We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Here are some key terms used in this policy:
We, us, our – Honeyguide School Leader Support, trading as Honeyguide
Our data protection manager – firstname.lastname@example.org
Personal information – Any information relating to an identified or identifiable individual
Special category personal information – Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; Genetic and biometric data; Data concerning health, sex life or sexual orientation
Personal information we collect about you
We may collect and use the following personal information about you:
your name and contact information, including email address
your billing information, transaction and payment card information
your contact history, purchase history and saved items
information about how you use our website, IT, communication and other systems
your responses to surveys, competitions and promotions
This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to you.
How your personal information is collected
We collect most of this personal information directly from you—in person, email, from social media contact and via our website. However, we may also collect information from cookies on our website.
We use both session cookies, third-party cookies and persistent cookies on this website.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The information below explains what we use (process) your personal information for and our reasons for doing so:
To provide products and services to you. Our reason: For the performance of our contract with you or to take steps at your request before entering into a contract.
Ensuring business policies are adhered to, e.g. policies covering security and internet use. Our reason: For our legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you.
Operational reasons, such as improving efficiency, training and quality control. Our reason: For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.
Ensuring the confidentiality of commercially sensitive information. Our reason: For our legitimate interests, i.e. to protect trade secrets and other commercially valuable information; To comply with our legal and regulatory obligations.
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures. Our reason: For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.
Updating customer records. Our reason: For the performance of our contract with you or to take steps at your request before entering into a contract; To comply with our legal and regulatory obligation; For our legitimate interests, i.e. making sure that we can keep in touch with our customers about existing orders and new products.
Ensuring safe working practices, staff administration and assessments. Our reason: To comply with our legal and regulatory obligations; For our legitimate interests, i.e. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
Marketing our services and those of selected third parties to a) existing and former customers, b) third parties who have previously expressed an interest in our services, and c) third parties with whom we have had no previous dealings. Our reason: For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers.
We may use your personal information to send you updates (by email) as well as advertising on social media about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it to other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by contacting us at email@example.com or using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
third parties we use to help deliver our products and services to you, e.g., payment service providers;
other third parties we use to help us run our business, e.g. marketing agencies, website hosts or our analytics tracking software;
third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
Where your personal information is held
Information is held digitally and may be held at offices of or digitally by our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
with your and our service providers located outside the EEA;
if you are based outside the EEA;
These transfers are subject to special rules under European and UK data protection law.
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguard is implemented:
Where we use providers based in the US, we may transfer data to them if they are part of the PrivacyShield which requires them to provide similar protection to personal data shared between Europe and the US.
You have the following rights, which you can exercise free of charge:
Access: The right to be provided with a copy of your personal information (the right of access)
Rectification: The right to require us to correct any mistakes in your personal information
To be forgotten: The right to require us to delete your personal information—in certain situations
Restriction of processing: The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object: The right to object, a) at any time to your personal information being processed for direct marketing (including profiling), and b) in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email us via firstname.lastname@example.org ; and
let us have enough information to identify you, e.g. your full name;
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Honeyguide School Leader Support uses a standard SSL encryption that encrypts all information you input as it is sent to us. We recommend you use an up-to-date internet browser which supports 128-bit encryption. Using an out-of-date browser or one that does not support 128-bit encryption may compromise the level of security we are able to provide.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 9th May 2023 and last updated on 9th May 2023.
We may change this privacy notice from time to time—when we do we will post those changes on this page and make you aware via our website so you are always aware of what information we collect and how we use it.
How to contact us
Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’).