Introduction

This Privacy Policy explains how we, Tassomai Ltd (company registration no. 08417700) of 601 The Pill Box 115 Coventry Road, London, E2 6GG (Tassomai) use your personal information which you provide to us.

Tassomai protects the personal information that you provide to us and is committed to complying with all relevant Data Protection Laws. We are registered with the UK Information Commissioner’s Office (ICO) as both a data processor, for the processing of data on behalf of our customers, and also, as a data controller in relation to information that we gather directly from private subscribers, job applicants and our own staff. We comply with the UK Data Protection Act 1998 (DPA), the EU General Data Protection Regulation (GDPR) as it forms part of domestic law in the United Kingdom by virtue of the European Union (Withdrawal) Act, 2018.

Queries

If you have any queries regarding this Privacy Policy, you should contact our Data Protection Officer. If you do not receive a reply within two working days, please telephone us on 0203 380 7968 and request to speak to our Data Protection Officer.

How we gather and process your Personal Information

The ways we gather your personal data are described below. Your data is used in a number of ways by us and we will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you or the school that you attend.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time: see OPTING OUT.

Potential Private Subscribers (usually Parents or Guardians)

New potential private subscribers (usually Parents or Guardians) may provide us with personal data in the following ways:

• By contacting us either via email, telephone or post. When you do this you may provide your contact details such as your email address and telephone number. Your information will then be passed to our customer team to contact you in order to assist you with your query. In the course of our assisting you with your query we may ask for your consent to use your details for further purposes such as marketing. When we do this you will be clearly advised and your specific consent will be required before we can use your information for any follow up purpose.

• By subscribing to Tassomai. When you sign up for Tassomai you will be required to provide your full name and the name of the child using the service, your email address along with the email address of your child. If you do not provide us with the requested information we will not be able to approve your application to subscribe and we will not be able to provide Tassomai to you or your child. You will also be asked to provide credit/debit card details however these are not stored by us but are held directly by our payment processor, Stripe.

When you subscribe to Tassomai we ask you to complete a form on our website which will include your full name, email address and the full name of the child who is to receive the service and their email address. This is to enable us to identify you for the purpose of providing the service to you and to enable the child to use Tassomai. If you do not provide this information to us we will not be able to approve your application to subscribe and we will not be able to provide Tassomai to you or your child.

School Accounts – Teachers and Students and Parents or Guardians of Students

When a school opens an account with us we act as a data processor and process personal information in accordance with the specific instructions of the school. The school will provide us with access via Wonde to the information we require to set up the school account. Any personal data processed by Wonde will be processed in accordance with the Wonde privacy policy. The school authorises us to obtain via Wonde the names and email addresses of those staff members which the school has nominated to participate in Tassomai, as well as the names and email addresses of students and parents and sometimes other relevant information concerning the students. This data will only be used in the normal operation of our program and will not be shared with any third parties.

In setting up Tassomai for a school, there are several ways that students provide their personal data:

Via Wonde (or similar MIS connection): If a school is using Wonde, the student names, school email addresses, parent/guardian email addresses and UPNs will be read by us from the school MIS via the Wonde interface. 

Information sent directly by the school: Alternatively, the school may share with us a list of the students they wish to set up and provide us with the student names, school email addresses and UPNs.  Schools who are not using Wonde (or another similar service) may also provide us electronically with contact details of parents or guardians of students in order to use our “Parent Reports'' facility and other parental-engagement features. 

Via connection code: Lastly, students may access Tassomai using a link or code provided by us. In this case, the student will be asked to provide personal data such as their email address and form details. 

We do not email students directly unless this is in response to a specific query or request from a student.

We will require schools to provide us with the contact details of the relevant person or people who will be responsible for managing the Tassomai account at the school. 

Job Applicants

On our website you may apply for a position in our organisation. If you decide to do so then you will be required to submit your personal details including previous employment experience and qualifications. This information is used for the specific purpose of assessing your suitability for a position in our business and you will be required to consent to the use of your personal data for this purpose. If you do not consent to our processing your data for this purpose then our ability to consider your application may be limited.

Children

We treat all personal data concerning children with the utmost protection and follow current guidance published by the Information Commissioner’s Office in relation to children including the Age Appropriate Design Code.

Private Subscriber Payment Details

The processing of all payments made through our website is undertaken either by Stripe, whose Privacy Policy you can view here, or the Apple App Store, whose Privacy Policy is here.

Algorithms

In order to develop a tailored service for users we use algorithms to help us develop learner profiles. We assess the user’s ability based on the responses to certain questions and the user’s learning programme is then tailored to that person’s ability. These algorithms do not use or rely on any personal information concerning the students.

Sharing your information

In order to enable teachers and schools to evaluate the benefits of Tassomai we may provide teachers and schools with a list of those students from the school who are using the service.

We will only share your information with third parties where this is necessary for the purposes we have described above. In order to provide our services and to operate our website we use various third parties which are carefully selected by us. All of these third parties have in place policies and procedures to ensure adherence to Data Protections Laws. We may occasionally share some good news or other promotional material on social media but if this contains any personal information at all we will only share it with the explicit consent of the individuals concerned.

There are however certain scenarios where we may have to share your data with other parties where this is required to comply with applicable laws and government or regulatory bodies' lawful requests for information. Examples of these scenarios are:

For legal reasons, we may be required to share your data with law enforcement agencies, governments, etc. This may be as part of an investigation, or it may be as part of a service such as fraud prevention.

• Where your data may be required to prevent or protect serious physical harm to an individual.

• If Tassomai is involved in an acquisition, a merger, sale of assets, or liquidation. In these circumstances appropriate undertakings would be obtained from the third party.

Security

We are committed to ensuring  the protection of your information against unauthorised access, alteration, destruction, disclosure or use. In order to ensure the level of security your information deserves, we will:

• Ensure that any data that moves across an untrusted network (such as the Internet), will be encrypted using strong methods. Unfortunately, the transmission of information via the internet cannot be guaranteed due to the scale and nature of it. We will do our best to protect your personal data, but cannot guarantee the security of your data whilst in transit to our site(s). Any transmission to us is at your own risk. Once we have received your information, we use strict procedures and security features to protect it against unauthorised access as reasonably as we can.

• Ensure that all of our staff who may come into contact with your data or the systems that process your data have sufficient knowledge and training to handle it in a confidential and secure manner.

• Ensure that we have appropriate policies and procedures in place which instructs our staff on how to handle your data securely.

• Ensuring that we minimise access to your information to only the minimal staff and systems that need it in order to perform the service we are offering you.

Opting Out

Consent to our using your personal data may be withdrawn by users of our services at any time by going to the User Settings. This will enable the user to opt out of marketing emails and other communications from us.

You may also opt out using the “unsubscribe” button in marketing emails or other emails which we may send.

Please note that where a Private Subscriber, teacher or student notifies us that we are not to use personal information which is required to perform the service then the account will be suspended or closed for that individual and that individual will not be able to access Tassomai.

Access to Personal Information

You have the right to ask us for a copy of the personal information we hold on you, a “subject access request”. You have the right to have any inaccuracies corrected or removed, or to instruct us to cease processing of your data if no longer relevant, or if there are no other legal or contractual obligations for us to do so. There is no fee for this.

Subject access requests received from children who are less than 13 years old will be referred back to the parent or guardian of the child for approval.

To request a copy of the personal data that we hold on you please send your request in writing to: dpo@tassomai.com or by post to The Data Protection Officer, Tassomai Limited, 503 The Pill Box, 115 Coventry Road, London, E2 6GG.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

How to update your information and Right to Erasure

You can review your account information by logging in and going to your settings page. Once logged in you can review and amend your details at any time.

If you would like us to erase all of the personal data that we hold on you then you can do so by contacting our Data Protection Officer: dpo@tassomai.com or by post to The Data Protection Officer, Tassomai Limited, 601 The Pill Box, 115 Coventry Road, London, E2 6GG.

Please note that if you ask us to delete your personal information then you will not be able to access Tassomai.

Data Retention

We hold your data only for as long as is necessary for the specified purpose.

Tassomai offers a personalised service, and in order to be able to offer this same service to users who have taken a break and wish to re-subscribe, we store users' data for a limited time after their course subscription has expired:

• Students: - information obtained from students is stored for two years after either (i) the subscription ends or (ii) the account is closed or cancelled.

• Teachers: - information is held for a period of two years after the account is closed. This is in order to deal with any follow-up queries or to enable an account renewal or re-subscription.

• Parents/Guardians: - information obtained from parents is stored for two years after either (i) the subscription ends or (ii) the account is closed or cancelled.

• Tassomai job applicants: - personal data held about job applicants is held for a maximum of one year.

We may also collect some personal information as part of our marketing activity and mailing list development when, for example, an individual chooses to download content we have created or opts in to a particular mailing list. These individuals may or may not be users of our program. In such cases we always ask for their consent to contact them about our services before storing or processing their contact details.  They will also always be given the option to opt out of any further communications we send them and their personal data will only be retained until that point.

We will also remove personal information, within a reasonable time frame, on the request of the user. The user should be aware however, that if this happens, and if they subsequently decide to re-subscribe, then all the personalised academic information generated by our system that had previously been accrued will not be able to be re-applied and their progress will be reset.

International Transfers

Like many businesses we may use a third party located outside the United Kingdom (“UK”) to help us provide our services. The data that we collect from you may in some cases be transferred to, or stored at, a destination outside the UK. It may also be processed by staff operating outside the UK who work for us or for one of our suppliers.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and Data Protection Laws. Where it is necessary to process data outside the UK  we ensure that the relevant third party processing the data is located in a country in respect of which the UK has granted an adequacy decision or has provided the required contractual undertakings as specified by law.

Cookies Policy

We may collect information about your computer, including where available your IP address, operating system and browser type using cookies. This information is used for system administration and/or dynamic adjustments of page layouts to improve your experience on our site, as well as to help us with marketing and advertising.

A “cookie” is a small piece of text that is sent by a site you visit and stored in your web browser. Cookies may enable the service or third party to recognise you and make your next visit easier, and the service more useful to you by giving you tailored options based on the information it has stored about your last visit, or it can be used to save display preferences between visits.

Cookies can be persistent or session cookies. When you use and access this site, we may place a number of cookie files in your web browser.

For a full list of cookies we use, please see the table here.

If you do not want us to use cookies in your browser, you can normally set your browser to reject cookies or to tell you when a website tries to put a cookie on your computer. Please note though that if you delete cookies or refuse to accept them, you may not be able to use all the features our website offers. You may not be able to store your preferences, and some of our pages might not display properly. You may also be prompted for the same information several times.

For information about cookies and how to disable them in your browser please visit the AboutCookies website.

Updates

We may make changes to our Privacy Policy in the future. Any updates or changes will be posted on this page.

Version 3.1.0 - March 2023