Last updated on 7 of January 2020
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). This policy sets out the basis on which any personal data we collect from you, or that you provide to us through your use of our website, will be processed, stored and disclosed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.simplestudying.com (the Site) or using any services offered through our Site (the Services), you are deemed to have accepted and consented to the practices described in this policy.
The Site is owned and operated by SimpleStudying Ltd (12373336).
SimpleStudying Ltd processes personal data as a Data Controller as defined in the Data Protection Legislation (being the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (GDPR) (both as amended, updated or re-enacted from time to time)).
You 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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. Information we collect about you:
We collect and process general information so we can provide our Services to you. Personal information (or personal data), 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). It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect and process about you is explained in the sections below.
3. Data You Give Us
- You give us information about you by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. We collect general information about you to create your profile on SimpleStudying. In particular, this information includes your full name, username, email address and the university where you study. You can also provide a short description about yourself which is optional and will be saved on our database.
- The information you give us includes compulsory information and voluntary information. The compulsory information includes names, usernames, email addresses and university name. The information you may choose to volunteer comprises a short description about yourself upon registration, anything you post or comment or any other kind of interaction you make on our forums and chats.
- We rely upon data subjects giving consent to use and process the data described above for one or more specific purposes. This data is necessary for our legitimate interests and for us to fulfill our contractual obligations to you, and we rely on this as a lawful basis to use and process the data described above.
4. Data We Automatically Collect
a. Each time you visit or use our Site, we automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any method used to contact us.
b. We use this information as statistical data about your browsing actions and patterns, for system administration, and to evaluate, provide, protect or improve our Services (including by developing new products and services). Because we collect, use and share this information in the aggregate, it does not identify any individual.
5. How We Use Your Data
a. We use your data to carry out our Site and Services in the following ways (and only when the law allows us to):
- To administer and manage your account, to provide you with information you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.
- To ensure that content from our Site is presented in the most effective manner for you and for your device.
- To respond to communications from you and to provide you with information about our Services, including notifying you about changes to our Site or Services.
b. We also use your data to make our Site and Services better in the following ways:
- To administer the Site for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- As part of our efforts to keep the Site safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.
c. We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable data protection laws. If you are an existing customer, we will only contact you by electronic means (e-mail or notification on the Site) with information about services similar to those which were the subject of a previous enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have expressly consented to this.
f. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us in writing or by email here.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|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
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
6. How We Secure Your Data
- All of your personal information is protected and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect. Your information is stored on secure cloud databases, internal servers, and on third party softwares. Your information is only accessible by SimpleStudying team who have authorised access rights to such information.
- Debugging: When there is a technical issue with a user account, our staff have the right to access the data of your account. However, they are unable to read your password.
7. How Long We Store Your Data
We only keep your personal information for as long as it is necessary for our original legitimate purpose for collecting the information and for as long as we have your permission to keep it. We will delete your personal information when you request that we delete your account data, once the request is received we investigate and process the deletion request at our earliest convenience.
8. Disclosure to Third Parties
The circumstances under which we would share your personal data are:
- If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If the Company or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.
- If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
9. Parties with whom You may Choose to Share Your Information:
- You may choose to share any information, photographs or other content that you voluntarily submit to the Site, either on public forums and public areas of the Site or within your private network (meaning other users you have invited or accepted as connections of your closed network). Such data will become available and viewable by other users as controlled by any applicable privacy settings that you define. To change your privacy settings on the Site, please contact us. Once you have shared your content or made it public, that content may be re-shared by others.
- If you choose to connect to social media networks from our Site, or post any of your content on our Site, to those networks, then in accordance with your social media privacy settings, the personal information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of those networks and we have no control over such viewing and use and cannot prevent further use of such information by third parties. When you interact with us through social media networks, you acknowledge that we may access your information that is held by that account, solely in accordance with your social media privacy settings.
- Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any information posted via social media through our Site, or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that information visible to third-parties who can use that information at their discretion.
- You may review, modify, update, correct or remove any personal data you have submitted to the Site at any time. If you remove information that you posted to the Site, copies may remain viewable in cached and archived pages of the Site, or if other users or third party APIs have copied or saved that information.
- You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their data at any time.
10. Your Rights:
We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one of the following bases applies:
- You have given your clear consent to the processing of your personal data for a specific purpose.
- Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
- Processing is necessary for our compliance with the law.
- Processing is necessary to protect someone’s life.
- Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
- Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests, such as allowing us to effectively and efficiently manage and administer the operation of our business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials, offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.
11. Data Subject Rights
a. Under the GDPR, you have the right to:
- Withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
- Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
- Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
- Correct or supplement any information we hold about you that is incorrect or incomplete.
- Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
- Object to the processing of your data.
- Obtain your data in a portable manner and reuse the information we hold about you.
- Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
- Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).
b. You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
c. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal 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 in relation to your request to speed up our response.
d. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
e. You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by contacting us at the Company Address, or via our contact us form, or by unsubscribing using the links contained in the marketing emails.
g. To enforce any of the above rights, please contact us at our Company Address or via Contact us form.
h. We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.
If you are under 18, you must have permission from a parent or a legal guardian before you give us your personal and payment information. If we find that we have received information from you without the appropriate consent, we reserve the right to cancel all transactions and services and remove all personal data that you have provided. You will be able to re-submit the information when you have the required permission.
13. Links to other websites: