Protection and privacy of personal information is the foundation for the design of the Vocab Express websites (www.vocabexpress.com and www.vocabexpress.co.uk) ("the Site"), its database and its security policies. The websites are operated by Toptrack Learning Ltd (“We” or “Us”).
This policy (together with our Website Usage Policy and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is Toptrack Learning Ltd, registered with the Information Commissioner's Office (ICO), under registration number Z1705575. We are incorporated in England and Wales under company number 06828680 and have our registered office at Sowton Business Centre, Capital Court, Bittern Road, Exeter EX2 7FW, United Kingdom. Our nominated representative for the purpose of the Act is Justin Sycamore.
1. Information we may collect from you
We may collect and process the following data about you:
- If you contact us, we may keep a record of that correspondence.
- Educational Centres - if you are a teacher or are registering on behalf of an educational centre, we ask you to provide us with personal details such as your name, position and your email address. We will use this information for the purposes of administration, operation of the service, marketing, sales and business development. In addition we require details of the students who will access the service at your centre which is detailed in clause 2 below.
- Individual Users – if you register with us independently of an educational institution, we ask you to provide us with personal details such as your name, your email address, your password, your password question, your password answer, your date of birth, your native language(s), your line of business where applicable and your interests.
We keep records of the tests that you and your students have completed and the points obtained. We aggregate points scored by users for the purpose of our internal statistical analysis and research.
We will not sell or disclose your personal information to anyone else without your permission.
We may use your e-mail address to send you the Vocab Express newsletter, which will keep you informed of changes and improvements to the website. The newsletter may contain promotional offers, although we shall not send these to you if you are a student of an educational centre subscribing to the service. Any such communications will be sent to you by e-mail not more than once a week. At any time, you can opt out of receiving the newsletter by emailing us using the Contact page on the website.
We collect statistical information in order to monitor website usage. This helps us to develop our website and the service. We may provide statistical information to third parties. This information will not identify you personally.
2. Student Data
We require educational institutions to send us or upload certain student data. Data stored for each student is as follows: name, username, password, date of birth, school admission number, sex, registration group, year group, Unique Student Identifier (USI), and classes. The USI is an internal identifier to enable us to tracking students as they move between educational institutions. Admission numbers are used to track students whose details may have changed since the previous year. Additionally, a record of all vocab tests completed and points scored awarded is stored for each student.
Any information relating to its students who have access to the Service and which is held by us is only used to facilitate individual progress tracking. We will not use student data for any commercial purpose and do not store any student contact details such as email or postal addresses. Students are not asked for additional details after they login, however they have the option to change their password.
Students can view their own usage data and points score. Members of staff can view usage data and points score for students in their centre. While details of specific centres or students are never released without permission, we may aggregate usage data and points for statistical analysis and research, which may be published and used to provide comparative data to other schools and bodies interested in education. All such data will be provided in such a way that individual students cannot be identified from the data itself.
Initially, student data may be uploaded in bulk into the platform and then modified either by the school directly or upon request by us on behalf of the school. Student data is only stored while there is a formal agreement between us, either as a subscriber to the Vocab Express service or during a formal evaluation of the service.
It is the responsibility of the educational centre to ensure that they have the appropriate parent or guardian permission to pass on student data. Most centres’ policies – of which parents and guardians are usually advised when initially providing their children’s details to the centre – state that the centre may provide student personal details to suppliers of goods and services for the purposes of administration of education and training. In this instance, no further permission is required from parents/guardians to provide us with the student data. We will never pass on any student data to any third parties from which an individual student’s identity may be ascertained, without your prior written consent.
3. IP addresses and cookies
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and activity monitoring purposes.
We may use a cookie file to store information. Cookies are small files which are stored on your computer and are used to improve our site and to deliver a better and more personalised service. They enable us to store information about your preferences, and so allow us to customise our site according to your individual interests.
4. Where we store personal data
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
5. Disclosure of your information
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Toptrack Learning Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it will be one of the transferred assets.
- If we are under a duty to disclose you personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Usage Policy or Subscriber Terms Of Service.
6. Your rights
You have the right to ask us not to process your personal data for marketing purposes. You can exercise the right at any time by contacting us via the Contact page on the Site.
Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7. Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
Version: VEPP04 25th June 2010