Introduction and contents:
Our values guide everything that we do – including how we use personal data. We are strongly committed to keeping your and/or your children’s personal data safe. This commitment exists throughout the lifecycle of your personal data, from the design of any Roaming Schoolhouse service which uses personal data to the deletion of that data.
We think carefully about our use of personal data, and below you can find the details of what we do to protect your and your children’s privacy. This policy covers, amongst other topics:
- Information about your rights, the choices available to you, and our obligations in the European Union;
- Transparency about how we collect and use your personal data, including whether it is shared;
- Information on how we protect your personal data;
- Information on how we will facilitate your rights and respond to your questions.
Personal data is any information about you and/or your children by which you can be identified or be identifiable. This can include information such as:
- your name, email address, postal address, phone number, mobile number and nationality in addition to your child’s name, date of birth, English level, educational experience, other English activities, School type and name;
- information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based);
- information relating to how you use and interact with our sites.
When we refer to “personal data” in this policy, we are also referencing “personal information,” as it is defined under California law, which you can read more about here, and as it is defined under Australian law, which you can read about here.
Who we are and how to contact us:
Schwa SARL is the data controller in respect of your personal data. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us directly, you can find our contact details in the “How to contact us” section below.
The types of personal data we collect about you:
We collect your personal data when you visit our website or subscribe to our newsletter. We will only collect your personal data in line with applicable laws. We collect your personal data in various ways:
- directly from you, when you sign up for our services or newsletter and when you browse our site;
- personal data we generate about you, e.g. personal data we use to authenticate you, or personal data in the form of your IP address or your preferences.
More detail about these three categories of personal data are provided below.
The personal data we collect when you register for a Roaming Schoolhouse account
When you register for an account on roamingschoolhouse.com, we collect:
- your name;
- your email address;
- your postal address;
- your phone numbers;
- your nationality;
- your child’s name;
- your child’s date of birth;
- your child’s English level;
- your child’s educational experience;
- your child’s other English activities;
- your child’s school type and name;
- your child’s photograph, if you add one to your profile page.
You can change or remove these details using the profile and settings area of your Roaming Schoolhouse account.
Personal data we generate about you:
When you register for a Roaming Schoolhouse account, we assign you a unique ID number that we use to recognise you when you are signed in to our services. This will recognise you if you sign in using the same account on a new device or through a different application such as the Roaming Schoolhouse app on mobile devices (if we ever invent one!)
- your IP address - a numerical code to identify your device, together with the country, region or city where you are based;
- your geolocation data - your IP address can be used to find information about the latitude, longitude, altitude of your device, its direction of travel, your GPS data and data about connection with local Wi-Fi equipment;
- information on how you interact with our services;
- your browsing history of the content you have visited on our site, including how you were referred to our site via other websites;
- details of your computer, mobile, TV, tablet or other devices, for example, the unique device ID, unique vendor or advertising ID and browsers used to access our content.
We will not collect special categories of data from you - such as personal data concerning your race, political opinions, religion, health or sexual orientation - unless you have chosen to provide that type of personal data to us.
Personal data when you post comments about the Roaming Schoolhouse on other social media sites:
If you have mentioned the Roaming Schoolhouse in posts on social media sites, then we may collect your social media handles. For example, when you mention the Roaming Schoolhouse in a tweet, we may collect your Twitter handle.
How we collect personal data:
We collect personal data when you:
- register for an account on roamingschoolhouse.com;
- subscribe to the Roaming Schoolhouse newsletter;
- access and interact our site;
- through cookies and other similar technology;
- when you contact us via email, social media, or similar technologies or when you mention us on social media.
How we use your personal data:
We use personal data collected through our sites and apps only when we have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which we have collected your personal data.
Legal grounds for using your personal data:
The legal ground may be one of the following:
- Consent: For example, where you have provided your consent to receive newsletters from us. You can withdraw your consent at any time. In the case of newsletters you can withdraw your consent by clicking on the “unsubscribe” link at the bottom of the newsletter.
- Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
- Our legitimate interests: Where it is necessary for us to understand our parents and be able to communicate with you. Examples of when we rely on our legitimate interests to use your personal data include: homework, cancellations, requirements for class etc
- when we analyse what content has been viewed on our site, so that we can understand how they are used and improve our content;
- for internal administrative purposes related to when you use our services - such as our accounting and records - and to make you aware of any changes to our services;
- to collect and log IP addresses to improve the website and monitor website usage;
- to personalise our services (for example, so you can sign in) by remembering your settings, and recognising you when you sign in on different devices;
- enabling you to share our content with others using social media or email;
- when responding to your queries and to resolve complaints;
Updating your personal data and your profile page on our site:
When you register for an account with roamingschoolhouse.com, you have access to a profile page. Under “edit profile” you can review and update what personal data is stored to ensure that we have the latest contact details for emergency purposes.
Using children’s personal data:
We do not share any of your data, or your children’s data, with third parties.
Security of your personal data:
We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our site. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending any information, including personal data, via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.
Do we share or sell your personal data ?
No. Absolutely not!
How long we keep your personal data:
How we may contact you:
From time to time we may send you service emails, for example, telling you registration is open for next year.
If we have your permission, we may send you materials we think may interest you, such as new Roaming Schoolhouse offers and updates. This will be by email.
You can decide not to receive these newsletters at any time and will be able to “unsubscribe” directly by clicking a link in the email.
Responding to your queries or complaints:
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
Cookies and similar technologies:
When you visit our site, we may collect personal data from you automatically using cookies or similar technologies. A cookie is a small file that can be placed on your device that allows us to recognise and remember you.
Your privacy and data protection rights with regard to the personal data that we hold about you:
You have a number of rights with regard to the personal data that we hold about you and you can contact us with regard to the following rights in relation to your personal data:
- You have the right to receive a copy of the personal data we hold about you;
- You have the right to correct the personal data we hold about you;
- Where applicable, you may also have a right to receive a machine-readable copy of your personal data;
- You also have the right to ask us to delete your personal data or restrict how it is used, consistent with the GDPR. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request;
- Where applicable, you have the right to object to processing of your personal data for certain purposes;
- Where you have provided us with consent to use your personal data, you can withdraw this at any time;
- If you do not want us to use your personal data for marketing analysis, you can change your settings in the “Emails and marketing” tab of your Roaming Schoolhouse account.
If you would like to exercise any of your rights specified above, please email firstname.lastname@example.org or write to the Schwa SARL at 25 rue Léon Bourgeois 92700 Colombes. We will deal with requests within one month.
We may need to request specific information from you to help us confirm your identity. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Contacting us for information about how we use your personal data:
If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact Derek Ferguson at Roaming Schoolhouse (Schwa), 25 rue Léon Bourgeois 92700 Colombes, France on 06 62 72 87 93 or via email email@example.com.
Complaints will be responded to within 30 days.
This policy is as uploaded on 2 February 2022. There were no previous versions of this policy.