Arc Pathway Limited Privacy Policy
Our Privacy Notice
Arc Pathway is committed to protecting the privacy of your personal information. We have written this Privacy Notice to let you know how Arc Pathway uses your personal data. In this notice you will find information about the types of personal data we collect from you, when we collect your personal data and how long we keep it for, how we collect your personal data, our reasons for collecting and using your personal data, and information about how we share your personal data. When we say "we", "us", or "our" in this Privacy Notice, we mean Arc Pathway.
Please take a moment to review this Privacy Notice in detail to understand our views and practices regarding your personal data and how we will treat it.
Any changes to this Privacy Notice will be communicated on www.arcpathway.com and, unless stated otherwise, will take effect immediately once posted.
For the purpose of applicable data protection laws, the Controller is Arc Pathway Limited and you can contact us using the following contact information:
Arc Pathway Limited
4th Floor
58-59 Great Marlborough Street,
London
W1F 7JY
T: +44 (0) 20 8080 2727
Privacy Notice last updated on 19th Februay 2024
What personal data do you collect from me and use?
We collect, store, and use the following categories and types of data which identifies you or which can be used to identify you when you enquire about our software:
- Identification data – this is limited to your name, business or personal email address, business address and telephone number;
- Information about your job, such as your position, title, management level, work location, department, and position level; and
- Information collected through Cookies – this may include, IP address, location and time zone setting, operating system and platform, browser plug-in types, domain name and your choice of browser. Please see our Cookie Policy for further information.
Arc Pathway does process other personal information (e.g. Child's Name, School, Region, Teacher Name, Teacher's Business Contact Information, Child's Performance/ Analytics & Children's Media - Photo/ Videos, Parent’s Contact Information); however this is in its capacity as Processor for which the relevant entity (e.g. school) is the Controller.
When do you collect my personal data?
We collect your personal data:
- when you visit any of our websites and agree to the use of cookies, or where you use our contact functionality on the websites;
- when you sign up to receive marketing information or other communications from us via our website;
- when you report an issue, ask us a question, or email us with feedback; and
- when you use our products and services.
In most cases you provide your personal data directly to us via our website. However, we may collect some usage data automatically when you browse our website.
What activities do you carry out using my personal data – “processing activities”?
We use your personal data in order to carry out the following Processing Activities:
- provide you with information about our products and services;
- help you to complete a transaction or order;
- provide you with support or education about our products and services;
- communicate with you;
- improve your experience when using our websites; and
- comply with our business, regulatory and legal obligations.
Why do you carry out these processing activities using my personal data?
Some of the laws that apply to us require us to tell you the legal reason for using your personal data. We list these below:
- Consent - Where applicable and appropriate, we will ask for your consent to collect and use your personal data. If we need your consent to collect and use your personal data we will make clear to you that the provision of your consent is voluntary. You have the right to withdraw your consent at any time by contacting us using the contact information set out above.
- Our Core Activities - In many cases using your personal data is core to our legitimate business interests. Where we use your personal data for these purposes you will have the right to object to our use of your personal data by contacting us using the contact information set out above.
We use your personal data for our legitimate interests to provide you with information about our products and services and to understand your use of our website, products, and/or services. We use information collected via cookies (electronic text files) that we place on to your machine in order to provide you with the best level of service when using our tools. These analytics tell us whether you had technical difficulties when using our website or to provide you with a service that is tailored to you. Our Cookie Policy provides you with more information about our use of cookies.
- Carry out a contractual relationship – We may process your personal data where necessary to perform our obligations in accordance with any contract that we may have with you.
- Legal Obligation - At times we may receive requests from Regulators or other authorised bodies to use your personal data in order to comply with a legal or regulatory obligation. Where this is the case, we will ensure that the request is legitimate.
For how long do you keep my personal data?
We keep your personal data for no longer than is necessary for the purpose for which the information is collected and to manage our relationship with you. Where personal data is kept, that period will be determined based on applicable local law. For further information, please contact us as set out above.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you), or receive anonymised personal data for research or statistical purposes, in which case we may use this information indefinitely without giving further notice to you.
Your rights in relation to your personal data
We explain here the rights that you may have in relation to personal data if you live in the UK or European Union.
Note the rights are only applicable to data we process as Controller (as set out above in ‘What personal data do you collect from me and use’). For data we process as a Processor you would need to contact the relevant Controller for that data (e.g. the School in respect of information on the software).
How can I find out what personal data you hold about me?
You may contact us using the contact information above if you would like more detailed information about what personal data we have collected from you, including the categories of personal data processed, the purposes of the processing and the third-parties to whom that data is transferred. You may also request a copy of your data. Note that we do have to consider the interests of others, and certain other legal obligations and restrictions, so this is not an absolute right.
Can I ask you to correct or delete my personal data?
You may contact us using the contact information above if you would like us to delete your personal data or to have your personal data corrected and, if required to do so, we will comply with your request.
Can I ask you to stop using my personal data?
You may contact us using the contact information above if you would like us to stop using your personal data (either entirely or for some of our Processing Activities) and, if required to do so, we will comply with your request.
Can I ask you to transfer my personal data to a Third-Party?
You may contact us using the contact information above if you would like us to transfer your personal data to a third party in a structured, commonly used, and machine-readable format and, if required to do so, we will comply with your request.
Do you securely store my personal data?
We apply strict security standards, controls, and processes to protect your personal data from unauthorised access, loss, or accidental deletion. These include restricting who can have access to your personal data and protecting your data with security tools appropriate to the type of information e.g. encryption software. We also require that our third-party Processors who handle your personal data do the same.
Do you use Cookies?
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that Cookie. Cookies are useful because they allow a website to recognise a user’s device. Cookies allow you to navigate between pages efficiently, remembering your preferences and generally improving the user experience.
Our Cookie Policy provides you with more information about our use of Cookies.
Do you share my personal data with Third Parties?
To help us carry out our Processing Activities, we may need to share your personal data with entities outside of Arc Pathway as follows:
Our Processors – from time to time, we may share your personal data with our third-party service providers who provide us with legal, regulatory, corporate advisory, banking, accountancy, insurance, marketing, communication and/or IT support services ("Data Processors"). In order to provide such services, our Processors process your personal data on our behalf. Our Processors have met our criteria as trusted guardians of personal data and are subject to contractual obligations to implement appropriate security measures to safeguard your personal data and to process personal data only as instructed by us.
Other Third-Parties – your personal data may also be transferred to Regulators, and other Authorities (e.g. tax and law enforcement authorities) and independent external advisors (e.g. lawyers, auditors).
For the full list of Processors and other third parties that we may share your data with, please contact us as set out above.
We do not sell the personal information we collect from you.
Do you transfer my personal data overseas?
We do not transfer your personal data outside the European Economic Area (EEA) or the United Kingdom (UK).
What should I do if I am not happy with how my information is being used?
If you have any concerns about our use of your personal data, you can make a complaint to us at dpo@arcpathway.com.
You also have the right to complain to our relevant Supervisory Authority, which is the Information Commissioner’s Officer (ICO) in the UK, who is responsible for ensuring we correctly follow the law or to any other competent data protection Supervisory Authority. You can contact the ICO at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Contact details of other European data protection Supervisory Authorities can be found here: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080