Privacy Notice

1. SCOPE

Satchel ('Satchel', 'we', 'us') takes the protection of privacy very seriously. This notice describes how we collect, use, and handle your personal data. It also describes your data protection rights, including a right to object to some of the processing which Satchel carries out. More information about your rights, and how to exercise them, is set out in the 'Your rights?' section below.

This notice applies to the information Satchel collect from parents and their children when they use Satchel Classes.

Teachercentric Ltd will be the data controller for the personal data which is hosted in Satchel Classes. For information on how personal data is processed in our flagship application, Satchel One, please see the Satchel One privacy notice here.

2. WHO WE ARE

We are Satchel, our flagship product, Show My Homework, was launched in 2011 by former assistant head teacher, Naimish Gohil, who had a vision to transform the way homework and technology was approached in schools. Our software is now used in over 1 in 3 secondary schools in the UK and in 23 countries across the world, making a difference to the lives of millions of students and parents.

Satchel Classes is the new service that aims to democratise access to catch-up learning and work experience opportunities by providing free and low-cost classes for students around life skills, careers guidance and curriculum support, broadening their horizons and supporting them in learning new skills throughout school and beyond.

The website www.teamsatchel.com, and Satchel apps in the UK are run by Satchel.

3. WHAT INFORMATION DO WE COLLECT?

We collect and process the following information:

• your first name
• your last name
• your email address
• your mobile number (which is optional)
• your payment information
• your marketing preferences, including any consents you have given us;
• Information about your child’s education (e.g. Year Group / Subjects Studied)
• Information you provide in enquiry forms;
• information related to the browser or device you use to access our website.

Sometimes, we receive information about you from third parties. This may include, information from publicly available sources such as LinkedIn and in some cases obtaining information (such as email contact lists) from data suppliers.

4. HOW DO WE USE THIS INFORMATION?

We process this data for the following purposes:

• To fulfil a contract, or take steps linked to a contract including:
• To provide Satchel Classes and our website, and ancillary services such as customer support.
• To authenticate users of Satchel Classes.
• Taking payments for the purchase of Satchel Classes online digital content.
• To send you service, technical and other administrative emails relating to Satchel

Classes and our website, messages and other types of communications, like two factor authentication and resetting your password.

As required by Satchel to conduct our business and pursue our legitimate interests, in particular:

• To ensure Satchel Classes and our website is working as intended, such as tracking outages or troubleshooting issues that you report to us.
• To make improvements to Satchel Classes and our websites and to help us develop new products and services.
• To respond to enquiry forms that you complete on our website.
• We use data for analytics and measurement to understand how Satchel Classes and our website is used. For example, we analyse data about your use of Satchel Classes to do things like optimise product design. This information can consist of information such as geographical location, browser type, referral source, length of visit, pages viewed and phone make and model.
• We use information you provide to investigate any complaints received from you or from others, about Satchel Classes, our website or other services.
• For direct marketing purposes including creating a profile about you to better understand you and tailor the marketing we serve you (including on social media). This may include information about Satchel Classes or information about our other products and services.
• We will use information in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
• To conduct surveys and other market research to ensure our services are relevant to your needs.

Where you give us consent:

• Linking information stored in your Satchel One account to your Satchel Classes account
• where required by law to send you direct marketing in relation to our services;
• we place cookies and use similar technologies. See our Cookie Policy and
• on other occasions where we ask you for consent, we will use the information for the purpose which we explain at that time.

For purposes which are required by law:

• In response to requests by government or law enforcement authorities conducting an investigation.

5. DISCLOSURE

• Vendors and service providers. We will share your personal information with third party service providers who support our business, who will process it on behalf of Satchel for the purposes identified above. Such third parties include providers of hosting services and technical infrastructure CRM services, customer support services, and marketing services. Some of our key service providers are listed below:

• Legal reasons. We will share personal information outside of Satchel if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to (i) enforce applicable terms of service or other agreements, including investigation of potential violations and audits, (ii) detect, prevent, or otherwise address fraud, abuse, security risks, or technical issues, and (iii) protect against harm to the rights, property or safety of Satchel, our users, or the public as required or permitted by law.
• Group companies. We may share your information with our group of companies for the purposes of business administration, maintaining security and regulatory compliance, providing support services to end users (including IT support, where relevant), marketing and analytics.
• Business transfers. In the event that Satchel undergoes any reorganisation, restructuring, merger, sale, or other transfer of assets your information will be disclosed to our advisers and any prospective purchaser's adviser and will be passed to any new owners of the business.

6. INTERNATIONAL TRANSFER

In connection with the purposes identified above, your personal information may be transferred outside the UK and the European Economic Area ('EEA'), including to the United States. Where information is transferred outside the UK or EEA that is not subject to an adequacy decision by the EU Commission, information is adequately protected by EU Commission approved standard contractual clauses, or a vendor's Processor Binding Corporate Rules. For more information on the transfer mechanism used, please contact us at the details set out below. We are also aware of the CJEU ruling “Schrems II” and have reviewed our international transfers to ensure we no longer rely on EU-US Privacy shield as the basis for any of our International Transfer to the USA.

7. RETENTION

For non-Satchel Classes users (such as prospects and business contacts) we will process and store personal data while we are in contact with you with relevant information on our services. If we have not contacted you for a period of 2 years your data will then be removed from our system automatically.

If you have opted out to your data being processed or have chosen to close your Satchel Classes account we will delete your data within 28 days of your opt out being received.

Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time.

Reasons we might retain some information for longer periods of time include security, fraud prevention, financial record-keeping, complying with legal or regulatory requirements.

8. YOUR RIGHTS

Where required by applicable law or regulation, you have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this information to another controller.

In addition, you can object to the processing of your personal information in some circumstances (in particular, where we don't have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing). These rights may be limited, for example if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights - or get a copy of our legitimate interest balancing tests - you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an information protection authority where you live, work or where you believe a breach may have occurred.

For the provision of information marked as mandatory when you register to use Satchel Classes, if such information is not provided, then you will not be able to use the service. All other provision of your information is optional. If you do not provide such information, our provision of certain services to you may be detracted from.

9. CONTACT DETAILS

Our Data Protection Officer and data protection representatives can be contacted directly here:

By email: DPO@teamsatchel.com
By Mail: Data Protection Officer 3rd Floor, 65 Clerkenwell Road, London, EC1R 5BL, United Kingdom