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Learning By Questions Privacy Notice

Learning by Questions Ltd (hereafter also referred to as 'The Company' and or 'we', 'us', 'our') provides the content and features of lbq.org (hereafter also referred to as 'the site') for the purpose of enhancing teaching and learning in a classroom setting.

The site allows teachers to: create work for, and monitor the work of, pupils, inform planning and teaching strategies and provide automatic marking and support to pupils. The site is available to users (hereafter also referred to as 'user(s)', 'you', 'your') who are either, members of a School Account or Individuals who register to take advantage of a time limited experience of the site on a Trial basis. Access to the site is at all times at the sole discretion of the Company.

For the purposes of this document the terms 'pupil' and 'student' are used interchangeably and describe any person, irrespective of age, who is presented with the opportunity to connect, by any supported method, to the site to receive and answer questions initiated by a user of the site.

For the purposes of this document the term 'School' describes any corporate entity (generally but not exclusively schools and education trusts) eligible to take out a subscription to the site. Subscriptions are not available to individuals.

We place a high priority on safeguarding the privacy of users of the site. This Privacy Notice is intended to help you understand what information, including personal information, we collect, how it is processed when you use the site and how it will be processed by The Company to meet our objectives of delivering a beneficial experience to teachers and learners.

Our aim is to collect the minimum of personal information required to make your use of the site beneficial, enjoyable and easy, whilst still permitting the Company to meet its objectives and fulfil our contractual obligations.

Learning by Questions Ltd reserves the right to modify this Privacy Notice at any time without giving you prior notice. Following any such changes, we will notify you and offer you the opportunity to review and accept the changes.

1 Information we collect about you

The information we collect varies with how you use the site and whether you're a visitor, an individual user registered for a time limited Trial, or a member of a School Account. To benefit from the time limited Trial you will have to register for an account with the site. As a member of a School Account your account may have been created by you and added to a school account or may be created for you by your school. Please review the parts of section 1 relevant to your use of the site.

1.1 Data collection information for visitors 
1.2
 Data collection information for individuals using the site on a time limited Trial basis 
1.3 Data collection information for users of the site who are members of a School Account.

1.1 Data collection information for visitors

When you visit the site and you are not logged in then we will not collect any personal data about you. We do however collect anonymous data to record what pages are visited, in what order and how long for. We will also record part of your IP address to help give us some idea about which part of the world you are browsing from.

To collect this information we use the Google Analytics tools to capture and analyse this data. The analysis we perform is on aggregated data and is only able to show broad trends in the use of the site. Non-aggregate data is deleted after 14 months.

The site is configured to respect 'Do not track' requests issued by your browser. Search online or in your browser's help to learn more about 'Do not track' settings.

1.2 Data collection information for individuals using the site on a Time Limited Trial basis

By accepting the terms of this Privacy Notice you are giving your consent for Learning By Questions Ltd to collect and process your data as outlined below (1.2.1 & 1.2.2), your consent and our legitimate interest is our lawful basis for that processing. Your account is strictly for your use and must not be shared with anyone else.

Users taking advantage of the Time Limited Trial may not use the site to make any lasting record of data that might be regarded as personally identifying another individual. To facilitate a fair assessment of the potential of the site, the system will make and display (to you) a temporary record of pupil names given by your pupils while they are directly engaged in completing a task you have set for them via the site. These temporary records will automatically expire after 2 hours or, if sooner, when you end a task. On expiry, pupil name data will be automatically and irretrievably anonymised.

Learning by Questions Ltd assumes that prior to using the site to create temporary records of pupil names, you have secured all the necessary consents from your school and that your school is fully conversant with your activities. If it becomes known to the company that your use of the site is not in accordance with this clause the Company reserves the right to suspend or remove your access to the site.

1.2.1 I'd like to register and create an account on the site

To create your account with the site, we collect your title, first name, surname, email address, date & time of your application and the password you create. Pseudonyms may be used in place of forenames and surnames, however for us to process your registration you must submit a valid email address. Your password will be hashed within our system using the industry leading bcrypt hashing function.

1.2.2 I've registered with the site for the Time Limited Trial and I'm currently logged in

When you login to the site we record the date & time of your login. We will also record key aspects of your use of the site, without recording and processing this data we cannot deliver our services. Therefore we will make a record in our database of:

  • Date/time and identity of any question-set you set as a task for your students
  • Anonymised names* and responses given by students during a task you have set
  • Any adaptations you make to a question set
  • Date and identity of any question set you place in your 'planning calendar'
  • Identity of any question set you place in your 'favourites'
  • Any data, including but not limited to: text relating to questions, answers, feedback, titles or images, you submit to the site when authoring your own questions and question sets (See 1.6 for full explanation and additional terms relating to user authored content)

Some key features of the site make it necessary for us to temporarily record data on your computer/device in the form of cookies See Section 1.7 for a full description of the way we use cookies and other modes of temporary data storage.

1.3 Data collection information for users of the site who are members of a School Account

For users of the site who are members of a School Account our lawful basis for processing your data is to fulfill the subscription contract between your school and the Company consent and our legitimate interest. Data collection on behalf of schools is further detailed in our data processing agreement with your school.

1.4 Cookies and temporary data storage used by Learning By Questions Ltd

Cookies are small files placed on your computer when you visit the site .We classify cookies into three types.

Session Cookies: are required to maintain access to your account after you have logged in to the site. If these cookies are not permitted you will not be able to log in correctly or access many features of the site. These cookies are removed when you log out of the site or close your browser.

Functional Cookies: are used to temporarily store information about your use of the site. For instance, cookies will remember the criteria you have used to search for an item of content so when you return to a search page your search criteria will be preserved. These cookies are removed when you log out of the site or close your browser.

Analytic Cookies: are third-party cookies and collect anonymous information about how visitors use our website. If you give your consent we will use the Google Analytics tools to capture and analyse this data. The analysis we perform is on aggregated data and is only able to show broad trends in the use of the site.

2. Who is collecting my information and who might it be shared with?

When you are on the site and are asked for personal information, you are sharing that information with Learning By Questions Ltd and its subsidiaries. Learning By Questions Ltd is a Private Limited Company. (Company #: 10240336)

For individuals who register for the Time Limited Trial, Learning By Questions Ltd. has the roles of both Data Controller* and Data Processor* with regard to the data shared with us.

For users who are part of a school account then the School has the role of Data Controller and the Company has the role of Data Processor and is processing your data in accordance with your school's instructions. In this case your data is shared by and controlled by your school.

* The ICO offers the following definitions of a Data Controller and Data Processor
  • 'A controller determines the purposes and means of processing personal data.'
  • 'A processor is responsible for processing personal data on behalf of a controller.'

For any user (school or individual) who gives consent for the Company to use their data for the purposes of marketing (and any other non transactional communications) then the Company has the roles of both Data Controller and Data Processor in respect of that processing.

Where consent is given for marketing communications the Company will additionally store your limited contact details (email address & name) with one or more third party providers for the purposes of fulfilling our marketing objectives. The Company is responsible for ensuring that any third party subcontractor or provider is fully compliant with Data Protection regulations. Learning by Questions Ltd may additionally process data we hold about your use of the site in order to ensure that any marketing communications are timely and relevant to you; for instance, primary teachers may not be interested in new resources we have produced for secondary pupils.

You may opt to stop receiving marketing communications at any time by: using an 'unsubscribe' feature in any marketing email we send, updating your consent within the site or, simply contacting us and making that request directly.

The Company reserves the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process initiated by or served on the Company.

We do not transfer your personal data outside the European Economic Area.

3. How Long Does Learning By Questions Ltd retain my data for?

As well as aiming to collect as little of your data as possible, Learning By Questions also aims to keep your data for the shortest time possible, and to give you as much control as we can over this.

For individual users who use the site on a Time Limited Trial basis we will retain your data for as long as we regard you as an active user, if you make no use of the site for a period of 14 months we will delete your account and any data associated with it. This would in no way prevent you from creating another account at a future date using, if you wish, the same personal details.

For users who are members of a School account, we will retain your data for a minimum period coinciding with the period of your subscription. Following the end of a subscription we will retain your data for as long as we regard you as an active user, if you make no use of the site for a period of 14 months we will delete your account and any data associated with it.

Records of our contracts and any transactions with schools will be retained for a minimum of 6 years to comply with legal / accounting requirements.

4. Your rights regarding personal information held about you by Learning By Questions Ltd

Where you are a member of a school account your school is the data controller and you should approach your school about exercising your rights. If you approach us directly we will in many circumstances refer the query to your school.

The law provides you with certain rights to access, erase or rectify your personal data. Our intention is to make as much of your data as possible accessible and editable via your account or your School Account however we recognise that this may not cover all data and may be impractical in some circumstances. You are therefore invited to make a direct request to exercise your rights.

Users also have a right to data portability, under this right we will provide a full transcript of data the company holds about you in a machine readable form (normally CSV or XML)

You can direct requests in relation to this privacy policy directly to Learning by Questions Ltd in writing (info@lbq.org) or verbally. Subject to satisfactory confirmation of your identity, we will act fulfil your request within 30 days.

Our /Individual-Rights-Policy details the individual rights of data subjects under data protection and privacy legislation (including GDPR).

5. What security precautions are in place to protect my information?

Our privacy policies, systems, practices and technology are all structured to ensure compliance with the GDPR and give assurance to all our users that we are handling their data in the most responsible way achievable.

Learning By Questions Ltd is registered with the ICO (ZA307554) and all data collected and stored by us is handled in compliance with the General Data Protection Regulations (GDPR). We apply a range of measures (see /Data-Security-Policy) to protect personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, should be regarded as 100% secure. Therefore, while we strive to use appropriate means to protect your personal information, we cannot guarantee its absolute security.

Your account information is protected by password, your password is stored in encrypted form and cannot be accessed by anyone. You should keep your password private at all times. You should also remember to log out of your account and close your browser window when you have finished using the site.

Learning By Questions Ltd cannot and does not ensure or warrant the security of any information collected by use, transmitted over the Internet, or maintained in your user account. You agree that any data transmission you make or receive through the Site is at your own risk.

Our /Data-Security-Policy details the practical, organisational and technical measures we take to protect data.

6. Your right to lodge a complaint

If after contacting us regarding data we hold about you, you are not satisfied with our response you have the right to lodge a complaint with the Information Commissioners Office (https://ico.org.uk/)

Learning by Questions Ltd's registration number with the ICO is (ZA307554)