Privacy Policy

Contents

1. Introduction
2. What does this Privacy Policy cover?
3. Data Collection
4. Use of Data
5. Disclosure of Data
6. Data Transfers
7. Data Security
8. Data Retention
9. Your Rights
10. Opting Out of Marketing Communications
11. Children
12. Changes to our Privacy Policy
13. Contacting Us
14. European Representative under Article 27 of GDPR
15. Complaints
16. Notice to Students and other authorised users
17. Notice to Parents or Legal Guardians

Introduction

Your privacy is genuinely important to us. Digital Theatre.com Limited and its holding company, subsidiaries, and affiliates ("Digital Theatre", "we", "our" or "us") are committed to safeguarding your data in line with the latest data protection and privacy laws.

The data we collect depends on the context of your interactions with us. Unless otherwise defined below, “You” or "Your" means any person or Institution that is authorised to use the Education Platform or Marketing Website. “Institution” shall herein include educational institutions, organisations, or businesses.

What does this Privacy Policy cover?

Education Platform and Marketing Website. This Privacy Policy describes the collection, use and disclosure of data, including personal data, from or about you in connection with your access and use of; (a) our cloud-based platform where our services are hosted and provided to account owners for distribution to their authorised users, located at: https://edu.digitaltheatreplus.com (the “Education Platform”); and (b) our marketing website, located at: https://www.digitaltheatreplus.com (the “Marketing Website”).

Account Owner. If you represent an Institution that utilises the Education Platform, for the purposes of this Privacy Policy, you are an “Account Owner”. Please read this Privacy Policy carefully and pay particular attention to the following sections as they include information about your data protection responsibilities to your authorised users:

• “Account Owner's Personal Data collected on the Education Platform”
• “Student Personal Data collected on the Education Platform”
• “Account Owners and the Children’s Online Privacy Protection Act”; and
• “Your Rights”

Student. If you are a full or part-time student who is only authorised to access the Education Platform through an account provided by an Account Owner, for the purposes of this Privacy Policy, you are a “Student”. Please see our “Notice to Students and other authorised users” for information regarding your personal data.

Parents or Legal Guardians. If you are a parent or legal guardian of a Student under the age of eighteen (18), please see the following sections: “Children” and “Notice to Parents and Legal Guardians”.

Services. The term “service” refers to: (a) the services to be delivered to our Account Owners via the Education Platform pursuant to the Licence and Terms of Use Agreement (“Agreement”); and (b) any other services offered from time to time through our Marketing Website. In the event of conflict between the terms of this Privacy Policy and the Agreement, the Agreement will control.

Data Collection

“Personal Data” means any information relating to an identified or identifiable natural person. Some laws may use different definitions, if you are asserting your rights under law, the applicable legal definition governs your rights.

Personal Data collected on the Marketing Website. In general, we may collect data about you in the following situations, when you:

• create an account with us
• apply for a job with us as part of the recruitment process
• enquire about any of our services
• use or request to use any of our online services
• fill in a form or survey for us
• subscribe to our mailing lists
• participate in a competition or promotion or marketing activity
• contact us, for example by email, telephone or social media
• participate in interactive features
• use our “Live Chat” facility to message and talk to our support services team

Personal Data collected directly from you. Through the Marketing Website, we may collect Personal Data that you voluntarily provide, such as your: (a) title; (b) first and last name; (c) Institution name; (d) business address; (e) email address; (f) the city and country in which you are located (but not your precise geographic location); (g) professional title and affiliation; (h) telephone number; and (i) Institution type. We also record your communications preferences when you sign up to receive marketing communications from us.

Technical Data collected automatically. When you use our service, we may automatically collect certain technical data about your use of our Education Platform or Marketing Website and data about the device you are using to access the services. Technical data may include your: (a) Internet Protocol (“IP”) address (which may tell us your general location); (b) browser type and version; (c) device IDs or other unique identifiers; (d) the referring webpage; and (e) viewing history. To collect this information, we may use cookies, web beacons, pixels and other automatic information gathering technologies. Please see our: Cookie Policy for the Education Platform and our Cookie Policy for the Marketing Website for more information.

Data collected by Marketing Partners or public sources. We may collect data about you from: (a) trusted third parties providing us with services and purchased data for marketing purposes, for example HubSpot.com (our “Marketing Partners”); or (b) public sources. These sources vary over time, but could include: (a) service providers that help us determine a location based on your IP address in order to customise our service and for other uses consistent with this Privacy Policy; (b) security service providers who provide us with data to secure our systems, prevent fraud and help us protect the security of our Account Owner’s accounts; (c) online and offline data providers, from which we obtain aggregated demographic, interest based and online advertising related data; and (e) publicly-available sources such as publicly available posts on social media platforms and information available through public databases.

Aggregated Data. We may also collect, use, and share data such as statistical or demographic data (“Aggregated Data”) for any purpose. Aggregated Data may be derived from your Personal Data, but it is still not considered Personal Data in law, as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we will treat this combined data as Personal which will be used in accordance with this Privacy Policy.

Special Categories of Personal Data. We do not collect any Special Categories of Personal Data (as defined in the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (known as the “UK GDPR”)). This includes details about your race, or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, data about your health or genetic and biometric data. Nor do we collect any data about criminal convictions and offences.

Account Owners Personal Data collected on the Education Platform. If you are an Account Owner, Personal Data and other data associated with your account may include: (a) name and contact data; (b) payment data (in some countries, this may include a government identification number for the purposes of billing and tax); (c) device and usage data; and (d) information about your interest in and use of various services and content available on our Education Platform. Signing into your account enables personalisation and consistent experiences across the Education Platform and through devices, permits you to use cloud data storage and enables other features. We collect and process this data to provide the service (including improving, securing and updating the service), conduct our legitimate business operations, and communicate with you. For example, when you interact with our customer or support service, we collect device and usage data or error reports to diagnose and resolve problems. When you pay for the services, we collect contact and payment data to process the payment. When we send communications to you, we use data to personalise the content of communications.

Student Personal Data collected on the Education Platform (only). When signing-in to our Education Platform using the Single Sign On mechanism, a Student may be prompted to provide Personal Data in the form of an email address that will assist the Account Owner in authenticating their identity for the first time and when they sign-in in the future (for the purposes of this section only, the “email address”). This does not have to be an email address that can receive emails. If you are an Account Owner, in accordance with the terms of our Agreement, you are responsible for: (a) adhering to legal and regulatory requirements for obtaining the email address, including the collection and maintenance of any necessary rights, permissions, and consents for the email address; (b) identifying and authenticating all Students; (c) for controlling against unauthorised access by Students; and (d) maintaining the confidentiality and use of the email address. You are the Data Controller (as defined in the UK GDPR) of the email addresses and other Personal Data relating to the Students on your account. Digital Theatre is the Data Processor (as defined in the UK GDPR) and only collects and processes Student email addresses because: (a) we have your consent to do so; (b) we need the email addresses to perform our contractual obligations to provide you with access and use of the services; and (c) we have a legitimate business interest to do so that is not overridden by the data protection interests or fundamental rights or freedoms of you or your Students. Except detailed in this section, we do not collect any other Student Personal Data. For information regarding the disclosure of Student Personal Data, please see “Disclosure of Personal Data under Account Owner control” section of this Privacy Policy. For information regarding the retention of Student Personal Data, please see “Data Retention” section of this Privacy Policy.

Account Owners and the Children’s Online Privacy Protection Act (“COPPA”). Without limiting the foregoing section regarding “Student Personal Data” and for the purposes of K-12 Account Owners only; under the COPPA, verifiable parental consent is needed to collect, use, or disclose Personal Data from a child under thirteen (13) years old. In accordance with COPPA, an Account Owner may act as the agent of the parent or legal guardian of a Student and provide consent on behalf of the parent for our processing of a Student’s email address. By allowing a Student under the age of thirteen (13) to authenticate to the Education Platform, the Account Owner provides such consent to us and agrees that the Student’s activities while utilising the service are subject to the terms of the Agreement between us and such Account Owners. For more information on your obligations under COPPA, see: https://www.ftc.gov/privacy

If you choose not to provide data. The provision of Personal Data is not mandatory. However, you will not be able to access and use the services and communicate with Digital Theatre without disclosing some Personal Data to Digital Theatre.

Use of Data

Why do we collect your Personal Data? We use your Personal Data solely for certain legitimate business purposes, which include some or all, of the following:

• contacting you and sending you communications that we think will be of interest to you
• providing you the information you request through our Education Platform or Marketing Website
• remembering data you previously entered on our Education Platform or Marketing Website to enhance, modify, personalise, or otherwise improve your experience on our Education Platform or Marketing Website
• improving our Education Platform, Marketing Website and/or services
• customising the advertising and content you see
• conducting research and providing statistical reporting to understand how individuals interact with our Education Platform or Marketing Website
• conducting voluntary user surveys on our Education Platform
• determine the effectiveness of promotional campaigns and advertising
• to process job applications and conduct any pre-employment screening
• formalise any contracts of employment and/or agreements of service
• allow you to participate in interactive features
• notify you about changes to our services
• respond to requests where we have a legal or regulatory obligation to do so
• assess the quality and/or type of care you have received and any concerns or complaints you may raise, so that these can be properly investigated
• to ensure that content is presented in the most effective manner for you and for your computing device
• to enable us to carry our obligations to you in connection with the service we provide
• to record (where applicable), transcribe, summarise and analyse meetings, demonstrations and other business communications using AI-assisted technologies for customer relationship management, staff training, quality assurance, service improvement and internal business administration
• if you are an Account Owner, to enable us to carry our obligations to you arising from the Agreement and related matters such as billing, accounting, audit, service of notices, support services, to better monitor the performance of the Education Platform, track account usage and test and improve the Education Platform

Lawful Basis. To process your Personal Data in accordance with data protection laws, we must establish a lawful basis for doing so. We process your Personal Data: (a) where we have your consent to do so; (b) where we need the Personal Data to perform a contract with you; or (c) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights or freedoms (for example, our direct marketing activities in accordance with your preferences). In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person. Mostly, however, Digital Theatre processes your personal information for our legitimate business interests as described in the section “Why do we collect your Personal Data?”. If we collect and use your Personal Data in reliance on any legal basis other than our legitimate interests, we will make it clear to you at the relevant time. For example, if we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as possible consequences if you do not provide your Personal Data). If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the details set out in the “Contacting Us” section below.

Disclosure of Data

Disclosure of your Personal Data. We do not disclose Personal Data about you to third parties except under the following circumstances and for the following purposes:

• when we have your permission to provide you with services you requested and to carry out your instructions
• we may share your data internally with our affiliates, as needed for: (a) data processing and storage; (b) providing you with access to our services; (c) providing support services; (d) making decisions about service improvements; (e) content development; and (f) for other purposes described in the “Why we collect your Personal Data section?”.
• when required by law to respond to subpoenas, court orders, or legal process by public authorities, including disclosures required by national security or law enforcement agencies
• when we need to establish or exercise our legal rights, or to defend against legal claims, or when we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, data breaches, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Agreement, or as otherwise required by law
• we may transfer your Personal Data if Digital Theatre is acquired by or merged with another company, to ensure the continuity of our business and services. In such event, Digital Theatre will make public announcement before data about you becomes subject to a different privacy policy
• we may share your Personal Data with third party IT system support and hosting service providers that we engage to support our business, the Education Platform or Marketing Website. For example, this may include: (a) Xero.com and Stripe.com for financial operations; (b) GetAccept for orders, proposals and eSignatures; and (c) Cookiebot.com for cookie consents
• we may share Personal Data with third-party service providers of customer relationship management, lead generation and outreach services (such service providers do not receive access to authorised user data, device or usage data)
• we may share Personal Data with carefully selected third-party service providers that provide cloud hosting, customer relationship management, meeting recording, transcription and AI- assisted analytics services.
• third party debt collectors for the purposes of debt collection
• with our Marketing Partners, as described above

Where a third-party data processor is used, we make sure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under data protection laws. We do not allow third parties to use your Personal Data for their own purposes.

Where AI-assisted technologies are used, they support our personnel by generating transcripts, summaries and recommendations. We do not make decisions producing legal or similarly significant effects about individuals based solely on automated processing.

Disclosure of Personal Data under Account Owner control. We are not responsible for disclosures of Personal Data made by Account Owners, their Students, and other authorised users through such Account Owner’s respective accounts. When we process Personal Data on behalf of an Account Owner, it is that Account Owner’s responsibility to protect the privacy of its Students and authorised users. We do not disclose the Personal Data of authorised users unless: (a) we have an Account Owner’s express written authorisation; (b) we are required by law to respond to subpoenas, court orders, or legal process by public authorities, including disclosures required by national security or law enforcement agencies; (c) we need to establish or exercise our legal rights, or to defend against legal claims; (d) we believe it is necessary to share data in order to investigate, prevent, or take action regarding illegal activities, data breaches, suspected fraud, situations, involving potential threats to the physical safety of any person, violations of our Agreement with Account Owner’s or as otherwise required by law; or (d) if we are acquired or merged with another company, the Education Platform (including data stored on Account Owner’s respective accounts) may be transferred. If you are an Account Owner, we warrant that we will not sell or rent Student or other authorised users email addresses for advertising or similar commercial purposes.

Third-Party Links. Our Marketing Website may include links to third-party websites, plug-ins and applications. We do not control these third-party websites and are not responsible for the privacy and security practices of any third-party websites, which are governed by their own practices.

Third-Party Systems. If you are an Account Owner, the Education Platform is designed to interoperate with different systems. You may choose to integrate the Education Platform with your own system or with other third-party services of your designation. Integration with third-party services is solely at your discretion. We cannot be responsible for systems connected to the Education Platform that are not under our control.

Data Transfers

Outside the UK/EEA. Digital Theatre is headquartered in the UK, but we operate internationally. We may share your Personal Data within Digital Theatre and transfer it to countries in the world where we do business (specifically to the USA where our affiliate Digital Theatre (US) LLC provides our services). We may also share Personal Data with third-party processors who process Personal Data outside of the UK/European Economic Area on our behalf (specifically to the USA where our authentication processor OKTA is located). We transfer this Personal Data only where necessary and only where appropriate security measures and controls are in place to protect your Personal Data in accordance with applicable data protection laws. This means these transfers will take place on the basis of an approved data transfer mechanism, such as UK/EU Standard Contractual Clauses or UK/EU Commission Decisions on Adequacy. Regardless of location, Digital Theatre takes care to ensure that our affiliates, employees, agents, and processors in other countries act in a manner consistent with this Privacy Policy.

EU-US Privacy Shield. Digital Theatre adheres to the principles of the EU-US Privacy Shield Framework as set forth by the Department of Commerce regarding the collection, use and retention of Personal Data transferred from the EU to the US, although we do not rely on the Privacy Shield as a legal basis for transfers of Personal Data in light of the judgement of the Courts of Justice in the EU in Case C-311/18. To learn more about the Privacy Shield programme, please visit https://www.privacyshield.gov. If you have any queries about our handling of your Personal Data in respect of the Privacy Shield principles, please contact us using the details in the “Contacting Us” section of this Privacy Policy.

Data Security

Security Measures. We use reasonable administrative, logical, physical and managerial measures to safeguard your Personal Data against loss, theft and unauthorised access, use and modification. All Personal Data will be stored on our secure servers that have limited access and are in controlled facilities. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a legitimate business reason to have such access and who have undergone a Disclosure and Barring Service (“DBS”) check. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers. To learn more about security, including the security measures we have taken and steps you can take to enhance the security of your information when using the Education Platform or Marketing Website, please contact us using the details set out in the “Contacting Us” section of this Privacy Policy.

Data Breach. Despite the above “Security Measures”, please note that no data transmission over the internet or any other network can be guaranteed to be 100% secure. While we strive to protect data transmitted on or through the Education Platform or Marketing Website, we cannot and do not guarantee the security of information you transmit. At your request, we may occasionally transfer Personal Data to you via email, or you may choose to transfer data to us via email. Email is not a secure method of data transmission; if you choose to send or receive such data via email, you do so at your own risk. When we transmit highly confidential data (such as passwords or payment details) over the internet, we protect it through the use of encryption. We also have appropriate procedures to deal with any actual or suspected data breach and will notify you when we are legally required to do so.

Data Retention

Length of Retention. We may retain your data for as long as you use our services and we reasonably need to use it, having regard to the purpose for which it was collected, and in accordance with all applicable data protection laws. For example, IP addresses are deleted within twenty-four (24) hours. If you are an Account Owner, we will not keep a Student’s or other authorised users email address after you instruct us to delete it or fourteen (14) months after the last time the Student or authorised user signed-in to your account. In some circumstances you can edit or delete your Personal Data, see the “Your Rights” section of this Privacy Policy. We take reasonable measures to destroy or de-identify Personal Data in a secure manner when it is no longer required.

Your Rights

Rights of California Residents. If you are a resident of the State of California in the US, you are entitled to certain rights under the California Consumer Privacy Act of 2018 (“CCPA”). The categories of Personal Data we collect about or from you are described in the “Data Collection” section above, and the business purposes for which we collect such Personal Data are described in the “Why do we collect your Personal Data” section above. As a business subject to the CCPA, Digital Theatre does not sell Personal Data to third party service providers or business partners for our own business purposes as described in the “Disclosure of your Personal Data” section above. We do not offer an opt-out to the sale of Personal Data. However, we disclose your Personal Data to these third parties only where you have consented to disclosure of Personal Data to such third parties or where such third parties have agreed to contractual limitations around their use, retention, and disclosure of Personal Data. As a resident of the State of California, you have the following rights under the CCPA, the right to (a) request access to the Personal Data we collect from or about you (b) request details about how we process or disclose your Personal Data (c) request that we delete the Personal Data we have collected about you, subject to certain exceptions and (d) not to receive discriminatory treatment if you exercise your CCPA rights. We will not discriminate against you if you exercise your CCPA rights. If you are an Account Owner, we have certain obligations as a service provider towards you regarding your Personal Data under the CCPA. As a service provider, we only process Personal Data for the purposes of providing services as specified in our Agreement. We do not process your Personal Data collected through your account for any other purpose. To learn more about your rights under the CCPA, please visit https://oag.ca.gov/privacy/ccpa

Other California Privacy Rights. California “Shine the Light” Law (Civil Code Section 1798.83) permits users of our Education Platform or Marketing Website that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes.

Rights of UK or EU/European Economic Area (“EEA”) Residents. If you are in one of the EU/EEA countries, you are entitled to certain rights under the EU General Data Protection Regulation 2016/679 (“GDPR”). If you are in the UK, you are entitled to the same rights under the UK GDPR. By visiting the Education Platform, Marketing Website or communicating with us you acknowledge that we may process your Personal Data for the purposes described above, either on the basis of your consent or if we have other lawful grounds to do so. Under the GDPR or the UK GDPR, you have the below additional rights in respect of your Personal Data.

• Right to withdraw consent to processing, where consent is the basis for processing (withdrawing your consent will not affect the lawfulness of any processing conducted prior to your withdrawal, nor affect processing of Personal Data conducted on reliance on lawful processing grounds other than consent). This includes your right to withdraw consent to us using your Personal Data for marketing purposes.
• Right to access your Personal Data that we hold and request further details about how it's processed.
• Right to demand rectification of inaccurate Personal Data about you. Please note, if you are an Account Owner, you can access and update a broad range of information about your account (such as your contact information).
• Right to object to the unlawful processing of your Personal Data, including processing for direct marketing.
• Right to erasure of past data about you (your “right to be forgotten”).
• Right to restrict processing of your Personal Data if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or if you believe your Personal Data is inaccurate.
• Right to data portability of Personal Data that you provided us in a structured, commonly used, and machine-readable format.
• Right in relation to automated decisions you have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or significantly affects you, unless it is necessary for entering into an agreement with you, it is authorised by law or you have given your explicit consent. We will let you know when such decisions are made, the lawful grounds we rely on and the rights you have.
• Right to complain to a data protection supervisory authority in your country if you believe that we are processing your Personal Data in violation of applicable laws.

To learn more about your rights under the GDPR, you can visit the European Commission’s page on the Protection of Personal Data: https://europa.eu/european-union/index_en

To learn more about your rights under the UK GDPR, you can visit the Information Commissioner’s Office page: https://ico.org.uk/your-data-matters/

Rights of US Residents. In accordance with the Controlling the Assault of Non-Solicited Pornography and Marketing (“CAN-SPAM”) we acknowledge and comply with the following:

• We will not use false or misleading header information: all commercial emails will be identifiable as from Digital Theatre in relation to an event or product we provide.
• As far as reasonably possible all subject lines we use will accurately reflect the content of the message being delivered.
• We will identify relevant commercial messages as advertisements where applicable.
• We will tell you where we are located. For Digital Theatre US LLC: 1209 Orange Street, Wilmington, DE 19801. For Digital Theatre.com Limited this will be the address set out in the “Contacting Us” section of this Privacy Policy.
• We provide information on how to opt out of commercial communications. For more information, see the “Opting Out of Marketing Communications” section of this Privacy Policy.
• We will honour any opt out requests promptly. All unsubscribes captured via the link in all commercial emails are actioned within twenty-four (24) hours. Opt out requests sent to us at the details in the “Contacting Us” section of this Privacy Policy will be actioned in five (5) working days.
• As far as reasonably possible we monitor our third-party Marketing Partners. We only work with Marketing Partners who legally comply with all global regulations and continue to monitor activity to ensure our standards are upheld.

Exercising your rights. If you want to exercise any of the rights described above, please contact us using the contact details in the “Contacting Us” section of this Privacy Policy. 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, or we may refuse to comply with your request in these circumstances. Please note, if you are an Account Owner, as a Data Controller, you are responsible for protecting the rights of your Students and other authorised users. If a Student or other authorised user was to contact us regarding Personal Data on your account, we would promptly forward all requests or inquiries to you.

Opting Out of Marketing Communications

You may opt out of receiving marketing communications from us by following this link: https://email.digitaltheatreplus.com/hs/manage-preferences/unsubscribe and entering your email address or by clicking the “unsubscribe” link in a particular promotional communication. Alternatively, you can contact us at any time using the details in the “Contacting Us” section of this Privacy Policy. Please note that you cannot opt out from receiving all communications from us, including administrative messages, service announcements, and messages regarding the terms and conditions of your account because they may contain important information.

Children

In compliance with applicable data protection laws, we do not collect Personal Data from children under thirteen (13), without a parent or guardian's consent, or that of an institution if applicable. If we discover that we have collected or processed Personal Data from a child under the age of thirteen (13) without the consents required by law, we will immediately suspend the associated account and/or delete that Personal Data as soon as possible.

Changes to our Privacy Policy

Digital Theatre may update this Privacy Policy at any time. We encourage you to review this Privacy Policy regularly to make sure you are familiar with our most updated policies and practices. When we make material changes, such as a change to the purposes of processing of personal data that is not consistent with the purpose for which it was originally collected, we will notify you by email. Your continued use of our Education Platform, Marketing Website, and other products and services following the publication or notification of any changes will constitute acknowledgement and (as applicable) acceptance of those changes. This Privacy Policy was last updated on 10 August 2026.

Contacting Us

Data Protection Officer. If you have any queries about this Privacy Policy, including any requests to exercise your legal rights, all correspondence should be directed to Digital Theatre’s data protection officer by email at DPO@DigitalTheatre.com. You may also send inquiries to the following postal address:

Information from you. Please note that if you contact us to assist you, we may need to request specific information from you to ensure that Personal Data is not disclosed to any person who has no right to receive it.

Our response. We try 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 a number of requests. In this case, we will notify you and keep you updated.

European Representative under Article 27 of GDPR

We have appointed EU Rep as our Representative under Article 27 of the GDPR. All GDPR queries from EU Data Subjects or Data Protection authorities should be addressed to privacy@eurep.ie. BizLegal Ltd trading as EU Rep have their registered office at: 27 Cork Road, Middleton Co. Cork, Ireland. Company number 635921.

Complaints

You have a right to make a complaint to a supervisory authority at any time. In the UK, this is the Information Commissioner’s Office ("ICO") (https://www.ico.org.uk). If you are in the EU/EEA/US you may also submit unresolved complaints to binding arbitration in front of the American Arbitration Association (“AAA”) under certain conditions. Information about AAA services can be found at: https://go.adr.org/. We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO or AAA, so please contact us in the first instance using the details in the “Contacting Us” section of this Privacy Policy.

Notice to Students and other authorised users

If you access the services through an account provided by your Institution, your Institution is solely responsible for adhering to legal and regulatory requirements, including the collection and maintenance of any necessary rights, permissions, and consents for the Personal Data which they collect and process. If we discover we have processed Personal Data from a child without the requisite consents required by law, we will immediately suspend your account and/or delete your Personal Data.

If your Institution provides you with access to our services, your use of the services is subject to your Institution’s policies (if any). You should direct all enquiries including any requests to exercise your data protection rights to your Institution’s administrator. We are not responsible for the privacy or security practices of our Account Owners, which may differ from those set forth in this Privacy Policy.

If you are a Student, you should also direct all enquiries regarding technical support to your Institution. It is our policy to revert any support service requests from a Student to your Institution. If you are an authorised user over the age of eighteen (18), you may submit a support service request to us. Please note, we may collect personal information (for example, your device, usage, and contact data) to diagnose and resolve problems.

When you use our services through your Institution’s account, our processing of your Personal Data in connection with that service is governed by the Agreement between us and your Institution. We process your Personal Data to provide the services to your Institution and you, and for our legitimate business operations relating to providing that service, in accordance with the Agreement. As mentioned above, if you have any questions about our processing of your Personal Data in connection with providing services to your Institution, please contact your Institution.

Notice to Parents or Legal Guardians

If you are a parent or guardian of a child under the age of thirteen (13) under the Children’s Online Privacy Protection Act, you have the right to access your child’s Personal Data or request that it be deleted through your School’s administrator (“Administrator”). If you wish to stop any further collection or use of your child’s information, you can request that the Administrator use the service controls available to them to limit the child’s access to the services or delete the child’s account access entirely.