1. Definitions
For the purposes of this Privacy Policy:
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Account means a unique account created for You to access our Service or parts
of our
Service.
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Affiliate means an entity that controls, is controlled by or is under common
control with a party, where "control" means ownership of 50% or more of the shares,
equity interest or other securities entitled to vote for election of directors or
other managing authority.
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Application refers to sqillup, the software program provided by the
Company.
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Company (referred to as either "the Company", "We", "Us" or "Our" in this
Agreement) refers to Nuvay Private Ltd, 6 Diamond Road Ruislip HA4 0PG.
For the purpose of the GDPR, the Company is the Data Controller.
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Cookies are small files that are placed on Your computer, mobile device or
any other device by a website, containing the details of Your browsing history on
that website among its many uses.
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Country refers to: United Kingdom
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Data Controller, for the purposes of the GDPR (General Data Protection
Regulation), refers to the Company as the legal person which alone or jointly with
others determines the purposes and means of the processing of Personal Data.
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Device means any device that can access the Service such as a computer, a
cellphone or a digital tablet.
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GDPR refers to EU General Data Protection Regulation.
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Personal Data is any information that relates to an identified or
identifiable individual.
For the purposes of GDPR, Personal Data means any information relating to You such
as a name, an identification number, location data, online identifier or to one or
more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity.
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Service refers to the Application or the Website or both.
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Service Provider means any natural or legal person who processes the data on
behalf of the Company. It refers to third-party companies or individuals employed by
the Company to facilitate the Service, to provide the Service on behalf of the
Company, to perform services related to the Service or to assist the Company in
analyzing how the Service is used. For the purpose of the GDPR, Service Providers
are considered Data Processors.
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Usage Data refers to data collected automatically, either generated by the
use of the Service or from the Service infrastructure itself (for example, the
duration of a page visit).
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Website refers to sqillup, accessible from https://sqillup.co.uk/
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You means the individual accessing or using the Service, or the company, or
other legal entity on behalf of which such individual is accessing or using the
Service, as applicable.
Under GDPR, You can be referred to as the Data Subject or as the User as you are the
individual using the Service.
2. Who are we?
2.1
We are Nuvay Private Ltd trading as “Sqillup S&M, Sqillup English, Sqillup 11+”.
are an online educational content provider (the “Services”) to parents, and School
Students (“you”) to assist the learning of students of school age.
3. What’s the purpose of this policy?
3.1
It tells you what to expect when we collect personal information from users of our
website/app. Please only use them if you are completely happy with this policy.
3.2
Generally, the policy covers only information provided to us. If you give personal
information to other people, such as payment providers or other websites, please
check their privacy policies. Nor does this policy apply to personal information
that we collect as a “processor”.
4. Might the policy change?
4.1
Yes. We will give you notice of the new version by posting it on our service and
communicating it otherwise if appropriate.
5. What do we collect?
5.1
Information that you upload to our service or otherwise give us such as:
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your name and contact details and other personal information that you supply on
registration;
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account information such as your username and password and your contact or other
account preferences;
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child/student name, student year group, name of the school, we may also collect
further identity data (e.g. gender, date of birth, student year group, language and
country of student living)
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details about your transactions on our service;
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other information that you include in messages sent to other users via our service
and/or in communications with us; and
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contact or other information which you give or allow us to use for newsletters or
other marketing.
5.2
Student Learning Data includes student responses to activity questions, aggregate
scores across subject and/or topic area and progress made over time
5.3
Automated browsing information about your use of our service such as: the internet
protocol (IP) address used to connect your device to the internet, connection
information such as browser type and version, information about your device
including device-type and device identifier, operating system and platform, mobile
network data, a unique reference number linked to the data you enter on our system,
the site from which you arrived at our service, details of your activity with
date/time stamps including pages you visited and your searches/transactions.
5.4
We may receive limited information about you from our payment/authentication
providers (for verification purposes). This information may include your name and
contact details.
5.5
Other data types
Usage Data includes information about how you use our website, app(s) and
services.
Marketing Data includes your preferences in receiving marketing from us and
your engagement with our marketing activities.
Communications Data includes your communication preferences and email,
voicemail and telephone records to customer support.
6. What’s our reason / legal basis for collecting the information?
6.1
Because it’s necessary to take steps at your request to enter into a contract with
you and/or to perform such a contract. This applies to information such as initial
enquiries and to account, contact and transaction information.
6.2
Because it’s in our “legitimate interests”, e.g., sending you marketing
communications about our similar products/services, managing and improving our
service including tracking usage patterns and preventing or detecting fraud or
abuse. This applies to information such as contact details and automated browsing
data.
6.3
Because you’ve specifically agreed on our service (e.g., by selecting a consent
box). This may apply to contact or other information that you specifically agree to
us using for certain kinds of marketing. You can withdraw permission at any time as
explained on our service or by emailing us at the above email address.
6.4
Because it’s necessary to comply with legal or regulatory obligations.
7. How long do we keep personal information?
7.1
We will generally hold your information for our default standard retention period of
six years after the end of our contract/relationship with you, but we may delete it
earlier/later as set out below or in our terms and conditions.
7.2
We will keep your information that we use for email newsletters or other marketing
until you tell us to stop sending you such messages.
7.3
We will generally keep automated browsing information for up to 14 months.
8. To whom do we send or make available your personal information?
8.1
To other people who supply us with services, e.g., website/app hosting and
management, app admin, payment, messaging, email distribution, e-commerce, online
advertising, analytics, social media etc.
8.2
To other users of the relevant project.
8.3
To regulators, the police and other law enforcement or official authorities to help
deal with fraud and abuse and/or comply with legal requirements and/or to protect us
or others.
8.4
To (actual or potential) potential buyers so far as reasonably necessary in the case
of a proposed or completed sale or merger or business combination involving all or
the relevant part of our business.
9. Do we send your information outside the UK?
9.1
Your personal information (e.g., name, username, contact details, IP address,
browsing information) is transferred to our offshore companies outside the UK
(generally to the Sri Lanka and India) that provide us with the services mentioned
above. Where this happens, we will ensure that there is a legal basis to do so, for
example in accordance with “adequacy regulations” applying to particular countries,
or under contracts with standard contractual clauses sanctioned by the Information
Commissioner that are designed to provide adequate safeguards for your personal
information.
10. What rights do you have?
10.1
If the legal requirements are met: To ask us for access to your personal
information, to rectify it if there are mistakes, to delete it or restrict its use
in certain circumstances or to “data portability” or to withdraw any consent you’ve
given (e.g., marketing).
10.2
You may also have the right to object to use of your personal information in certain
circumstances.
10.3
If you have a complaint about how we are dealing with your personal information,
please contact us via the email address above. If you are not happy with our
response or think we are not handling your personal information in accordance with
the law, you have the right to complain to the Information Commissioner’s Office
(ICO).
10.4
For more information about your rights, visit the ICO’s website: www.ico.org.uk.