Privacy Policy

Introduction

Play Virtuoso Group Ltd (PLAYvirtuoso) respects your privacy and is committed to protecting your personal data.

This privacy notice contains information about who we are and how and why we collect, store, use, and share your personal data when you interact with us.

When we collect, use, or share your data, we are subject to applicable data protection laws including the General Data Protection Regulation, and are responsible for that personal data as a data controller. This notice will also inform you about your privacy rights and how the law protects you. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Changes to the Privacy Notice and Your Data

This version was published on 21.07.2021 and last updated on 17.07.2024. We may change this privacy notice from time to time and we will inform you when those changes may materially affect you.

The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1. Important information and who we are

Data controller

Where we refer to “we”, “us” or “our” in this privacy notice, we are referring to PLAYvirtuoso, as the legal entity that is responsible for processing your personal data.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below:

Play Virtuoso Group Limited
Ruskin Chambers
Drury Lane
Knutsford
Cheshire
WA16 6HA
Email: [email protected]

You can contact us directly to resolve any query or concern you might have about our use of your personal data. In most cases, you will find that contacting us resolves the matter promptly however you also 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).

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped follows:

  • Identity Data which allows us to identify you including your name, title, and date of birth. On occasion, this can also include a form of identification such as a driving license or passport if supplied to us.
  • Contact Data including postal address, email address, and telephone numbers.
  • Financial Data including bank account and payment and credit card details enable us to process your payments.
  • Transaction Data including historical transactions for services from us.
  • Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting, and the general location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. This also includes your username and password for our client portal.
  • Usage Data including information about how you use our website and services including your service preferences and any feedback
  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  1. Direct interactions

    You may give us your Identity, Contact, and Financial Data by filling in forms and signing documents, dealing with our tutors, or corresponding with us by post, phone, email, or our website. This includes personal data you provide when you:

    • enquire about, request, or order our services;
    • access and receive our services or attend one of our events or talks;
    • create an account on our website;
    • subscribe to our emails or notifications;
    • request marketing to be sent to you;
    • enter a competition, promotion, or survey; or
    • give us some feedback.
  2. Automated technologies or interactions

    As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites that employ our cookies. Please see below for more details about cookies.

  3. Third parties or publicly available sources.

    We may receive personal data about you from various third parties set out below:

    • Identity Data from Partners, awarding organisations, schools, or teachers to provide you with information about the services we offer;
    • Technical Data from our IT providers, analytics providers, and search information providers;
    • Contact, Financial, and Transaction Data from providers of technical and payment services;

4. How we use your data

We will only use your data when the law allows us to. Most commonly, we will use your data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • If you are a student or are under the age of 18, we ask the person with parental responsibility for you for their consent for the processing of your data. We will rely upon this consent as our legal basis for processing your data where (i) you are under the age of 13; or (ii) you are 13 or over and notify us that you withdraw or amend our right to process your data.

We have set out below, a description of the ways we plan to use your data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose / Activity Type of personal data Lawful basis for processing including basis of legitimate interest
To register your details as a customer, a candidate, or contact (whether via our website, a paper form, by phone, email, or otherwise). (a) Identity
(b) Contact
(c) Financial		 Performance of a contract with you
To process your order:
Manage and collect payments and fees;
To mark your assessments.
To issue certificates
To issue assessment certifications		 (a) Identity
(b) Contact
(c) Financial		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to collect payment for our services)
To notify parents/legal guardians and schools to report on:
Assessment entries
Results
News and information which affects or is specific to your child’s learning		 (a) Identity
(b) Contact
(c) Financial		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests
To enable you to partake in a promotion or complete a survey (a) Identity
(b) Contact
(c) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud
(b) Necessary to comply with a legal obligation
To use data analytics and automated profiling to improve our website, products/services, marketing, customer relationships, and experiences (a) Technical
(b) Usage		 Necessary for our legitimate interests (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)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage		 Necessary for our legitimate interests (to develop our products/services and grow our business)

PLAYvirtuoso marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or used our services or if you provided us with your details when you have opted in to receive that marketing.

We will get your express opt-in consent before we share your personal data with any company for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us using the details set out at the start of this privacy notice.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the use of our services.

Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. By continuing to browse the site, you are agreeing to our use of cookies.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to checkout and make payments to us online.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited, and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that in some cases, trusted third parties (including, for example, advertising networks and providers of external services like web traffic analysis services – like Google Analytics) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use employing cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Change of purpose

We will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Third-party Links

We may include links to third-party websites, plug-ins, and applications to make your experience on our website seamless. For example, we may allow you to connect with your social media network through third-party platforms such as partner sites, Twitter, Instagram, or Facebook. Clicking on those links or enabling those connections may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements. Those sites may also set cookies over which we have no control, and which are subject to the cookie policies of the relevant third-party platform. When you leave our website, we encourage you to read the privacy notice and cookie notice of every website you visit.

6. Sharing your personal data

We routinely share personal information with:

  • third parties partners who help deliver our services to you – e.g. schools, industry partners, payment service providers, examination boards, awarding organisations, certificate printing partners, UCAS, and examination regulators;
  • third parties approved by you – e.g. social media sites you choose to link your account to, third-party payment providers.
  • Our service providers who provide IT and system administration services;
  • Professional Advisors acting as processors or joint controllers: examiners, quality assurance examiners, banks, auditors, insurers, solicitors, and other providers of professional services;
  • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances;

We require all third parties to respect the security of your data and to treat it in accordance with the law. We do not allow our third-party service providers to use your data for their own purposes and only permit them to process your data for specified purposes and by our instructions.

We also make use of Visitor Action Pixels from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on this website.

This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter of GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data to display Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads. Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

Your personal data may be held at our office and at the locations of those third parties set out above. This includes personal data held on our IT systems. We do not transfer your data outside the European Economic Area (EEA).

We will only retain your data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data, and whether we can achieve those purposes through other means, and the applicable legal requirements. Some data may be retained for legal (including tax) reasons for a period exceeding that which we require for our business purposes.

In some circumstances, we may anonymise your data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws concerning your data.

You have the right to:

  • Request access to your data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request the erasure of your data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your data. This enables you to ask us to suspend the processing of your data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have to override legitimate grounds to use it.
  • Request the transfer of your data to you or a third party. We will provide to you, or a third party you have chosen, your data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details set out at the start of this privacy notice.

You will not have to pay a fee to access your data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.

We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Glossary

Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your data for our legitimate interests. We do not use your data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.