Kinteract Privacy Policy

The revised privacy policy will be effective starting on May 25, 2018

What this policy covers

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:

• Our service and the type of account you have determines our responsibility to you
• What information we collect about you
• How we use information we collect
• How we share information we collect
• How we store and secure information we collect
• How to access and control your information
• How we transfer information we collect internationally
• Other important privacy information
• How to contact us

This Privacy Policy covers the information we collect about you when you use our products or services, or otherwise interact with Kinteract (for example, attending Kinteract events), unless a different privacy policy is displayed. This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, please do not access or use our Services or interact with any other aspect of our business.

When we refer to "Kinteract," "we," or "us" in this policy, we mean Make It Plain Ltd., which controls the information Kinteract collects when you use the Services. Kinteract offers a collaborative digital portfolio, including our web, desktop, and mobile products, which help to track learner progression. We also own and operate a number of websites and offer related services, like support. We refer to all of these products, together with our other services and websites as "Services" in this policy.

The Service

Education institutions, primarily Schools and Nurseries/Kindergartens, subscribe to Kinteract to use it as a digital portfolio and assessment platform for students under their care and to share with their staff. In addition the institution may share this information with parents and carers of those students.

Relationship with Kinteract and managed accounts

If your account was created through an institution subscribing to Kinteract then the institution own the data they place in our service, and the institution are the Data Controller and Kinteract is just the Data Processor. Moreover where we provide the Services under contract with an organisation (for example your employer), that organisation controls the information processed by the Services. For more information, please see Notice to End Users below.

What information we collect about you

We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.

Information you provide to us

We collect information about you when you input it into the Services or otherwise provide it directly to us.

• Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences. For example, you provide your contact information when you register for the Services. You also have the option of adding a profile photo, bio, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.
• Content you provide through our products: The Services include the Kinteract web, desktop and mobile products you use, where we collect and store content that you post, send, receive and share. This content includes any information about you that you may choose to include. Content also includes the files and links you upload to the Services. Examples of content we collect and store include: narrative on a card, files you attach to a card, tasks to do and completed, assessments and reports on student performance.
• Content you provide through our websites: The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.
• Information you provide through our support channels: The Services also include customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.

Institutional Sign Up

Specifically when an institution subscribes we store the following:

• The name and address of the institution
• The name, email address and telephone number of the person at the institution who plays the role of account owner/administrator

The institution may then store some or all of the following data on our Service

• The names and email addresses of their staff
• The names, dates of birth, addresses and email addresses of students
• The names, addresses, email addresses of parents and carers of students
• The components of a digital portfolio:
  • Observations, posts, next steps
  • Assessment and reports of student performance
  • Rich media including audio, photos and videos

Information we collect automatically when you use the Services

We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.

• Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the cards, reports, assessments, next steps and other links you click on; the type, size and filenames of attachments you upload to the Services; frequently used search terms; and how you interact with others on the Services.
• Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
• Cookies and Other Tracking Technologies: Kinteract and our third-party partners, such as analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookies Policy , which includes information on how to control or opt out of these cookies and tracking technologies.

Information we receive from other sources

We receive information about you from other Service users and from select third party services,

• Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. For example, you may be mentioned by someone else on a card, or a team member may upload content about you to a card/post. We also receive your email address from other Service users when they provide it in order to invite you to the Services. Similarly, an administrator may provide your contact information when they designate you as a new account user.
• Other services you link to your account: We receive information about you when you or your administrator enable integrations or link a third-party service with our Services. For example, if you create an account or log into the Services using your Google credentials, we receive your name and email address as permitted by your Google profile settings in order to authenticate you. You or your administrator may also integrate our Services with other services you use, such as Office 365 to allow you to access, store, share and edit certain content from a third-party through our Services. For example, you may authorize our Services to access and display files from a third-party document-sharing service within the Services interface. Or you may authorize our Services to sync a contact list or address book so that you can easily connect with those contacts within the Services or invite them to collaborate with you on our Services. The information we receive when you link or integrate our Services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared with our Services.

How we use information we collect

How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.

• To provide the Services and personalise your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services. For example, we use the name and picture you provide in your account to identify you to other Service users. Our Services also include tailored features that personalise your experience, enhance your productivity and improve your learning by providing activity feeds, notifications, connections and recommendations that are most relevant for you and your team. We may use your email domain to infer your affiliation with a particular organisation or industry to personalize the content and experience you receive on our websites.
• For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. We also test and analyse certain new features with some users before rolling the feature out to all users.
• To communicate with you about the Services: We may use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages.
• To market, promote, and drive engagement with the Services: We may use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying Kinteract ads on other companies' websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement and maximising what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We may also communicate with you about new product offers, promotions and contests. You can control whether you receive these communications as described below under "Opt-out of communications."
• Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyse crash information, and to repair and improve the Services.
• For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
• To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
• With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
• Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
  • We need it to provide you the Services, including to operate the Services, provide customer support and personalised features and to protect the safety and security of the Services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  • You give us consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

How we share information we collect

We provide a digital portfolio and assessment platform and we want this to work well for you. This means sharing information through the Services and with certain third parties. We may share information we collect about you in the ways discussed below but you can be rest assured that we are not in the business of selling information about you to advertisers or other third parties.

Sharing with other Service users

When you use the Services, we share certain information about you with other Service users.

• For collaboration: You can create content, which may contain information about you, and grant permission to others to see, share, edit, copy and download that content based on settings you or your administrator (if applicable) select. Some of the collaboration features of the Services display some or all of your profile information to other Service users when you share or interact with specific content.
• Managed accounts and administrators: If you register or access the Services using an email address with a domain that is owned by your employer or organisation, certain information about you including your name, profile picture, contact info, content, and account use may become accessible to that organisation’s administrator.

Sharing with third parties

We share information with third parties that help us operate, provide, improve, integrate, customise, support and market our Services.

• Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
• Third-Party apps: You, your administrator or other Service users may choose to add new functionality or change the behaviour of the Services by enabling third party integrations within the Services. Doing so may give third-party apps access to your account and information about you like your name and email address, and any content you choose to use in connection with those apps. If you are an administrator or contact listed on an account, we share your details with the third-party app provider upon installation. Third-party app policies and procedures are not controlled by us, and this privacy policy does not cover how third-party apps use your information. We encourage you to review the privacy policies of third parties before connecting to or using their applications or services to learn more about their privacy and information handling practices. If you object to information about you being shared with these third parties, please disable the app.
• Links to Third-Party Sites: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
• With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
• Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Kinteract, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

How we store and secure information we collect

Information storage and security

We use data hosting service providers in the United Kingdom to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. We will respond to requests about this within a reasonable timeframe.

How long we keep information

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymise your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

• Account information: We retain your account information until you delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about you.
• Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we continue to display comments and content you provided to cards or made assessments/reports.
• Managed accounts: If the Services are made available to you through an organisation (e.g., your employer or that your child attends that institution), we retain your information as long as required by the administrator of your account. For more information, see "Managed accounts and administrators" above and “Notice to End Users” below.
• Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

How to access and control your information

You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. We will respond to requests about this within a reasonable timeframe.

Your Choices:

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an administrator (see "Notice to End Users" below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

• Access and update your information: Our Services and related documentation give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account and search for content containing information about you using key word searches in the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
• Deactivate membership to an institution: You or an administrator can deactivate your access to an account associated with an institution. If you can deactivate your own access, that setting is available to you in your account settings. Otherwise, please contact your administrator. If you are an administrator and are unable to deactivate an account through your administrator settings, please contact Kinteract support. Please be aware that deactivating access does not delete your information from content associated with that account; your information remains visible to other Service users based on your past participation within the Services. For more information on how to delete your information, see below.
• Delete your information: Our Services and related documentation give you the ability to delete certain information about you from within the Service. For example, you can remove content that contains information about you using the key word search and editing tools associated with that content and you can remove certain profile information within your profile settings. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
• Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honoured or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.
• Opt out of post notifications: You may opt out of receiving post notifications that are linked to you or in the case of a parent or carer a child under their care. You can update notification preferences within your Profile settings in your Services account.
• Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your notification preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
• Mobile Push Notifications: You can use the settings on your mobile device to enable or turn off mobile push notifications from Kinteract.
• Turn off Cookie Controls: Relevant browser-based cookie controls are described in our Cookies Policy
• Send "Do Not Track" Signals: Currently, various browsers offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to websites visited by the user about the user’s browser DNT preference setting. Kinteract does not track its users over time and across third-party websites to provide behaviourally-targeted advertising and therefore does not respond to Do Not Track (DNT) signals. For more information on “do not track” please visit www.allaboutdnt.org.
• Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces under your sole control.

How we transfer information we collect internationally

International transfers of information we collect

We collect information globally and primarily store that information in the United Kingdom. We transfer, process and store your information outside of your country of residence, to wherever we, Kinteract, or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.

Other important privacy information

Notice to End Users

Our products are intended for both personal use and use by organisations. Where the Services are made available to you through an organisation (e.g., your employer or that your child attends that institution) that organisation is the administrator of the Services and is responsible for the end-users and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organisation's policies. We are not responsible for the privacy or security practices of an administrator's organisation, which may be different than this policy.

Even if the Services are not currently administered to you by an organisation, if you are a member of a team administered by an organisation, or if you use an email address provided by an organisation (such as your work email address) to access the Services, then the administrator of that team or the owner of the domain associated with your organisational email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens.

Administrators are able to restrict your access to and privileges within your account. In some cases, enterprise administrators can also:

• require you to reset your account password;
• restrict, suspend or terminate your access to the Services or your account;
• control your ability to edit, restrict, modify or delete account information;
• change your account information, including profile information or the email address associated with your account;
• access information in and about your account;
• access or retain information stored as part of your account; and
• enable or disable third-party apps, or other integrations.

If you do not want an administrator to be able to assert control over your account or use of the Services, you should deactivate your membership with the organisation or remove any email addresses containing a domain owned or controlled by the administrator entirely from your account. Once an administrator asserts control over your account or use of the Services, you may no longer be able to withdraw membership or change the email address associated with your account without administrator approval.

Please contact your organisation or refer to your administrator’s organisational policies for more information.

Our policy towards children

Kinteract is designed for students to take ownership of their digital portfolio and facilitate student directed learning. We expect that any use by students, specifically those under the age of 13, will only be done with the guidance, supervision and consent of their parents, carers and or authorised institution officials. Kinteract relies on parents and carers to ensure that minors only use Kinteract if they can they understand their rights and responsibilities as laid out in our Terms of Service and in this Privacy Policy.

Changes to our Privacy Policy

We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

Contact Us

If you have questions or concerns about how your information is handled, please direct your inquiry to Make It Plain Ltd T.A as Kinteract, as set forth below:

• Make It Plain Ltd T/A Kinteract
  Innovation Centre
  Mewburn Road
  Banbury, Oxfordshire, OX16 9PA
  E-Mail: privacy@kinteract.co.uk