The Planet Bofa group of websites provide an online tutoring system that deliver bespoke, dynamic learning that individually guides each student to 11+ and KS2 success.  This policy applies to data collected from the following websites: www.bofaKS2.co.uk, www.bofaKS2.com, www.planetbofa.com, www.planetbofa.co.uk, www.bofa11plus.co.uk, www.bofa11plus.com, www.bofaelevenplus.co.uk, www.bofaelevenplus.com, www.online-eleven-plus.com and www.online-eleven-plus.co.uk, www.Pre-test.co.uk, www.bofamaths.co.uk, primary-online.in, www.bofaclassroom.co.uk("BOFAclassroom"), www.bofaclassroom.com("BOFAclassroom"), www.london-11plus.co.uk.

This policy applies to information we collect when; you choose to use our websites or you buy or use our products; and/or when you supply us with goods or services.

We take your privacy very seriously and we ask that you read this privacy policy carefully as it contains important information on the personal information we collect about you; what we do with your information and who your information might be shared with.

If you do not consent to our privacy policy, please do not use our services.

Who we are

This website is owned by Planet Bofa Limited ('we', 'us' or 'our') and our registered office is at 10 Church Lane, Horsforth, Leeds, West Yorkshire LS18 5LA, United Kingdom.  We are a 'data processor' for the purposes of the Data Protection Act 2018 (the "Act") where we are processing personal data on behalf of schools and/or parents and/or users of our products.  We are a ‘data controller’ where we are processing personal data such as contact details for our customers.  We take all appropriate steps to ensure compliance with the Act whether acting as a processor or controller.

Any questions about our data protection policy or how we handle your personal data should be addressed to: enquiries@planetbofa.com.

When you use our products or services or supply us with products or services, you share personal information with us. We are committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms of Use ) sets out the basis on which any information we collect from you, or that you provide to us, will be used, processed and shared.

Although children use our websites or the BOFAclassroom they do this further to an adult's approval.  Only adults are able to access and authorise the Terms of Use and payment.

The Planet Bofa website allows you to track your child's progress effortlessly with instant reporting.  With the exception of the BOFAClassroom only you, the child's parent/carer can authorise disclosure of such information to a tutor or school. This is done via the website or via the school or tutor. (For details of how we process personal data relating to the BOFAClassroom see below.)

Information we may collect from you(other than in relation to the BOFAclassroom)

We collect and process the following data about you:

• Information you give us. This is information about you (or your child) that you give us by filling in forms on our websites, corresponding with us by phone, email or otherwise. It includes information you provide when you register on our websites, subscribe to or use any of our services, search for a product, place an order on our websites, participate in social media functions on the websites, enter a competition, promotion or survey, and when you report a problem with the websites or our services or supply us with goods or services. The information you give us may include, but is not limited to, your name, address, e-mail address, your child's email address, phone number, age, username and other registration information. We do not process any credit/debit card information.  This is done by third parties on our behalf, currently Sagepay.
• We will only process the name of a child, the child's email address and part of their date of birth.  This data together with performance information is shared with third parties such as schools/tutors who are authorised to receive this information by the child's parent/carer.  
• If you are unhappy with the personal data we hold for you and ask us to delete this information we shall do so immediately unless we are required to keep it for legal reasons.
• Information we collect about you via cookies. Each time you use our websites we may automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer, mobile or handheld device to the Internet, we do this to ensure the user experience is consistent across browsers and to block spam spider attacks, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
  • information about your visit to our websites, including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
• Personal information about other individuals.  If you give us information on behalf of someone else, you confirm that either:
  1. the other person has a contractual relationship with you and knows that you will be transferring their personal data to us for specific purposes; and/or
  2. s/he has appointed you to act on his/her behalf and has agreed that you can:
     • give consent on his/her behalf to the processing of his/her personal data and
     • receive on his/her behalf any data protection notices.

If you contact us, we may keep a record of that correspondence. 

We do not process any sensitive/special category data.

Cookies

Our websites use cookies to distinguish you from other users of the websites. This helps us to provide you with a good experience when you browse our websites and also allows us to improve the websites. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

Uses made of your information

We take appropriate measures to ensure that any information collected from you is kept secure and kept only for so long as is necessary for the purpose for which such information was collected.  We use information held about you in the following ways:

• To provide the services to you and communicate with you.
• To carry out our obligations arising from any contracts entered into between you and us and to provide you with information, products and services that you request from us.
• To provide you with information about other services we offer that are similar to those that you have already purchased or enquired about.  
• To personalise the services for you and ensure that content from our websites is presented to you in the most effective manner.
• To notify you about changes to our services or products.
• To develop, maintain and protect our websites, our services and/or products.
• To administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To allow you to participate in interactive features of our services, when you choose to do so.
• As part of our efforts to keep our websites safe and secure.
• Parent information is used for payments.  The financial transactions on our websites are handled through Sagepay.  All credit and debit card payments are processed externally and no card details are processed or held by us or our websites.

We may associate any category of information with any other category of information and will treat the combined information in accordance with this privacy policy for as long as it is combined.

The lawful basis for each of the uses listed above is; 

• contractual or necessary in order to enter into a contract with you; or
• in our legitimate interest having taken account of the fundamental rights and freedoms of the relevant data subject which require protection of personal data, in particular where the data subject is a child; or
• legal (where we have to process personal data to comply with the law); or
• based on consent where you have been asked to give this.

Who your information might be shared with

We do not share your personal information with third party advertisers and we do not allow third party advertisements on our websites.

We do not share your personal information with any third party other than:-

• a third party supplier of products which you have ordered (such as 'Galore Park') to enable delivery;
• analytics and search engine providers to assist us in the improvement and optimisation of our websites;
• to a third party which acquires substantially all of our assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal, governmental or regulator obligation or request;.
• in order to:
  • enforce this privacy policy and other agreements or to investigate potential breaches; or
  • protect the rights or safety of our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and to address security or technical issues.

We do not share your child's personal information with any third party other than:-

• your child's school and/or tutor – where you have authorised this transfer - unless your child’s school or tutor is using the BOFAclassroom
• search engine providers to assist us in the improvement and optimisation of our websites.

Marketing and email

We may occasionally email you to provide you with further information about the products and services we offer which you have requested and/or which may be of interest to you.  Such information will also be made available to you when you log into your account.

You can choose to unsubscribe at any point by clicking on the link at the bottom of the email, or changing your preferences through your account.

When you purchase our products an invoice confirming payment will be sent to you via email.  An email will also be automatically generated when a child completes a test. Preferences for this can be managed through your account.

Where we store your information

All information you provide to us is stored on secure servers in the UK. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Planet Bofa website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We do not transfer data outside the European Economic Area ("EEA"). 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted to us. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retention periods for personal data

With the exception of personal data processed further to the BOFAclassroom (details of which are given below) we store your personal data on secure servers for a period of:

• 12 years; and
• 7 years for information required to be held by HMRC; or
•  until you ask us to delete it,

in each case unless the law requires us to store the data for a longer period.

Use of the BOFAclassroom 

Copyright. All copyright in our video and audio recordings created further to the use of the BOFAclassroom (and any other materials which we create and supply to you) (‘Materials’) will be owned by us. 

We will license the relevant school or educational provider to use our Materials for educational purposes only.  This licence includes the right for the school or educational provider to sub-licence our Materials, for educational purposes only, to the parents/carer of the children who appear on or are audible in such Materials. 

Personal Data we process further to use of the BOFAclassroom. We will process personal data such as images and voices of the children and/or teachers who appear in the video and audio recordings. 

Retention of information. We will retain copies of the video and audio recordings for a period of 12 months. After that time the recordings will be deleted unless we are contacted with a request to retain the recordings and there is a legal reason for so doing.

The school or education provider with whom we have contracted to provide the Virtual Classroom may keep copies of the recordings for as long as they see fit in compliance with their own privacy policies and so long as such a period is lawful under the Act.

Lawful basis. We have a contractual right to create and process the personal data which appears in the video and audio recordings provided we comply with the terms of this Policy and our Terms and Conditions.  

Insofar as our contract is with a school it has a legal obligation to educate children and using the BOFAclassroom may also be in its legitimate interest during this period of enforced physical distancing due to the Covid-19 virus.

What rights do you have?

The Act provides the following rights for individuals whose personal data is processed:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object to processing
8. Rights in relation to automated decision making and profiling. (We do not carry out automated decision making and profiling)

Account holders can access and amend any personal data held by us at any time.

You can ask us to stop contacting you for particular purposes or to remove your information completely from our records.  We will then immediately delete your personal data unless there is a legal reason why we need to keep your personal data. In that circumstance we will let you know and destroy your personal information as soon as we are legally entitled to do so.

Right to lodge a complaint with the Supervising Authority

If you have any concerns or complaints about how we use your personal data we hope you will alert us to these directly (see the Contact information below).  In any event you are entitled to complain to the Information Commissioners Office (ICO) which is the supervisory authority in the UK. Their contact details and the procedure can be found at www.ico.org.uk 

Links

Our websites may, from time to time, contain links to and from the websites of our partner networks, and affiliates and third party sites. If you follow a link to any of these third party websites, please note that these websites and any services that may be accessible through them are subject to their own privacy policies and we do not accept any responsibility or liability for these policies or for any information that may be collected through these websites or services. Please check these policies before you submit any information to these websites or use their services.

Your consent and changes to this privacy policy

When you choose to use our services you are consenting to our use of your information as set forth in this privacy policy.

We may change this privacy policy from time to time. Any changes we may make to our privacy policy in the future will be posted on this page and, if we consider it material, notified to you by email.  The most current version governs our use of your personal information. By continuing to access our websites and use the Services after those changes, you agree to the revised privacy policy. 

Contact us

If you have any questions, comments or requests regarding this privacy policy or general data protection enquiries please contact us at enquiries@planetbofa.com.

 

Last updated March 2020