Smile4Kids | PRIVACY POLICYS

The following document explains how Smile 4 Kids Ltd. uses, processes and protects personal data collected via our website. We therefore request you to carefully read the following Privacy Policy as you will be legally bound by its terms whenever you visit our website or when you provide any personal data about yourself or about your children.

Reference to a “child” in this Policy means anyone under the age of 18. This is in accordance with the UN Convention on the Rights of the Child.

Reference to “parental responsibility” in this Policy, means someone, who according to the law in the child’s country of residence, has the legal rights and responsibilities for a child that are normally afforded to parents.

Background

Smile 4 Kids Ltd. (“Smile 4 Kids”, “The Company”, “we”, “us”) value and respect the privacy of those who visit our website or provide information and personal data to us for the purposes of availing our services and/or for carrying out any other business or dealings with us.

This Privacy Policy (“the Policy”) provides information on how we collect information relating to our students and other persons or organisations that visit our website or who we deal with for the purposes of carrying out our business. It should be read in conjunction with the Terms and Conditions that we may have issued to you, other policies on our website and with the information contained in the Register of Fee Payers published electronically by the Office of the Information Commissioner (“ICO”).

Who we are

For the purposes of the Data Protection Act 2018 (“the DPA”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (“the GDPR”), the data controller in respect of any personal data submitted by you will be Smile 4 Kids Ltd. which is a private limited company incorporated under the laws of England and Wales and registered at the Companies House under number 11651695. Our registered office address is 171 Homesdale Road, Bromley, England, BR1 2QL.

Who is the person responsible for the management of your data?

We are registered with the Information Commissioner’s Office (ICO) under registration number ZA760453.

The Person responsible for data protection is Mrs. Sarwarinder Sidhu Saran (Safrina Saran). For any queries relating to the management of your personal data please do not hesitate to send us an email at sfs-3662001@yahoo.com.

What personal data do we need/receive?

“Personal Data” has been defined under the GDPR as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

Any references to “personal data” in this Policy therefore means information about living individuals, which, alone or in conjunction with other information held by us is capable of identifying them. The DPA and the GDPR regulate our use of your personal data.

In order to provide our services or for the purposes of conducting our business we may need the following data from the individuals we are dealing with:

(We have tried to cover categories of data that we generally require while providing services to our clients/students or for operating our business. However, this is not an exhaustive list)

Name(s) of the individual(s)
Their physical and electronic addresses
Their phone number
cFor employment purposes National Insurance Number

What personal data do we collect, hold and share relating to our students?

When enrolling your child for our courses or when making a booking for a class, we may collect the following information (without limitation), relating to you and/or your child being enrolled as a student:

Name, date of birth, gender
Contact details such as postal address, telephone number, email address
Any medical conditions or disabilities that we should be aware of
Any behavioural problems that we should be aware of
Any Special Education Needs (SEN) that we must be aware of
Ethnic background and languages spoken, or knowledge of languages possessed by the student
Details about the student’s designated emergency contact
Images and videos of students strictly subject to express parental consent for the purposes of marketing and promotion.

What personal data relating to our students do we hold for our records?

For the purposes of our records, internal use and for the purposes of assessing a student’s progress we hold the following information (without limitation), relating to our students:

Name and contact details of the student
The student’s unique student/pupil number
Any Special Education Needs or any medical conditions so that we may be able to make certain adjustments to our classes in order to cater to students with Special Education Needs
Any video recordings of classes for the purposes of internal staff training

Sources of personal data

We may obtain your/your child’s personal data from you when you contact us or get in touch with us via our website, email, telephone or through any means of communication. This includes personal data you provide to us when you:

Contact us with a question or query
Ask us to provide our services to you/your child
Ask us to collaborate with you on any assignment
Contact us or authorise anyone to contact us about employment or apprenticeships at Smile 4 Kids
Contact us to provide us your services or goods
Correspond with us to submit any complaints that you may have
Correspond with us to address any complaints we may have raised
Register for a seminar, event where information is shared between fellow members
Register for a seminar, event where information is shared between fellow members
Register to receive updates and newsletters
Attend events and provide our staff with your contact details
Connect with us on social media platforms.

What are the purposes for gathering and processing personal data?

We may gather and use your/your child’s personal data for the following purposes, including but not limited to.

Providing teaching services and supporting student learning
Monitoring student progress
Internal staff training
Assessing the quality of our services and making improvements to our services
Providing you updates about upcoming courses, events and activities
If you have opted to receive newsletters and other marketing related communication from us, to send such communication to you (We will retain your personal data for these purposes until you opt-out of receiving our newsletters and/or other forms of marketing related communication)
Compliance and due diligence
Inviting you to organised events, seminars and webinars. (We will retain and use this information until such time you expressly opt-out of being contacted for receiving invitations and updates about organised events).
Social media- We may gather certain personal data in relation to you as a result of being connected with you on social media platforms such as LinkedIn, Instagram, Facebook, Twitter and other similar platforms. You may at any given point in time discontinue your connection with us on social media platforms.

Analytics

We use cookies and analytics tools (described in further detail below) to monitor and analyse user website activities, including but not limited to page views, location of access and sources and time spent on the website. This information is depersonalised and is displayed as numbers. This information cannot be traced back to individuals. This therefore ensures your privacy.

Internal data analysis

Where we have obtained personal data for any of the purposes set out in this Policy, we may use it in connection with internal data analysis and also for any of the other purposes set out in this Policy. This does not affect your legal right to object to the use of your data for direct marketing purposes.

Personal data we may obtain from our website about our web visitors

We may automatically collect the following information, which may or may not be personal data, in relation to anyone visiting our website:

IP addresses (static or dynamic) and other technical information relating to the virtual or physical location of a visitor and their means of access, including browser information, time zone settings and hardware information
How visitors use the website, including dates and times and any details of how and for what duration particular resources are viewed or used; and
Clickstream data, including where users navigate to our site to and from and any searches users make on or relating to our website.

We will use this data to:

If anyone makes an allegation of child abuse against a member of staff:

Run our website and ensure it works properly
Improve how we present the information on it and make browsing easier and more productive
Maintain the site’s security and that of our visitors

Cookies

Cookies are small text files that are downloaded to your device by websites you visit. Currently our website uses required/necessary cookies that enable you to navigate our website and use its features, such as accessing secure areas of the website. Since required cookies are essential to operate the website there is no option to opt out of these cookies.

We may also use certain functionality cookies and web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. The information that the cookies collect, such as the number of visitors to the site, the pages visited and the length of time spent on the site, may be aggregated and will therefore be anonymous.

We may embed certain videos from our YouTube or other video channels that may drop or set up their own or third party cookies to enable you to play the videos and to collect certain analytics data such as for how long the viewer has watched the video. These cookies do not track individuals.

We don’t use cookies in a way that allows us to identify site users.

You may refuse the use of cookies or withdraw your consent at any time by selecting the appropriate settings on your browser. However, this may prevent you from accessing all of our website.

Lawful basis for processing your personal data

The following is the lawful basis for processing your/your child’s personal data:

Consent- In order that we can provide our courses and teaching services to students, you consent to us obtaining and processing your/your child’s personal data. By enrolling into or by enrolling your child into our courses you consent to your/your child’s personal data being collected, used and processed by us.
Contractual necessity- One of the grounds for obtaining and processing your/your child’s personal data is so that we can perform the services you have signed up for. However, we will always obtain your consent before we (i) take any photographs/videos of you/your child, (ii) use any personal data for promotional activities and/or (iii) add you to our newsletter.
Compliance with legal obligations- We may have to collect personal data in order to comply with certain legislative and regulatory requirements.
Legitimate interests- We may process your/your child’s personal data to promote the legitimate interests our business as well to promote and pursue the legitimate interests of our students such as their safety and well-being.

Who do we share your personal data with?

Your/your child’s personal data may be received by:

Smile 4 Kids and its staff who need to receive your/your child’s personal data in order to provide services to you/your child or to carry out the administration of business
Any local authorities or government bodies to whom the information may need to be submitted
Any regulatory authorities regulating us
Any external agencies that support children learning, especially for children with Special Education Needs. (You will however always be informed and unless the law requires us to do so we will not share such personal information without your prior consent)
Certain personal information collected for the use of marketing purposes may be shared on our website and social media platforms. (This will however be strictly subject to your/your child’s express consent).
Any other party you may instruct us to share your/your child’s personal data with.
Any other organisation who may take over the business of Smile 4 Kids either by purchasing it or by way of a merger or in the event of any catastrophic circumstances by reason of which new management has to continue Smile 4 Kids’ business.

We do not share our students’ personal data with anyone without prior express consent unless the law and our policies allow us to do so.

Transfer of personal data to international organisations or countries outside the United Kingdom

While providing services we may have to collect or provide information including personal data from or to third parties located in territories outside of the United Kingdom.

Where we collect personal data from students/individuals located in the EU we will try our best to ensure that such personal data is granted the same level of protection as it would enjoy in the EU.

Where we transfer personal data to third parties outside of the UK or the EU, we will ensure that the recipients are aware of the provisions of the DPA and the GDPR respectively and provide an adequate level of protection for the rights of persons whose personal data has been shared with them.

In addition, all our inbound and outbound email communications are TSL (Transport Security Layer) encrypted.

Retention of personal data

Any personal data will be retained by us for the duration as will be deemed necessary by us for the purposes of providing further services, marketing or growing our business, such duration not being less than (3) three years from the date on which data was first gathered.

Hosting and back-end infrastructure

We use third-party hosting services for the purposes of hosting data and files that enable our website to run and be distributed as well as to enable us to run specific features and functions within our website. Some of these functions work through geographically distributed servers, thereby making it difficult to identify the exact location where the personal data is stored.

What are your rights with respect to your personal data?

Under the DPA, you have the following rights in relation to your own/your child’s personal data:

to prevent us from using your/your child’s data for direct marketing
to have (in certain circumstances) inaccurate personal data corrected, blocked or destroyed
to access a copy of the information that we hold about you/your child or that is undergoing processing (“subject access rights”)
to object to automated decisions. We do not, however, use automated decision making
the right to withdraw consent from us continuing to process your personal data; and
a right to object to processing that is likely to cause or is causing damage or distress.

If you want to (1) tell us to stop using your/your child’s data for direct marketing or withdraw consent from us processing your/your child’s personal data for any of the purposes mentioned in this Policy; (2) exercise your subject access rights; (3) tell us about inaccurate personal data you think we hold on you; or (4) object to a use you believe we’re making of your data which is causing, or is likely to cause, damage or distress, please contact Mrs. Safrina Saran or write to us at this address:

The Data Protection Manager (Mrs. Safrina Saran)
Smile 4 Kids Ltd
171 Homesdale Road
Bromley, England
BR1 2QL

Unless the law permits us to do so, we will not charge you to exercise your subject access rights but may charge a reasonable fee reflecting our administrative costs should you request further copies of the personal data. When you contact us to exercise any of the above rights, we will first ensure that the person requesting the data is the person whose data is being sought (or that it is being requested on that person’s behalf). This may involve providing us with proof of your identity or your authority to act for the data subject. We may also ask you for any information we need to help us find the personal data you’re enquiring about.

We will also provide you with the following information relating to your personal data:

the purpose for which we’re processing it
what categories of data about you we process
the recipients of your data, if any, including specifically international or foreign organisations
our expected retention period or how we’ll calculate this, if we don’t know yet
your rights in relation to the data; and
the source of the data, if we didn’t get it from you.

Should you contact us in relation to us holding incorrect, incomplete or inaccurate data about you, we will make the required corrections promptly.

Right to lodge a complaint

If you are unhappy with the way, we are processing your personal data you can lodge a complaint by writing to Mrs. Safrina Sidhu Saran at sfs-3662001@yahoo.com or by sending your complaint to:

The Data Protection Manager (Mrs. Safrina Sidhu Saran)
Smile 4 Kids Ltd
171 Homesdale Road
Bromley, England
BR1 2QL

You are also entitled to make a complaint at the Information Commissioner’s Office (ICO).

Variations to this Policy

We may update this Policy from time to time. We reserve the right to alter and make changes to this Policy at our sole discretion and we therefore request all users to regularly refer to our Privacy Policy for updates and variations.