Privacy, security, and ethical usage of data are company-wide imperatives at Studious and must guide how we handle data every day. Studious is committed to protecting the privacy and security of the data we handle, and ensuring we use, process, and share it responsibly.
- PART 1: Purpose
- PART 2: What data do we collect?
- PART 3: Why do we collect information?
- PART 4: Lawful Basis for Processing
- PART 5: How long do we keep your Personal Data?
- PART 6: Who do we share your Personal Data with?
- PART 7: How is your Personal Data kept secure?
- PART 8: What rights do you have?
- PART 9: How to contact us
- PART 10: What can I do if I am unhappy?
PART 1: PURPOSE
For the purposes of the Data Protection Act 2018 and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), Studious will be the ‘data controller’ for all Personal Data we determine the means and purpose of processing.
We refer to your “Institution” where you are a student at an educational entity (e.g. a university) or if you are an employee, the Institution will refer to your employer.
Where we receive your Personal Data from an Institution, or where we share your Personal Data with an Institution, we will be doing so in the capacity of a ‘joint data controller’ pursuant to the applicable Data Protection Legislation and in accordance with the principles set out below.
PART 2: WHAT DATA DO WE COLLECT?
If you register to use the Studious Ryze app or any other Studious created app or e-learning platform (each defined as an “App”), we will collect the following information from you:
- full name;
- email address (which will typically be your Institution’s email address);
- age; and
- mobile number.
This information may be provided to us directly by your Institution (where applicable).
When you use the App we also collect the following data:
- as part of your ‘Learner’ profile within the App, any voluntary information in relation to your educational interests, Institution and programme of study;
- the results of your achievements from assessment and content that you enter onto the App. This may include how you perform on quizzes, polls and other sources of gamification;
- your computer’s IP address; and
- when, where and for how long you engage with learning content, social learning and other features of the App (as further detailed below).
1.2 Website Users
Whilst you can use our website studious.org.uk (the “Website”), without providing your Personal Data, once you contact us via the Website, you will provide us with your:
- full name; and
- email address.
We may also collect technical information about you when you visit the Website. This information may include the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from the Website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page. Information about your visit(s) to the Website may also be collected. The collected information is used to provide an overview of how people are accessing and using the Website. It is not used for any additional purpose, such as to profile those who access the Website.
1.3 Social Media Platforms and Third Party Websites
Our website and the Apps will permit limited use of social sharing buttons which helps allow you to share web content directly from our web pages to social media platforms. Please note that social media platforms may track and save your request to share a web page through your social media platform account and this information will be subject to their privacy policies and terms and conditions.
Our website also contains links to other websites of interest. Please note that external websites are not under our control and will have their own privacy policies and terms and conditions.
1.4 Marketing Information
We may, where we have obtained your express permission, also use the information collected to:
- contact you occasionally in order to invite you to share your opinions and experiences of Studious eLearning content or platforms in order to collect your feedback and improve our services and products;
- send newsletters where you have asked for them;
- provide you with information about our services that we offer via promotional emails; and
- keep you up to date with features on the Website and/or the App,
however, you can change your communication preferences within the settings section of the App or opt-out of any of these data uses at any time by emailing [email protected]. We will only keep your information for as long as reasonably required.
Email marketing campaigns sent to you by us may contain tracking facilities within the actual email. Your activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity, other activity around how you access and view the emails and tracking with the aim of improving your experience and how we present our email newsletter going forward.
This information may be used to refine future email campaigns and supply you with more relevant content based on your activity.
You will be able to unsubscribe from an email newsletter from us by clicking the applicable unsubscribe link in our email – or other instructions provided by us in the email.
PART 3: WHY DO WE COLLECT INFORMATION?
We collect this data to:
- assist you in answering any questions or queries you may have submitted;
- provide you with a personalised browsing experience when using the Website. This may include automated decision making within the app to order to provide more bespoke user experiences and to access the correct resources for courses;
- allow you to use the full range of features on our Apps or our Website;
- fulfil any contractual agreements between you and us or your Institution and us;
- manage any Learner account that you hold with us. Your individual learner data (name and email) will be stored on our Learner Management System (LMS) to enable learners to access the online learning service, complete courses, answer questionnaires, access resources, record learning progress and download notes or journal entries;
- send you course-specific notifications and updates about online courses and content you are enrolled on;
- comply with our legal and regulatory requirements;
- allow your Institution to monitor your progress and award you with the relevant reward or accreditation as required where you are taking online content and courses and are awarded points;
- provide affiliated education institutions with anonymised and aggregated information about user behaviour. For example, how often and when users are engaging with learning content or social learning interactions. Permitting affiliated education institutes to adapt to the needs of their students and to enhance their learning experience; and
- provide, maintain, protect and improve the quality of the App(s) or the Website and the online courses and content we offer, including by conducting anonymised market research.
PART 4: LAWFUL BASIS FOR PROCESSING
We will only process your information for as long as we have a relevant legal basis to do so. This is usually in order to provide you with the services you have requested from Studious and unless stated, all of the above processing is conducted under the legal basis of performance of a contract.
We have provided a breakdown of the relevant grounds for processing below:
Personal Data Processing Activity Legal Ground For Processing Replying to website enquiries Contractual Necessity Providing you with access to the App Contractual Necessity Sending you communications via the App Contractual Necessity Storing voluntary information in relation to your App profile Consent Creating statistics relating to your use of App where you are identified Consent Sharing your personally identifiable information with your Institution Legitimate Interests Creating statistics relating to your use of App where you are not identified N/A – The data is anonymised and aggregated so that no personal data processed and you are not identifiable. Sending you information about services that may interest you Legitimate Interests. Sending you marketing communications Consent
If we have collected sensitive personal data as part of our service provision, we will always ensure that we either request explicit consent from you or document the appropriate exemption to allow the processing of this data.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we consider the new purpose to be incompatible with the original purpose of collection, we will conduct a privacy impact assessment or contact you to request your consent for further processing. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
PART 5: HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We only keep your Personal Data for as long as is necessary to fulfil the purposes we collected it for. The decision on the length of time which we will retain your Personal Data for will depend on the following criteria:
- the amount, nature, and sensitivity of the Personal Data;
- the potential risk of harm from unauthorised use or disclosure of your Personal Data;
- the purposes for which we process your Personal Data and whether we can achieve those purposes through other means;
- legal requirements;
- contractual requirements;
- management of the service; and
- requirements placed upon us by your Institution / other data controllers.
Anonymised statistical and aggregated information which cannot identify you will be retained for longer periods of time.
Studious will invite you to download any content before the notified service expiry date. If you choose not to download your user-generated content, access to the courses and content will be stored for three months, after that time you will no longer be able to access the content.
PART 6: WHO DO WE SHARE YOUR PERSONAL DATA WITH?
If and when we share your data, we always do so under a written agreement governing how your data must be protected.
Sharing App Data with Institutions – Statistical Information
In relation to your use of the App we may provide the following information to Institutions:
- Total number of login sessions;
- Average session by day of week and hour;
- Average session time;
- Total count of lesson access (first access only);
- Ranked order of most popular lessons;
- Total number of videos watched;
- Total number of points collected;
- Average interaction of lesson content over 14 day running period;
- Total number of bookmarks made;
- Total number of active bookmarks;
- Ranked order of currently bookmarked content;
- Total number of thread messages sent; and
- Total number of unique threads contributed too
The above information will be identifiable by your email address and may be used to by Institutions in conjunction with other Identifiable Personal Data they store on you.
Sharing App Data with Institutions – Course Activity and Comments
Studious and other partner institutions that provide online and app-based e-learning courses or content carry out academic and educational research in order to develop and provide improved online course content. Your activities on any Studious course are shared with the course provider for academic research purposes. This includes the comments you make where you may disclose certain Personal Data about yourself.
Even though we never associate your comments, information or other course activity with any of your public user profile information (such as name or profile picture) in the datasets we share with the course provider, it may still be possible to identify you by (a) the content of your comments or (b) finding the actual comment on the website and seeing the user associated with it; (c) matching pseudonymised identifiers to an individual.
We want you to feel comfortable sharing any comments with us and your Institution, and we confirm that all our course providers who conduct research will never associate your comment or your activity with your user account by method (b) above and will always treat any Personal Data in strict accordance with data protection laws and the research ethic guidelines.
Sharing Data with Other Third Parties
We may be required to disclose your Personal Data by law, i.e. by court order, to government bodies and law enforcement agencies.
We may share your information with third parties in the following ways:
- we may use carefully selected sub-processors to help us collect, store or manage your information. This will always be managed under the terms of a written data processing agreement;
- analytics and search engine providers that assist us in the improvement and optimisation of the App and the Website; and
- we will transfer your Personal Data to a third party if:
- We sell or buy any business or assets, we will provide your Personal Data to the seller or buyer (but only to the extent we need to, and always in accordance with Data Protection Legislation); or
- If Studious or the majority of its assets are acquired by somebody else, in which case the Personal Data held by Studious will be transferred to the buyer.
PART 7: HOW IS YOUR PERSONAL DATA KEPT SECURE?
We take the protection of your data seriously. We protect your Personal Data via the use of various technical and organisational measures such as encryption, password protection, access controls, and appropriate firewall technology to prevent unauthorised access. All information is stored on secure servers within the EU and is regularly backed up. When you register, we will ask you to choose a password which enables you to access the online courses and content. You are responsible for keeping this password confidential. This password must not be shared with anyone.
PART 8: WHAT RIGHTS DO YOU HAVE?
You have the following rights:
- To have access to your Personal Data. You can access your Personal Data through your user account on the App or by emailing [email protected]. You are also entitled to receive confirmation as to whether your Personal Data is being processed by us, as well as various other information relating to our use of your Personal Data;
- to amend or rectify your Personal Data, such as changing your communication preferences, account username or picture, which can be done through your user account settings area on the App. You also have the right to have incomplete Personal Data we hold about you completed, by providing a supplementary statement to us;
- to request deletion of your Personal Data in the following circumstances: (i) we no longer need to use your Personal Data for the reasons we told you we collected it for; (ii) where we needed your consent to use your Personal Data and you have withdrawn your consent; (iii) you object to our use of your Personal Data and we have no compelling reason to carry on handling your Personal Data; (iv) our handling of your Personal Data has broken the law; or (v) we must erase your Personal Data to comply with a law we are subject to. Please note, that there may be circumstances where we are legally required or entitled to retain it. An individual learner can request that we delete individual learning history via emailing [email protected], requests will be reviewed on a case-by-case basis;
- to restrict the processing of your Personal Data where: (i) you think we hold inaccurate Personal Data about you; (ii) our handling of your Personal Data breaks the law, but you do not want us to delete it; (iii) we no longer need to process your Personal Data, but you want us to keep it for legal reasons; or (iv) we are handling your Personal Data because we have a legitimate interest, and are in the process of objecting to this use of your Personal Data., in certain circumstances;
- to object to us handling your Personal Data when: (i) we are handling your Personal Data based on our legitimate interests. If you ask us to stop handling your Personal Data in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your Personal Data should continue; or (ii) for marketing purposes; and
- to receive the Personal Data we hold about you in a structured, standard machine-readable format and to send this to another organisation controlling your Personal Data.
If you wish to exercise any of these rights in relation to the use of your Personal Data, please contact us (the details to do this can be found the ‘How to contact us’ section below).
PART 9: HOW TO CONTACT US
PART 10: WHAT CAN I DO IF I AM UNHAPPY
If we cannot resolve any data privacy issues, or you are unhappy with our decisions, you have the right to complain to the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales.
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