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.
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.
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.
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 email@example.com.
“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)
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:
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:
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:
We may gather and use your/your child’s personal data for the following purposes, including but not limited to.
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.
We may automatically collect the following information, which may or may not be personal data, in relation to anyone visiting our website:
If anyone makes an allegation of child abuse against a member of staff:
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.
The following is the lawful basis for processing your/your child’s personal data:
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.
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.
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.
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.
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
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.
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 firstname.lastname@example.org or by sending your complaint to:
The Data Protection Manager (Mrs. Safrina Sidhu Saran)
Smile 4 Kids Ltd
171 Homesdale Road
You are also entitled to make a complaint at the Information Commissioner’s Office (ICO).