Version 2: May 2018 (Current)
Sixth Domain Ltd ("We") are committed to protecting and respecting your privacy and the privacy of the data you enter into our site.
This policy (together with our terms and conditions of software use www.rewardsystem.org/terms and any other documents referred to) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Sixth Domain Ltd is fully compliant with the General Data Protection Regulation ((EU) 2016/679) (GDPR). Under GDPR, Sixth Domain Ltd is both a data controller and processor.
Sixth Domain Ltd is a registered data controller (ICO Z3164232).
By using the Software (as defined below) you warrant that you are complying with any relevant school's data protection policy, as well as GDPR and any relevant laws in your jurisdiction, and shall indemnify us for any breach.
Information We May Collect from You
We may collect and process the following data about you:
- Information that you provide by filling in forms and registering for the Reward System software ("Software") or as a user of the website www.rewardsystem.org ("the Website"). This includes information provided at the time of registering on the Website, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with the Website.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of activities you carry out through the Website.
- Details of your visits to the Website including, but not limited to, traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
We will only collect personal data from you in order to provide the functionality of the Software and Website and this will be limited to what is necessary to do this. If any of the data we have collected is inaccurate, please contact us at firstname.lastname@example.org.
We collect information about you when you use the Software and when you correspond with us. If you think any personal data is inaccurate, please contact us.
The identifiable information you upload to the Website or the Software shall remain the property of the relevant school and we shall have no rights in such data except in an anonymised or aggregated format, in which case we shall own the intellectual property in the data we have collected.
The relevant school shall retain ownership of identifiable information and we shall own the intellectual property in anonymised and aggregated data.
Other Information We May Collect
We will also collect and process the following data through your use of the Software:
- Information in respect of individual children in your class/department/school (as appropriate) which you provide by completing details in the Software. This may include sensitive personal data (as defined in the GDPR).
- Information about your class/department/school which you provide by completing details in the Software.
We collect information you input in the Software relating to pupils and your school.
If you input sensitive information we will collect this.
We collect statistical data about your computer when you access the Website.
We may use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website.
Where and How We Store Your Personal Data
The data that we collect from you will be stored on our secure servers based in the United Kingdom with fire walled server infrastructure and swipecard only access to the data centres.
We use SSL encryption with forward secrecy where it is available on your browser and store the information we collect in encrypted format within the database where appropriate.
The members of our staff who can access the data are limited to those for whom it is necessary and all such staff have a valid UK Disclosure and Barring Service (formerly CRB) check.
By using the Software you acknowledge that the Software is designed and intended to be used in the United Kingdom and you warrant that you are based in the United Kingdom and shall not knowingly be transferring data from or to any other country through the Software.
The information held by us will be stored on secure servers with strict security measures in place.
The information will be encrypted and our staff will have limited access to it.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
For security we recommend that you keep your browser updated to the latest version at all times.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Despite our efforts, the internet is not completely secure and we ask that you keep your log-in details confidential. You should keep your browser updated and make transmissions at your own risk.
Uses Made of the Information
We use information held about you in the following ways:
- To ensure that content from the Website is presented in the most effective manner for you and for your computer.
- To provide you with the Software.
- To keep the Software updated.
- To provide you with the services you require as a user of the Website and Software.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To analyse behaviours in schools and amongst certain demographics of students; any such data will only be used on an aggregate basis and will not identify individuals.
- To carry out our obligations arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
We use the information we collect from you to provide you with the Software and other services and to keep these updated.
We will never sell your data or any information relating to students which we obtain through your use of the Software to any third party (unless this is as part of a sale of Sixth Domain Ltd or its assets).
We may also use your data to provide you with information about goods and services which may be of interest to you and we may contact you about these by email, post or telephone.
If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous order by you. We will always obtain your consent before contacting you in this way.
We will always obtain your consent before passing any of your personal data on to third parties for marketing purposes.
All emails we send to you will be signed by DomainKeys Identified Mail (DKIM) so you know it is from us.
We also conduct research but the information we use for this will be aggregated and will not identify individuals.
We may send you marketing emails about our products and services unless you have said that you do not want us to do this.
Disclosure of Your Information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may disclose your personal information to third parties:
- Where such third parties are a member of your department or school network; all comments you include about an individual student through the Software can be accessed and read by each other member of your department or school network.
- Where such third parties are our partners for the purposes of providing the services you require as a user of the Website or the Software.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Sixth Domain Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of software use www.rewardsystem.org/terms and other agreements; or to protect the rights, property, or safety of Sixth Domain Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We may disclose the information we collect to our partners when legally required and in the event of a sale of Sixth Domain Ltd or our assets.
Where you are a member of a department or school network the information you include in the Software will be shared with all of the other members of the network.
Retention of Data
We will retain the information for no longer than is necessary for the purposes for which the information was collected or for which it is to be further processed. In some cases there are legal requirements to keep information for a minimum period and the time period for which we keep the information will vary according to what it is used for.
As a user you may delete any information from the Software at any time.
We will only retain your information for as long as is necessary.
You have the right to access the personal data we hold on you and to receive this data in a portable format. You also have the right to rectify and delete this data, and to ask us to stop or restrict the processing of it. If you wish to exercise these rights, please contact us at email@example.com.
We will inform you about how we use your personal data. Contact us if you want to receive of a copy, change, delete or make a change to how we process it.
The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We may change this policy in the future; please check back.
Contact us at firstname.lastname@example.org.