-

cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

10.2 Blocking all cookies will have a negative impact upon the usability of many websites.

10.3 If you block cookies, you may not be able to use all the features on our website.

11. Our details

11.1 This website is owned and operated by PE Planning Limited.

11.2 You can contact us:

(a) by using our website contact form;

(b) by telephone, on the contact number published on our website from time to time; or