Last Modified 09/12/2021
At Swotly, we take privacy very seriously. We have prepared this privacy notice to ensure that we communicate to you, in the clearest way possible, how we treat your personal information. We encourage you to read this privacy notice carefully.
This notice sets out how we look after your personal data if you are a:
Parent or student
Member of staff at a school
Visitor to our website
Supplier or business contact of Swotly
We may update this notice from time to time, and you can find our latest notice on our website or by asking us for a copy.
Swotly Limited is a company incorporated in England and Wales, with company number 13222488 (referred to as “we” “us” “our” and “Swotly” in this notice).
This privacy notice applies to personal data we collect from our Marketing site, and our Alexa Skills and Google Actions (referred to as “voice applications”).
Our address is Unit 5, Cobden Chambers, Pelham Street, Nottingham, England, NG1 2ED
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer as follows:
Address: Unit 5, Cobden Chambers, Pelham Street, Nottingham, England, NG1 2ED
Email address: dpo@swotly.io
We are registered at the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Our registration number is: ZA938100
We provide voice applications to schools to help improve parental engagement. The Swotly platform integrates with a school’s management information systems and learning management systems, to allow parents to enquire about their children’s education.
With regard to student data, Swotly acts as a data processor. We retrieve student data from a school’s systems and store it in the Swotly platform so that we can provide answers to parents’ enquiries in a timely manner. We only retrieve student data associated with verified parents and legal guardians. The school is the data controller and the person responsible for deciding how and when student data is collected and used, whilst we follow the instructions of the school. The school should provide you with their privacy policy or privacy notice, setting out how the school uses your personal data.
Where we act as a data processor, we have legally binding agreements in place with the school which restricts how we process personal data, in accordance with data protection laws.
When you register or log in to the Swotly platform, visit our website, use our voice applications, or contact support, we will receive certain data directly from you, such as your name, login details, and voice profile. For this limited data only, we will be responsible for deciding how and when your data is used, and we will be the data controller.
We are a data controller when we collect personal information from suppliers and other third parties who interact with us.
The purpose of the remainder of this privacy notice is to set out how we use personal data when we act as a data controller.
This notice does not apply when we act as a data processor. In those cases, our private agreement with the school will apply, and you should read the school’s privacy policy or privacy notice to understand what personal data is collected and how it is used and shared.
Depending on your relationship with us (for instance, whether you are a parent or an employee of a school), we collect, use, store and transfer some or all of the following data:
Identity Data includes your given name, family name, username and date of birth
Contact Data includes billing address, email address and telephone numbers.
Profile Data includes your username, PIN, profile picture and any profile data you choose to share with us from your social media accounts
Voice Data includes Alexa Voice Profile that uniquely identifies your voice
Relatives Data: the name(s) of your parent(s) and/or child or children.
Pupil Data includes aliases and gender of children you are associated with
Financial Information includes your bank account details
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access the Swotly platform and our services
Usage Data includes information about how you use the Swotly voice applications
You can withhold your personal data from us, but we may not be able to provide our services to you if you do so.
We may collect your personal data from different sources:
We collect all of the types of data listed above directly from you when you interact with us. This includes when you register with our platform, and when you enable our voice applications
We collect Relatives Data from the school(s) you are connected to
We collect Technical Data automatically when you interact with our website or platform, by using cookies and other similar technologies
We collect Technical Data automatically when you interact with voice applications
We will only use your personal data when the law allows us to.
We will only use your personal 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.
When we are acting as a data controller, we will use your personal data for the purposes set out in the table below.
The law sets out a number of different reasons for which we can collect and use your data. The legal grounds on which we collect and use your data are also set out below:
Purpose: To register you as a new user Type: Identity, Contact, Voice Lawful basis: Performance of a contract with you
Purpose: To verify your identity Type: Identity, Contact Lawful basis: To comply with our legal and regulatory obligations
Purpose: To determine which students you are associated with Type: Identity, Contact, Relatives Lawful basis: Performance of a contract with you, and to comply with our legal and regulatory obligations
Purpose: To allow you to access your account on our platform Type: Identity, Profile, Voice, Relatives, Pupil, Technical Lawful basis: Performance of a contract with you, and necessary for our legitimate interests
Purpose: To provide support to you when you contact us Type: Identity, Contact, Profile, Voice, Pupil Lawful basis: Performance of a contract with you, and to comply with our legal and regulatory obligations
Purpose: To manage our relationship with you which will include notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey Type: Identity, Contact, Profile, Marketing and Communications Lawful basis: Performance of a contract with you, to comply with our legal and regulatory obligations, and necessary for our legitimate interests (to gather customer feedback in order to improve the Platform)
Purpose: To use data analytics to improve our website, voice applications, marketing, customer relationships and experiences Type: Technical, Usage Lawful basis: Necessary for our legitimate interests (to define types of customers for our voice applications, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Purpose: To make suggestions and recommendations to you about goods or services that may be of interest to you Type: Identity, Contact, Technical, Usage, Profile, Marketing and Communications Lawful basis: Necessary for our legitimate interests (to develop our voice applications and grow our business)
Purpose: To create anonymous aggregated data, as set out below. Type: Identity, Contact, Profile, Pupil, Marking and Communications, Technical, Usage Lawful basis: Necessary for our legitimate interests (to provide additional benefits and functionality to our customers and users without disclosing personal data).
We may aggregate and use non-personally identifiable data we have collected from you and others. This data will in no way identify you or any other individual.
We may use this aggregated non-personally identifiable data to:
assist us to better understand how our users are using our platform and services
provide users with further information regarding the uses and benefits of our platforms and services
enhance school productivity, including by creating useful school insights from that aggregated data and allowing benchmarking of performance against aggregated data
improve our platform and services.
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.
Swotly does not sell, rent or lease your personal data. However, in order to operate Swotly may need to share personal data with the following service providers:
Swotly has vetted each of these service providers to ensure they are fully compliant for use in an educational context. To the best of our knowledge, all of these providers are GDPR-compliant. Some or all of these service providers may be considered to be sub-processors as defined within the GDPR.
From time to time, Swotly may share your personal data with our professional advisers, including lawyers, auditors and insurers.
In all cases, your data is stored by us and our sub-processors in the UK or EEA.
The Swotly platform is built with strong security features that continuously protect your information. We work hard to protect your data from unauthorised access, alteration, disclosure and destruction.
Some of our key practices include:
We use encryption to keep your data private while in transit and at rest
We use field-level encryption to protect particularly sensitive information so that, even having gained access to our databases, an intruder can’t read data without additional keys to decrypt it
We use centrally-managed vaults to store, rotate, and restrict access to passwords and secrets
We use hardened networks to limit access to all infrastructure and data
We restrict access to your data to key employees of Swotly who need that information in order to process it.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data. We also take into consideration the potential risk of harm from unauthorised use or disclosure, the purposes for which we process said data and whether we can achieve those purposes through other means.
For more details of our specific retention periods, please contact our Data Protection Officer.
In the unlikely event that Swotly comes to suspect a breach of the protective measures we have in place with respect to the data we collect, we will:
Assess the likely risk to individuals as a result of the breach
Inform, without delay, affected individuals about the breach when their rights and freedoms are at high risk
Where appropriate, provide advice to affected individuals to help protect themselves from the breach effects
Notify the ICO of the breach within 72 hours of becoming aware of it, even if we do not have all the details yet
Document the details of the breach, even if it doesn’t need to be reported
Under the Data Protection Laws your rights are:
Right of access – you have the right to request a copy of the personal data that we hold about you and to check that we are lawfully processing it
Right of rectification – you have a right to request that we correct personal data that we hold about you that is inaccurate or incomplete
Right to be forgotten / erasure – in certain circumstances, you can ask for the data we hold about you to be erased from our records
Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing
Right of portability – you have the right to have the data we hold about you transferred to another organisation
Right to object – you have the right to object to processing of your personal 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
Where we are relying on your consent to process your personal data, you may withdraw consent at any time. However, if you withdraw your consent, we may not be able to provide certain 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 our Data Protection Officer. All of the above requests will be forwarded should there be a third party involved in the processing of your personal data.
You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
You have the right to make a complaint at any time ICO. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.