1. Introduction
Learn High respects the privacy of Students, parents, guardians, Teachers,
Academic Mentors, website visitors and other individuals whose personal information
it processes.
This Privacy and Cookie Policy explains, in clear terms:
- what personal information Learn High collects;
- why Learn High collects it;
- how Learn High uses it;
- who it may be shared with;
- how it is protected;
- how long it may be retained;
- how cookies and similar technologies are used; and
- the rights individuals may have in relation to their personal information.
Learn High operates primarily in the United Kingdom and Switzerland and may
provide Services internationally.
Learn High aims to comply with applicable data-protection requirements, including
the UK GDPR, Data Protection Act 2018, Privacy and Electronic Communications
Regulations (PECR) and applicable Swiss data-protection requirements, including
the Swiss Federal Act on Data Protection (FADP).
Swiss data-protection guidance requires privacy information to be transparent,
comprehensible and accessible to individuals.
2. Who Is Responsible for Your Information?
Learn High is the trading name of Mathusha Chandrakumaran, a UK sole trader.
For data-protection purposes, Learn High is generally the data controller for the
personal information it collects and determines how to use.
Contact:
support@learnhigh.co
We do not publish a residential address in this Privacy Policy.
3. What Information We Collect
Depending on how you interact with Learn High, we may collect:
Contact information
This may include:
- name;
- email address;
- telephone number;
- communication details; and
- parent or guardian contact information.
Student information
Where necessary to provide the Academic Programme, we may collect:
- Student name;
- age or date of birth;
- year group;
- subjects;
- curriculum;
- examination board;
- academic objectives;
- academic progress;
- attendance;
- lesson records;
- learning needs;
- academic feedback; and
- information provided by the Student, parent or guardian.
Programme information
We may collect information concerning:
- programme selection;
- lesson schedules;
- session attendance;
- lesson records;
- communications;
- invoices;
- payments;
- programme progress; and
- customer-service enquiries.
Technical information
When you use our website or online systems, we may collect information such as:
- IP address;
- browser type;
- device information;
- operating system;
- website interactions;
- pages visited;
- approximate location derived from technical information;
- referral information;
- usage information; and
- information collected through cookies or similar technologies.
4. Information Concerning Children
Learn High may process information relating to Students who are children or young
people.
Where appropriate, we may obtain information from:
- the Student;
- a parent or guardian;
- a school or educational organisation;
- a Teacher or Academic Mentor; or
- another authorised person.
We take particular care with information concerning children and only collect and use
information that is reasonably necessary for the relevant purpose.
Where consent is required by law, we will seek appropriate consent.
Parents and guardians should contact us if they have questions about information
held concerning a Student.
5. How We Use Personal Information
We may use personal information to:
- provide Academic Programmes;
- arrange and manage sessions;
- communicate with Students and parents;
- allocate Teachers and Academic Mentors;
- monitor programme participation;
- maintain academic and lesson records;
- manage customer accounts;
- issue invoices;
- process payments;
- administer contracts;
- respond to enquiries;
- manage complaints;
- maintain safeguarding processes;
- maintain security;
- prevent misuse or fraud;
- improve our Services;
- improve our website;
- analyse website performance;
- understand how visitors use our website;
- communicate information about Learn High;
- conduct appropriate marketing where legally permitted;
- comply with legal obligations; and
- establish, exercise or defend legal claims.
6. Our Legal Bases for Processing
Where UK GDPR applies, Learn High will rely on an appropriate lawful basis for
processing personal information.
Depending on the circumstances, this may include:
Contract
Where processing is necessary to enter into or perform an agreement with a
Customer or Student.
Legal obligation
Where Learn High is required to process information to comply with a legal or
regulatory obligation.
Legitimate interests
Where processing is reasonably necessary for Learn High's legitimate business
interests and those interests are not overridden by the individual's rights and
interests.
Examples may include:
- administering the business;
- maintaining security;
- improving Services;
- managing customer relationships;
- preventing fraud;
- maintaining appropriate business records; and
- protecting Learn High's legal rights.
Consent
Where the law requires consent, Learn High will request consent before carrying out
the relevant processing.
Consent may be withdrawn at any time.
Where processing is based on consent, withdrawal of consent does not affect the
lawfulness of processing that occurred before withdrawal.
7. Academic and Safeguarding Information
Learn High may process information relating to a Student's academic development
and, where genuinely necessary, information relevant to safeguarding or welfare.
Such information will only be processed where there is an appropriate legal basis
and where necessary for the relevant purpose.
Learn High does not seek unnecessary sensitive information.
Students and parents should avoid providing sensitive information unless it is
reasonably necessary for the provision or safe administration of the programme.
8. Who We Share Information With
Learn High may share personal information with carefully selected service providers
where necessary to operate the business and provide the Services.
Depending on the Services used, these may include providers of:
- payment processing;
- email and business communication;
- video conferencing;
- scheduling and calendars;
- customer relationship management;
- learning management systems;
- cloud storage;
- website hosting;
- analytics;
- security;
- administrative services; and
- professional or legal services.
Learn High currently uses or may use services including Stripe, Microsoft/Outlook,
Google Workspace/Gmail, Google Analytics, Zoom, WhatsApp, LinkedIn,
Facebook/Instagram, YouTube and related business or analytical services
where applicable.
We do not sell Student or Customer personal information.
We may disclose information where required by law, court order, regulatory
authority, safeguarding requirement or other lawful process.
9. International Transfers
Some service providers used by Learn High may process personal information
outside the United Kingdom or Switzerland.
Where personal information is transferred internationally, Learn High will take
appropriate steps required by applicable data-protection law, which may include
using recognised adequacy arrangements, contractual safeguards or other lawful
transfer mechanisms.
Because Learn High works internationally, information may be processed in
countries other than the country in which the Student, parent or website visitor lives.
10. Payment Information
Payments may be processed through third-party payment providers such as Stripe.
Learn High does not ordinarily need to receive or store complete payment-card
details.
Payment providers may process payment information under their own privacy
policies and security arrangements.
Customers should review the applicable third-party provider's privacy information
where appropriate.
11. Communications
We may communicate with Customers and Students through:
- email;
- Microsoft Outlook;
- Gmail;
- WhatsApp;
- Zoom;
- scheduling systems;
- learning-management systems; and
- other communication tools reasonably required to provide the Services.
Communications relating to an existing programme may be necessary to perform the
contract.
Marketing communications will be sent only where legally permitted and, where
required, with appropriate consent.
Individuals may opt out of marketing communications at any time.
12. Marketing and Social Media
Learn High may maintain business profiles and marketing activities on platforms
including:
- Facebook;
- Instagram;
- LinkedIn; and
- YouTube.
These platforms may process personal information independently of Learn High.
Learn High may use platform analytics to understand general engagement and
improve its marketing and Services.
Learn High will not publish identifiable Student information, photographs, recordings,
testimonials or other personal information for promotional purposes without an
appropriate lawful basis and, where required, consent.
13. Website Analytics
Learn High uses analytics technologies, including Google Analytics, to understand
how visitors use the website and to improve its performance, content and user
experience.
Analytics technologies may collect information about:
- pages visited;
- interactions;
- approximate geographic information;
- device type;
- browser;
- referral source; and
- website activity.
Where required by applicable law, non-essential analytics cookies or similar
technologies will only be activated after the relevant user has provided consent.
14. Cookies
Cookies are small files or similar technologies that allow a website to recognise a
device or remember information about a user's interaction with the website.
Learn High may use:
Strictly necessary cookies
These are necessary for the operation, security or functionality of the website.
These cookies may be used without consent where legally permitted.
Analytics cookies
These help Learn High understand how visitors use the website and measure
website performance.
These cookies require consent where applicable law requires consent.
Preference cookies
These may remember choices made by visitors, such as language or certain website
preferences.
Marketing or advertising cookies
Where used, these may help Learn High understand marketing effectiveness,
measure campaigns or provide relevant advertising.
These cookies will not be activated without appropriate consent where consent is
legally required.
15. Cookie Consent
Where required, Learn High will provide a cookie consent mechanism allowing
visitors to make a clear choice regarding non-essential cookies.
Visitors should be able to:
- accept non-essential cookies;
- reject non-essential cookies; and
- manage or change their preferences.
Consent must involve a clear affirmative action and should not be assumed merely
because someone continues browsing the website. UK guidance specifically
requires users to be told what cookies do and, for non-essential cookies, to provide
appropriate consent.
16. Third-Party Cookies and Technologies
Third-party services embedded in or connected to the Learn High website may use
cookies or similar technologies.
These may include analytics, advertising, social-media, video or other technology
providers.
Third-party providers may process information independently under their own privacy
policies.
Learn High will take reasonable steps to ensure that its website's use of third-party
technologies is consistent with applicable data-protection and cookie requirements.
17. How Long We Keep Personal Information
Learn High retains personal information only for as long as reasonably necessary for
the purposes for which it was collected, including contractual, legal, accounting,
safeguarding, regulatory and legitimate business purposes.
Different categories of information may therefore be retained for different periods.
For example:
- customer and contractual records may need to be retained for legal and
accounting purposes;
- invoices and financial records may need to be retained for statutory periods;
- academic records may be retained for an appropriate period to administer and
evidence the programme;
- safeguarding records may require longer retention where necessary; and
- marketing information will be retained in accordance with applicable
requirements and preferences.
When information is no longer required, Learn High will take reasonable steps to
delete it securely or anonymise it.
18. Data Security
Learn High takes reasonable technical and organisational measures to protect
personal information against:
- unauthorised access;
- accidental loss;
- misuse;
- alteration;
- unauthorised disclosure; and
- destruction.
Access to personal information is restricted to people who reasonably need it for
legitimate business or service-delivery purposes.
However, no online system can be guaranteed to be completely secure.
19. Data Breaches
If Learn High becomes aware of a personal-data breach, it will assess the incident
and take the steps required by applicable law.
Where notification to a regulator or affected individuals is legally required, Learn
High will make the appropriate notification within the applicable timeframe.
20. Your Data Protection Rights
Depending on the applicable law and circumstances, individuals may have rights
including:
- the right to request access to personal information;
- the right to request correction of inaccurate information;
- the right to request deletion;
- the right to request restriction of processing;
- the right to object to certain processing;
- the right to data portability in applicable circumstances;
- the right to withdraw consent where processing is based on consent; and
- rights concerning automated decision-making where applicable.
These rights are not absolute and may be subject to legal exceptions.
UK privacy guidance requires privacy notices to explain applicable individual rights
and how people can exercise them.
21. How to Exercise Your Rights
To exercise a data-protection right or ask a privacy question, contact:
support@learnhigh.co
Please provide enough information for us to identify the relevant records and
understand your request.
We may need to verify your identity before providing personal information or making
certain changes.
22. Complaints
If you have concerns about how Learn High processes your personal information,
please contact us first:
support@learnhigh.co
We will consider the matter and aim to resolve it appropriately.
Individuals may also have the right to complain to the relevant data-protection
authority.
For individuals in the United Kingdom, this is generally the Information
Commissioner's Office (ICO).
For individuals in Switzerland, the relevant authority is the Federal Data Protection
and Information Commissioner (FDPIC).
23. Children's Information
Learn High may provide Services to children and young people.
Parents and guardians are encouraged to contact Learn High if they have questions
about the collection or use of a child's information.
Where consent is required for a particular processing activity, Learn High will take
appropriate steps to obtain valid consent.
Learn High does not knowingly use children's personal information for purposes
unrelated to the provision, administration or lawful promotion of its Services.
24. Recordings
Learn High does not automatically assume that every academic session will be
recorded.
Where a session, meeting or communication is recorded, Learn High will provide
appropriate information and obtain consent where required by law.
Recordings will only be used for legitimate purposes communicated to the relevant
individuals.
Students and parents should not record sessions or distribute recordings without
appropriate permission and without considering the privacy rights of Teachers,
Academic Mentors and other participants.
25. Website Security and Third-Party Links
The Learn High website may contain links to third-party websites or services.
Learn High is not responsible for the privacy practices, security or content of third-
party websites.
Visitors should review the privacy policies of third-party services before providing
personal information.
26. Changes to This Privacy Policy
Learn High may update this Privacy and Cookie Policy from time to time to reflect:
- changes in the Services;
- changes in technology;
- changes in third-party providers;
- changes in legal requirements; or
- changes in how Learn High processes personal information.
The latest version will be published on the Learn High website.
Where a significant change materially affects individuals, Learn High will take
reasonable steps to bring the change to their attention.
27. Contact
For all privacy, data-protection and cookie enquiries:
Learn High
Trading name of Mathusha Chandrakumaran, Epping, Essex, United Kingdom