Smile 4 Kids

PRIVACY POLICY


The following document explains how Smile 4 Kids Ltd. uses, processes and protects personal data collected via our website. We therefore request you to carefully read the following Privacy Policy as you will be legally bound by its terms whenever you visit our website or when you provide any personal data about yourself or about your children.

Reference to a “child” in this Policy means anyone under the age of 18. This is in accordance with the UN Convention on the Rights of the Child.

Reference to “parental responsibility” in this Policy, means someone, who according to the law in the child’s country of residence, has the legal rights and responsibilities for a child that are normally afforded to parents.

Background

Smile 4 Kids Ltd. (“Smile 4 Kids”, “The Company”, “we”, “us”) value and respect the privacy of those who visit our website or provide information and personal data to us for the purposes of availing our services and/or for carrying out any other business or dealings with us.

This Privacy Policy (“the Policy”) provides information on how we collect information relating to our students and other persons or organisations that visit our website or who we deal with for the purposes of carrying out our business. It should be read in conjunction with the Terms and Conditions that we may have issued to you, other policies on our website and with the information contained in the Register of Fee Payers published electronically by the Office of the Information Commissioner (“ICO”).


Who we are

For the purposes of the Data Protection Act 2018 (“the DPA”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (“the GDPR”), the data controller in respect of any personal data submitted by you will be Smile 4 Kids Ltd. which is a private limited company incorporated under the laws of England and Wales and registered at the Companies House under number 11651695. Our registered office address is 171 Homesdale Road, Bromley, England, BR1 2QL.

Who is the person responsible for the management of your data?

We are registered with the Information Commissioner’s Office (ICO) under registration number ZA760453.

The Person responsible for data protection is Mrs. Sarwarinder Sidhu Saran (Safrina Saran). For any queries relating to the management of your personal data please do not hesitate to send us an email at sfs662001@yahoo.com.

What personal data do we need/receive?

“Personal Data” has been defined under the GDPR as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

Any references to “personal data” in this Policy therefore means information about living individuals, which, alone or in conjunction with other information held by us is capable of identifying them. The DPA and the GDPR regulate our use of your personal data.

In order to provide our services or for the purposes of conducting our business we may need the following data from the individuals we are dealing with:

(We have tried to cover categories of data that we generally require while providing services to our clients/students or for operating our business. However, this is not an exhaustive list)

What personal data do we collect, hold and share relating to our students?

When enrolling your child for our courses or when making a booking for a class, we may collect the following information (without limitation), relating to you and/or your child being enrolled as a student:

What personal data relating to our students do we hold for our records?

For the purposes of our records, internal use and for the purposes of assessing a student’s progress we hold the following information (without limitation), relating to our students:

Sources of personal data

We may obtain your/your child’s personal data from you when you contact us or get in touch with us via our website, email, telephone or through any means of communication. This includes personal data you provide to us when you:

What are the purposes for gathering and processing personal data?

We may gather and use your/your child’s personal data for the following purposes, including but not limited to.

Analytics

We use cookies and analytics tools (described in further detail below) to monitor and analyse user website activities, including but not limited to page views, location of access and sources and time spent on the website. This information is depersonalised and is displayed as numbers. This information cannot be traced back to individuals. This therefore ensures your privacy.

Internal data analysis

Where we have obtained personal data for any of the purposes set out in this Policy, we may use it in connection with internal data analysis and also for any of the other purposes set out in this Policy. This does not affect your legal right to object to the use of your data for direct marketing purposes.

Personal data we may obtain from our website about our web visitors

We may automatically collect the following information, which may or may not be personal data, in relation to anyone visiting our website:

We will use this data to:

Cookies

Cookies are small text files that are downloaded to your device by websites you visit. Currently our website uses required/necessary cookies that enable you to navigate our website and use its features, such as accessing secure areas of the website. Since required cookies are essential to operate the website there is no option to opt out of these cookies.

We may also use certain functionality cookies and web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. The information that the cookies collect, such as the number of visitors to the site, the pages visited and the length of time spent on the site, may be aggregated and will therefore be anonymous.

We may embed certain videos from our YouTube or other video channels that may drop or set up their own or third party cookies to enable you to play the videos and to collect certain analytics data such as for how long the viewer has watched the video. These cookies do not track individuals.

We don’t use cookies in a way that allows us to identify site users.

You may refuse the use of cookies or withdraw your consent at any time by selecting the appropriate settings on your browser. However, this may prevent you from accessing all of our website.

Lawful basis for processing your personal data

The following is the lawful basis for processing your/your child’s personal data:

Who do we share your personal data with?

Your/your child’s personal data may be received by:

We do not share our students’ personal data with anyone without prior express consent unless the law and our policies allow us to do so.

Transfer of personal data to international organisations or countries outside the United Kingdom

While providing services we may have to collect or provide information including personal data from or to third parties located in territories outside of the United Kingdom.

Where we collect personal data from students/individuals located in the EU we will try our best to ensure that such personal data is granted the same level of protection as it would enjoy in the EU.

Where we transfer personal data to third parties outside of the UK or the EU, we will ensure that the recipients are aware of the provisions of the DPA and the GDPR respectively and provide an adequate level of protection for the rights of persons whose personal data has been shared with them.

In addition, all our inbound and outbound email communications are TSL (Transport Security Layer) encrypted.

Retention of personal data

Any personal data will be retained by us for the duration as will be deemed necessary by us for the purposes of providing further services, marketing or growing our business, such duration not being less than (3) three years from the date on which data was first gathered.

Hosting and back-end infrastructure

We use third-party hosting services for the purposes of hosting data and files that enable our website to run and be distributed as well as to enable us to run specific features and functions within our website. Some of these functions work through geographically distributed servers, thereby making it difficult to identify the exact location where the personal data is stored.

What are your rights with respect to your personal data?

Under the DPA, you have the following rights in relation to your own/your child’s personal data:

If you want to (1) tell us to stop using your/your child’s data for direct marketing or withdraw consent from us processing your/your child’s personal data for any of the purposes mentioned in this Policy; (2) exercise your subject access rights; (3) tell us about inaccurate personal data you think we hold on you; or (4) object to a use you believe we’re making of your data which is causing, or is likely to cause, damage or distress, please contact Mrs. Safrina Saran or write to us at this address:

The Data Protection Manager (Mrs. Safrina Saran)
Smile 4 Kids Ltd
171 Homesdale Road
Bromley, England
BR1 2QL

Unless the law permits us to do so, we will not charge you to exercise your subject access rights but may charge a reasonable fee reflecting our administrative costs should you request further copies of the personal data. When you contact us to exercise any of the above rights, we will first ensure that the person requesting the data is the person whose data is being sought (or that it is being requested on that person’s behalf). This may involve providing us with proof of your identity or your authority to act for the data subject. We may also ask you for any information we need to help us find the personal data you’re enquiring about.

We will also provide you with the following information relating to your personal data:

Should you contact us in relation to us holding incorrect, incomplete or inaccurate data about you, we will make the required corrections promptly.

Right to lodge a complaint

If you are unhappy with the way, we are processing your personal data you can lodge a complaint by writing to Mrs. Safrina Sidhu Saran at sfs662001@yahoo.com or by sending your complaint to:

The Data Protection Manager (Mrs. Safrina Sidhu Saran)
Smile 4 Kids Ltd
171 Homesdale Road
Bromley, England
BR1 2QL

You are also entitled to make a complaint at the Information Commissioner’s Office (ICO).

Variations to this Policy

We may update this Policy from time to time. We reserve the right to alter and make changes to this Policy at our sole discretion and we therefore request all users to regularly refer to our Privacy Policy for updates and variations.

©2018 by SMILE 4 kids developed by AAHA Solutions