PRIVACY AND DATA PROTECTION POLICY

General Information
Mini-Engineers Limited (“we” or “us”) take the privacy of your information very seriously. Our Privacy Policy is designed to tell you, the user of our services about our practices regarding the collection, use and disclosure of personal information which may be provided to us via our websites, associated apps and other digital products we provide or collected through other means such as an in person, an online form, email, or telephone communication. This policy applies to information provided by individuals whose data we hold, whether or not they have booked a course with us. In this policy “you” refers to any individual whose personal data we hold or process (other than our instructors or staff).  In this policy, references to the “Site” are references to any website, app or other means by which you provide personal data to us or access our services.   This policy is governed by the EU General Data Protection Regulation (the “GDPR”).


On what basis do we process personal data?
Personal data we hold about you will be processed either because:
  • you have consented to the processing for the specific purposes described in this policy (for instance in relation to health or medical information);
  • the processing is necessary in order for us to comply with our obligations under a contract between you and us; or
  • the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security.
 
What personal data do we collect?
We may collect and process the following personal data (information that can be uniquely identified with you) about you:
  • Login Information:  log-in details and information you provide when setting up an account on our Site, such as your name and email address (“Login Information”);
  • Contact Information: information we collect from you; for example, your name, address, telephone number, email address (“Contact Information”);
  • Booking Information:  information we collect which relates to courses, sessions or parties you have booked with us (“Booking Information”);
  • Payment Information:  information provided to us relating to payment including credit or debit card details (“Payment Information”);
  • Communication Information: a record and details of any correspondence or communication between you and us or relating to any complaint submitted to us (“Communication Information”);
  • Technical Information:  details of your visits to the Site, the resources and pages that you access and any searches you make (“Technical Information”).
You do not have to supply any personal information to us but the Site may not be operable without providing data to us. In particular, we will not be able to fulfil an order without collecting some personal data from you.  You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time but we will be entitled to complete any orders we are then processing and we may need to withhold some personal data for legal or other reasons (see below).
 

Sensitive Information
Other than relevant medical or health information about a child who is booked to attend a course, session or party, we will not collect any sensitive personal data about you or your child without your prior consent.  By sensitive personal data we mean data which falls within certain ‘special categories’ which are defined in the GDPR (e.g. health data) and which require additional protection and consent measures.

If we become aware of a relevant medical or health issue we may record this and take appropriate steps in order to protect the child concerned, other children or our staff. When we collect health or medical information from you, we will request your consent to process this data in accordance with this policy. You are not required to give your consent, but we may be unable to accept a booking without your consent.
 

Processing your personal data
We collect and process your personal data for a variety of reasons.  The types of data we will collect and process include Login Information, Contact Information, Booking Information, Payment Information, Communication Information and Technical Information.  We process this data to perform a contract with you, to comply with legal obligations and for our legitimate interests, which include the following:
  • When you register with the Site and or when you update/amend your details with us:  to obtain necessary information in order to provide our services;
  • When we deliver a course, session or party to you or your child:  for running our business and to provide you with services requested;
  • When you seek to cancel or change a booking with us:  for running our business and to provide you with services requested and to fulfil our statutory obligations;
  • To manage our relationship with you which will include (i) notifying you about changes to our terms or privacy policy, (ii) asking you to leave a review or take a survey and (iii) when you submit a complaint:  to keep our records updated and to study how users use the services we provide;
  • To administer and protect our business, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data:  for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation;
  • To use data analytics to improve the Site, services, marketing, customer relationships and experiences: to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.

How long do we retain your data?
Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:
  • Records relevant for tax purposes:  eight years from the end of the tax year to which the records relate;
  • Personal data processed in relation to service:  seven years from either the end of the contract or the date you last used our services or placed an order with us, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim;
  • Personal data held on marketing or business development records:  three years from the last date on which a data subject has interacted with us.
For any category of personal data not specifically defined in this policy, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be seven years from the date of receipt by us of that data. The retention periods stated in this policy can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).  We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.  If you wish to request that data we hold about you is amended or deleted, please refer to section "What are your Privacy Rights?".


Who do we share your information with?
We do not disclose any personal data you provide to any third parties other than as follows:
  • If you purchase a course, session or party delivered by one of our instructors, information may be provided to that instructor in order for them to deliver our services;
  • We may host personal data with third party hosting partners;
  • Certain third party suppliers including technical support providers may have access to personal data;
  • Where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal data itself) may be transferred to interested third parties;
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
  • In order to enforce any terms and conditions or agreements for our services that may apply;
  • We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
  • To protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this policy.


Use of Cookies                       
A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our Site.  On our Site, we use cookies to track users' progress, allowing us to make improvements based on usage data. We also use cookies if you log in to one of our online services to enable you to remain logged in to that service. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service.  Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browse settings you should go to your advanced preferences.

We are required to obtain your consent to use cookies. If you continue to use the Site, having seen this policy, then we assume you are happy for us to use cookies.  If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Site. However, you will not be able to make full use of our online services.

An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.


Security
We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
  • protecting our servers by both hardware and software firewalls;
  • locating our data processing storage facilities in secure locations;
  • encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
  • when necessary, disposing of or deleting your data so it is done so securely;
  • regularly backing up and encrypting all data we hold.
We will ensure that our instructors and employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.  This policy and our procedures for handling personal data will be reviewed as necessary.  Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use the strict procedures and security features referred to in this clause to try to prevent unauthorised access.
 

What are your privacy rights?
The GDPR gives you the following rights in respect of personal data we hold about you:
  • Right to be informed:  You have a right to know about our personal data protection and data processing activities, details of which are contained in this policy;
  • Right of access:  You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below;
  • Right to correction:  Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information;
  • Right to erasure (“right to be forgotten”):  Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible.  We will communicate the erasure to any third parties to whom we have passed the same information;
  • Right to restrict processing:  You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data;
  • Right to data portability:  You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible);
  • Right to object:  Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted. You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing, unless we have overriding legitimate grounds;
  • Right to withdraw consent:  If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).
All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to Mini-Engineers Limited, 1 Filament Walk, Studio 402, The Light Bulb, London SW18 4GQ or via email  letsbuild@mini-engineers.com   We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).


What we will do in the case of a data breach
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO). If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.


Other websites
Our Site may contain links and references to other websites. Please be aware that this policy does not apply to those websites.  We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.  In addition, if you came to this Site via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.


Transferring your information outside Europe
As part of the services provided to you the information you provide to us may be transferred to, processed and stored at, countries or international organisations outside of the EEA.  We will not transfer the personal data of EEA customers in a systematic way outside of the EEA but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
  • If you use our Site while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services;
  • We may communicate with individuals or organisations outside of the EEA in delivering our services, those communications may include personal information (such as contact information) for example you may be outside of the EEA when we communicate with you;
  • From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).
If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this policy. If you would like to obtain details of the safeguards we have put in place then please contact us at: Mini-Engineers Limited, 1 Filament Walk, Studio 402, The Light Bulb, London SW18 4GQ  or via email -  letsbuild@mini-engineers.com


Changes to this privacy policy
We will post details of any changes to our policy on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.


Getting in touch
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: Mini-Engineers Limited, 1 Filament Walk, Studio 402, The Light Bulb, London SW18 4GQ or via email - letsbuild@mini-engineers.com  If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.

May 2018