Privacy Notice

Summary

By using Numerise, you agree to your personal information (referred to in this Privacy Notice as Customer Data and Usage Data) being used by Sparx and shared with other companies who support Sparx (referred to in this Privacy Notice as Support Companies) in providing Numerise to you.

Virtual classroom privacy flow

Key information

We need to use personal information in order to provide personalised maths teaching and learning through Numerise. It is always used responsibly, transparently and securely. We will never sell personal information nor use it to market or sell non-Sparx Family products or services. Numerise does not contain any in-platform advertising or marketing. We are compliant with the Data Protection Act 2018, GDPR and COPPA.

 

COPPA Direct Notice

This notice applies to Users who are based in the US. The consent of a supporting adult is required before a User under 13 years old can use Numerise. During our registration process, the personal information of a supporting adult is collected for the purpose of obtaining consent from them before their child under 13 years old can use Numerise. Once consent has been obtained, and their child begins to use Numerise, personal data will be collected from the child so they can use Numerise. Should consent not be given by the supporting adult within a reasonable time (2 weeks), any personal information held by Sparx about the child will be deleted. Supporting adults can give their consent by replying to the emails sent by Numerise. Full details of the personal information used by Sparx in connection with Numerise, and how supporting adults can exercise their rights in relation to this personal information in respect of their child under 13 years old, are set out below.


 

Information about Sparx

Sparx Limited (company number 07907042) (Sparx, we, us or our) is the entity responsible for the use of personal information for the purposes of providing Numerise. Sparx is registered as a data controller at the Information Commissioner’s Office (ICO) with registration number ZA006725.


If you have questions, comments or requests regarding the personal information that we use to deliver Numerise to you, or this Privacy Notice more generally, please contact Sparx’s Data Protection Officer by email at privacy@sparx.co.uk. Alternatively you can write to the Data Protection Officer, Sparx Limited, Oxygen House, Grenadier Road, Exeter, Devon EX1 3LH.

 

Information about this Privacy Notice (go to top)

This Privacy Notice is for the following user groups (Users): 

  • Those Users who create their own Numerise account (who must be at least 13 years old);
  • Those Users who create a Numerise account on behalf of another person (who is most likely to be a child under 18 years old) (supporting adults) and
  • Those Users whose supporting adult has created a Numerise account on their behalf (including Users who are under 13 years old).

This Privacy Notice was published in May 2020 and applies to the use of personal information by Sparx in connection with Numerise from May 2020. It aligns with the requirements of the Data Protection Act 2018, the General Data Protection Regulation (GDPR) and the Children’s Online Privacy Protection Act (COPPA). It is the responsibility of users of Numerise from outside the UK, EU or US to review this Privacy Notice against their local data protection regime.

In this Privacy Notice:

  • personal information is any information about a User which can identify that User. It does not include any information where the User’s identifying information has been removed (this is known as pseudonymised information); and
  • using (or any derivations of it such as use or uses) in the context of personal information includes (as applicable and without limitation) collecting, recording, organising, combining, storing, pseudonymising and deleting. 

 

How does Sparx get personal information? (go to top)

Users give Sparx personal information when they subscribe to Numerise. This is called Customer Data. Data is also generated by using Numerise. This is called Usage Data.

 

What personal information does Sparx collect? (go to top)

Customer Data provided by Users in order to set up a Numerise account or otherwise collected by Sparx in connection with Numerise includes:

  • If you are a User over 13 years old with your own Numerise account: your name, your date of birth, your country of residence, your email address and your password;
  • If you are a supporting adult: your name, your date of birth, your country of residence, your email address and your password;
  • If you are a User whose Numerise account has been created by a supporting adult (including Users who are under 13 years old): your name, your date of birth, your country of residence, your username and your password.
  • Comments and ratings that you provide to us when you respond to our requests for feedback on Numerise (but we will not attribute these to you without your agreement); and
  • Support requests, comments or questions regarding Numerise that you submit to us.

 

Usage Data collected by Sparx in connection with Numerise includes:

  • Unique identifiers, such as user IDs; 
  • Answer history and results which are used to create maths attainment profiles;
  • Use of features (e.g. videos watched);
  • When Numerise is used and the time spent using it;
  • The platform and device used to access Numerise; and
  • Website analytics, including pages viewed, links clicked and journeys through the website.

 

How is personal information used? (go to top)

Sparx uses personal information in order to provide personalised maths teaching and learning through Numerise. Our lawful bases for using personal information for this purpose are:

  • Consent: which you provide as part of our registration process; and
  • Contract: we are using your personal information in order to deliver the contract you enter into with Sparx when you subscribe to Numerise.

 

Sparx uses Customer Data and Usage Data in order to:

  • Provide personalised maths teaching and learning through Numerise;
  • Set up and administer accounts;
  • Provide technical support and deal with help requests and enquiries;
  • Build performance and progress profiles;
  • Display performance and progress information via dashboards made available to Users;
  • Send emails to Users with their own Numerise accounts, and to supporting adults, that contain performance and progress information;
  • Populate algorithms which recommend personalised maths tasks;
  • Evaluate and improve Numerise and other Sparx products and services;
  • Ensure Users are complying with the Numerise subscription terms;
  • De-identify such data through aggregation and pseudonymisation. This creates pseudonymised information which we can use for research and development and/or marketing and promotion purposes; and
  • Provide marketing information about Numerise and related products (but only with your consent).

 

Personal information will never be sold or used to market or sell non-Sparx Family products or services. Numerise does not contain any in-platform advertising or marketing.

 

Where is the personal information stored? (go to top)

The personal information that Sparx uses in connection with Numerise will be stored and used in the European Economic Area (EEA). We will only transfer your personal information outside the EEA where it is necessary for us to do so (for example, because there are no reasonable alternatives based in the EEA). Whenever we transfer your personal information out of the EEA, we ensure it is protected by appropriate safeguards. A list of the third parties with whom we share personal information in order to deliver Numerise to Users (Support Companies), including the location of their servers, can be found here. This list will be updated regularly.

 

How does Sparx share personal information? (go to top)

Personal information is shared with our Support Companies and may also be shared in the event that Sparx enters into certain types of business partnership arrangements with a third party (such as an acquisition agreement or joint venture). We may share pseudonymised information with third parties for research and development and/or marketing and promotion purposes provided that such third party agrees not to attempt to identify Users from such pseudonymised information.

 

How long is personal information stored for and what happens to it? (go to top)

Personal information is used for the duration of a User’s subscription to Numerise. When your subscription ends, personal information will be kept for a period of time in order to complete administrative and other tasks and to provide continuity of learning in case you decide to renew your subscription (although if you do not renew within one year, we cannot guarantee this continuity). When your personal information is no longer required for these purposes it will be stripped of identifying information (meaning it will no longer be possible to identify the User) and retained as pseudonymised information. Because re-identification is not possible, the pseudonymised information is not personal information and may be retained indefinitely.

 

Security of personal information at Sparx (go to top)

Sparx is committed to protecting and respecting the privacy of our Users. Sparx has appointed a Data Protection Officer who advises on, and oversees matters relating to, privacy and data security. Appropriate security measures have been put in place to prevent personal information from being lost, used or accessed in an unauthorised way. We conduct regular penetration testing to make sure that our system has robust security and have obtained a Cyber Essentials certification. We limit access to personal information to only those employees, Support Companies and other third parties who have a legitimate need for access.

 

Cookies (go to top)

In order to provide Numerise via a web browser, Sparx will place cookies on Users’ devices. Cookies are used to collect standard internet log and user behaviour information. This information is used to arrange Numerise content, ensure security, track use of Numerise and to compile statistical reports. These cookies are not used to target users of Numerise with online advertising. For further information visit www.aboutcookies.org.

 

Your rights (go to top)

Your rights in relation to your personal data are:

GDPR Data Subject Rights for Users based in the UK and EU

Data Subject Right

How Numerise caters to the Right

The right to be informed of processing

Providing a link to this Privacy Notice on our website and as part of our subscription process.

The right to access personal data by making a subject access request

Your full question history is visible in Numerise. Other personal information records may be requested by contacting Sparx’s Data Protection Officer (privacy@sparx.co.uk).

The right to rectification where personal data is inaccurate or incomplete

Personal information correction requests can be made by contacting Sparx’s Data Protection Officer (privacy@sparx.co.uk).

The right to erasure, sometimes called ‘the right to be forgotten’

Requests for erasure of Customer Data can be made by contacting Sparx’s Data Protection Officer (privacy@sparx.co.uk).

Usage Data will be retained as pseudonymised information so it is no longer considered to be personal information.

The right to the restrict processing

Data use can be restricted by ending your Numerise subscription.

The right to data portability

Not applicable as we do not integrate with any other providers of independent education products.

The right to object to processing

Data use can be stopped by ending your Numerise subscription.

The right not to be subject to a decision based solely on automatic processing

Our maths tasks are suggested based on User profiles and answer history. This is an automated process, however no significant adverse privacy effects arise from this use.

You also have the right to make a complaint at any time to the ICO regarding the use of personal information by Sparx in connection with Numerise. However, we would appreciate being given the chance to help you with your concerns before you approach the ICO, so please contact us if you have a complaint. For more information about the ICO please visit https://ico.org.uk/for-the-public/.

 

COPPA Parental Rights for Users based in the US

Parental Right

How Numerise caters to the Right

The right not to require a child under 13 years old to disclose more personal information than is reasonably necessary

Sparx follows a ‘by design’ approach to privacy matters. This includes only collecting the personal information we need from all Users (including children under 13 years old) to allow them to use Numerise.

The right to review the personal information of a child under 13 years old

Requests to exercise this Parental Right can be made by contacting Sparx’s Data Protection Officer (privacy@sparx.co.uk).

The right to direct Sparx to delete the personal information of a child under 13 years old

Requests for erasure of Customer Data relating to a child under 13 years old can be made by contacting Sparx’s Data Protection Officer (privacy@sparx.co.uk). 

Usage Data relating to a child under 13 years old will be retained as pseudonymised information so it is no longer considered to be personal information.

The right to refuse to allow Sparx to continue to collect or use the personal information of a child under 13 years old

Data use can be stopped by ending your Numerise subscription.

The right to agree to Sparx’s collection and use of the personal information of a child under 13 years old but to refuse disclosure of such personal information to third parties unless that’s part of the service

Sparx only provides personal information relating to Users (including children under 13 years old to Support Companies), all of whom are involved in the delivery of Numerise.

The procedures to follow to exercise rights relating to a child under 13 years old

Generally, requests for more information about, or to exercise, Parental Rights can be made by contacting Sparx’s Data Protection Officer (privacy@sparx.co.uk).

 

How to contact us (go to top)

If you have questions, comments or requests regarding the personal information that we use, or regarding this Privacy Notice more generally, please contact Sparx’s Data Protection Officer (privacy@sparx.co.uk). Alternatively you can write to the Data Protection Officer, Sparx Limited, Oxygen House, Grenadier Road, Exeter, Devon EX1 3LH.