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STUDEO

PRIVACY AND COOKIES POLICY

Welcome to Studeo’s Privacy and Cookies Policy.

Studeo respects your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when you visit and use Studeo’s website or app, and tell you about your privacy rights and how the law protects you. References to “we”, “us”, or “our” in this Policy mean Studeo.

We ask that you read this Policy carefully.

This Policy is divided into the following sections:

Section 1: Privacy Policy

Who we are, purpose of this privacy policy, and our processing role
Contact details:
Our collection and use of your personal data
How we use your personal data and our lawful basis
Transfers of your personal data out of the UK and EEA
Marketing
Your rights
Keeping your personal data secure
How to complain
Changes to this Policy Section 2: Cookies Policy Section 3: Payment and Trial

SECTION 1: PRIVACY POLICY

Who we are, purpose of this Policy and our processing role:

STUDEO LIMITED is a company registered in England and Wales under company number 12788770. Studeo operates a website (the “Site”) and an application (the “App”) which provide e-learning educational content (the “Digital Learning Material”) aimed at learners who are at the secondary or sixth-form stage of their education. For more information see our website studeo.app

As such, we collect and use the personal data of two categories of data subjects:

Visitors to our Site or App;
Buyers of and Subscribers to the Digital Learning Material with accounts on the Site and App, a and those conducting purchase on a guest

We collect, use and are responsible for certain personal data about you. When we do so we are regulated under the UK GDPR (consisting of the UK Data Protection Act 2018, as amended and updated in light of the UK’s departure from the European Union) and the EU GDPR (the General Data Protection Regulation (EU) 2016/79, as amended from time to time), as applicable based on your location in the United Kingdom or the European Union, and we are responsible as ‘controller’ of that personal data for the purposes of those laws.

We do not knowingly collect personal data from children under the age of 13. If you are under the age of 13, please do not attempt to register for membership or send any information about yourself, including your name, address, telephone number, or email address. Instead, please ensure this is done through your parent or guardian, and that they expressly consent to your use of our Site and App and services by checking the consent box upon sign up or prior to purchase or subscription of our Digital Learning Material.

If you are a parent or guardian of a child under the age of 13 and become aware that your child has provided personal data to Studeo without your consent, please contact us using the ‘Contact Us’ form on the website, and you may request exercise of your applicable rights detailed in the section “Your rights” below.

If we learn that we have collected the personal data of a child under the age of 13 years who does not have parent or guardian consent to do so, we will take reasonable steps to delete the personal data. This may require us to delete the Studeo account for that child.

Throughout the Site or the App, we may link to other websites owned and operated by certain trusted third parties to make additional materials and external services available to you. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Contact details:

If you have any questions about this Policy or our privacy or tracking practices, please contact us using the following details:

Full Name of Legal Entity: STUDEO LIMITED Email Address: hello@studeo-online.com

Postal Address: 86-90 Paul Street, EC2A 4NE, London

You have the right to make a complaint at any time to your local supervisory authority. If you are based in the United Kingdom, this will be the Information Commissioner’s Office (the ICO), who is the UK regulator for data protection issues. For more information, please visit www.ico.org.uk.

If you are based in the European Union, please consult the following website to find out the details of your local supervisory authority, https://edpb.europa.eu/about-edpb/board/members_en.

We would, however, appreciate the chance to respond to your query and deal with your concerns before you approach a supervisory authority.

Our collection and use of your personal data:

We collect personal data about you when you access our Site and App, create an account with us, purchase/subscribe to Digital Learning Material, contact us, send us feedback, create content to our Digital Learning Material and complete surveys or participate in competitions via our Site and App.

We collect this personal data from you either directly, such as when you create an account with us, contact us or subscribe to or purchase Digital Learning Material via our Site and App, or indirectly, such as your browsing activity while on our Site or when using the App (see Section 2 – Cookies Policy below for more information on the cookies we use).

The personal data we collect about you depends on the particular activities carried out through our Site and App.

If you create an account on the Site/App to purchase Digital Learning Material, we collect the following personal data:

your name, billing and delivery address and contact details such as email address and telephone number;
date of birth;
credit card or other payment information, so we can process payments (even if the payment information we have access to may be limited where we use a third party payment provider);
details of any feedback you give us by phone, email, post or via social media;
information about the services we provide to you and the Digital Learning Material you are interested in purchasing, or have purchased;
your account details, such as username, login details;
IP address, login data, browser type and version, operating system and platform, and device data;
usage data on how you use our Site, App, and services; and
your preferences in receiving marketing from us and your communication preferences.

If you are a parent or guardian creating an account on the Site/App to purchase Digital Learning Material for your children, we collect the following personal data:

information about your children, including their name, age, gender and other information relevant to us providing services to you;
information about the Digital Learning Material you have purchased through our Site and App; and
confirmation of the age of the child/your children and your relationship to them (i.e., parent, guardian or other responsible person).

If you are a visitor to the Site or App, but do not have an account or have not purchased or subscribed to any Digital Learning Material via the Site or App, we only collect the following personal data about you:

IP address, login data, browser type and version, operating system and platform, and device data;
usage data on how you use our Site and App, and services; and
your preferences in receiving marketing from

We use this personal data to:

create and manage your account with us, both when you are a user, parent or guardian, including provide Digital Learning Material on our Site and App that you have requested;
verify your identity;
provide our services and Digital Learning Material to you;
customise our Site and App and its content to your particular preferences and requirements;
notify you of any changes to our Site and App or to our services that may affect you; and

improve our

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Site or App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we use your personal data and our lawful basis for processing your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

If you are a user, parent or guardian who has purchased access to Digital Learning Material via the Site/App, we will process your personal data to perform the contract we are about to enter into or have entered into with you;
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; or
Where we need to comply with a legal

When we process your personal data, we are required to have a lawful basis for doing so. There are various different lawful bases on which we may rely, depending on what personal data we process and why.

Please see the below for more information on the lawful basis that we may rely on:

consent: where you have given us clear consent for us to process your personal data for a specific purpose (including so that we can provide you with direct marketing – please note you can withdraw such consent at any time by contacting us or clicking on the unsubscribe link in any email you receive)

contract: where our use of your personal data is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract

legal obligation: where our use of your personal data is necessary for us to comply with the law (not including contractual obligations)

legitimate interests: where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides our legitimate interests)

Further information—the personal data we collect, when and how we use it

For further details on when we collect personal data, the type of data we collect as well as the lawful basis we rely on, please read the following table:

Purpose for processing your personal data

Type of data

Lawful basis for processing including basis of legitimate interest

To create an account for you as a user on the Site and App

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your purchase including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(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:

(a) Notifying you about changes to our Terms of Use or Privacy and Cookies Policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(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 users use our materials/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how users use our materials/services, to develop them and grow our business)

To administer and protect our business and the Site and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(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 re-organisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Site and App content and advertisements to you and measure or understand

the effectiveness of the

(a) Identity

(b) Contact

Necessary for our legitimate interests (to study how users use our materials/services, to develop them, to grow our business and to inform our marketing strategy as well as

the business interests and marketing

advertising we serve to you

(d) Usage

(e) Marketing and Communications

(f) Technical

strategy and our sourcing and engagement of expert teachers, tutors who procure or provide us with Digital Learning Material to supply on the Site and App)

To use data analytics to improve our Site and App, materials/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of users for our materials and services, to keep our Site and App 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

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our materials/services and grow our business)

Who we share your personal data with

If you are a user on the Site and App, we may share your personal data such as with various third party suppliers who help us to provide our App, Site, Digital Learning Material and content, and our services to you. A list of these third party suppliers is available by contacting us.

This data sharing enables us to provide you with our Site and App, any Digital Learning Material and any other service you have requested.

Some of those third party recipients may be based outside the United Kingdom and European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the UK and EEA’ below.

We will share personal data with law enforcement or other authorities if required by applicable law.

Where we do engage third party suppliers who process personal data about you on our behalf, we always ensure that they are bound by a contract which imposes obligations of confidentiality and security on the handling of your personal data, that they only process your personal data in accordance with our written instructions, and which also contain all of the compulsory provisions as required by applicable data protection laws.

Transfer of your personal data out of the UK and EEA

We may transfer your personal data to the following which are located outside the United Kingdom (UK) and European Economic Area (EEA). Where we transfer your personal data outside of the UK and the EEA, we will only do so for the purposes mentioned in this Policy and any contract that we have entered into with you or the entity that you are representing.

Countries outside of the UK and the EEA do not have the same data protection laws as the UK and EEA. Therefore, when making such a transfer of data, we will always rely on a safeguard mechanism

under the UK GDPR and/or the EU GDPR. We will only transfer your personal data to a country which the European Commission or the UK authorities have given a formal adequacy decision/regulation that confirms this third-country provides an adequate level of data protection similar to those which apply in the UK and EEA. If the third-country does not have an adequacy decision awarded to it, any transfer of your personal information will be subject to entering into the European Commission’s Standard Contractual Clauses (the SCCs) which are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

Transfers of personal data from the UK to the EEA shall be done on the basis of the adequacy regulation awarded to the European Union by the UK pursuant to the withdrawal of the UK from the European Union. Transfers of personal data from the EEA to the UK shall be done on the basis of: (a) the right to freely transfer personal pursuant to the bridge period agreed between the UK and the EU, currently set to expire four months after the withdrawal of the UK from the European Union on 31 December 2020; and (b) thereafter, either on the basis of an adequacy decision awarded by the European Commission to the UK, and notwithstanding this, by entering into the SCCs for any such transfers of personal data.

If you would like further information please contact us using the details provided at the start of this Policy. We will not otherwise transfer your personal data outside of the UK and the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Marketing

We would like to send you information about the Site and App, our services, our Digital Learning Material and any special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.

We will ask whether you would like us to send you marketing messages when you provide consent to such marketing, or where you have purchased products from us.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

—contacting us using the detail provided at the beginning of this Policy;

—using the ‘unsubscribe’ link in emails; or

—updating your marketing preferences via help@studeo-online.com

Your rights

Under the UK GDPR and the EU GDPR, you have a number of important rights free of charge. In summary, those include rights to:

fair processing of information and transparency over how we use your use personal data

access to your personal data and to certain other supplementary information that this Policy is already designed to address

require us to correct any mistakes in your personal data which we hold

require the erasure of personal data concerning you in certain situations

receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

object at any time to processing of personal data concerning you for direct marketing

object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

object in certain other situations to our continued processing of your personal data

otherwise restrict our processing of your personal data in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please email or write to us using the details provided at the beginning of this Policy.

We will require information from you to allow us to identify you. We will endeavour to respond to all requests with 30 days of receipt.

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this Policy

This Policy was published on 23 April 2021 and last updated on 23 April 2021.

We may change this Policy from time to time, when we do, we will update this Policy on the Site or within the App.

SECTION 2: COOKIES POLICY

Please read this Cookies Policy carefully as it contains important information on how we use cookies on our Site and App.

Cookies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you visit and use our Site and App. We may use cookies on our Site and App. When we do use such cookies, these will help us to recognise you and your device and store some information about your preferences or past actions.

For example, we may monitor how many times you visit the Site and App, which pages you go to, traffic data, location data and the originating domain name of your internet service provider.

When we do so, this information helps us to grow our business and provide more tailored content for you. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

Consent to use cookies and changing settings

We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (e.g. to enable you to have access to the Digital Learning Material you chose and use our check-out process).

You can withdraw any consent to the use of cookies or manage any other cookie preferences by following instructions on our Site and/or within the App.

Our use of cookies

We will use third party analytics tools from time to time to record browsing sessions on our Site, but these tools cannot identify unique users across different browsers or devices. Currently on our Site’s landing page, we are not storing any information which will uniquely identify users.

On our App, we are using Facebook as a third-party service to sign-up and login, but are not sharing any cookies or data with Facebook.

We will update you via this page should our use of cookies or third-party providers change. Where legally required to do so, we will request your consent prior to placing any such cookies which are for non-functional, non-necessary purposes, which you may withdraw at any time.

Third party access to the cookies

Currently we are also not sharing any data with any third party and any data collected via cookies will only be accessed by Studeo. We will update you via this page should this change and will ask for you prior consent to such cookies where we are legally required to do so. Any third party that places cookies on our Site or App, including on your browser (such as Google) will have their own privacy policies which you must check and agree to before permitting the placement of such cookies. We are not responsible for third party cookies which are placed on our App or Site without our consent.

How to turn off all cookies and consequences of doing so

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our Site and App.

For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

How to contact us

Please contact us using the details provided at the beginning of this Policy if you have any questions about this cookie policy or the personal data we hold about you.

SECTION 3: PAYMENT AND TRIAL

Trials: Ordering or subscribing to Digital Learning Material from us

From time to time, we may offer trials for a subscription to our Digital Learning Material for a specified period without payment or at a reduced rate (a Trial). We may determine your eligibility for a Trial, and withdraw or modify a Trial at any time without prior notice and with no liability, to the extent permitted under applicable law. For the avoidance of doubt, a Trial is not available for monthly subscriptions.

These Terms will apply to any Trial you have with us. As set out in clause 1 below, if wish to participate in a Trial you must provide us with your payment details in order to do so.

Below, we set out how a legally binding contract between you and us is

You can order or subscribe to our Digital Learning Material via the app by selecting your relevant subscription tier or the course that you wish to purchase. Details of our subscription tiers are available at https://studeo.app/upgrade . Please read and check your order or subscription carefully before submitting it and correct any errors.

We may offer different subscription periods, for example monthly, 3-monthly, semi-annual or annual subscriptions (Subscription Period). Details of the associated fee for each (Subscription Fees) will be set out on our app and

Before you subscribe to our Digital Learning Material, you must check that the hardware and software requirements of your computer or device mean that you can access and stream the Digital Learning

When you place your order or subscription at the end of the subscription process (e.g., when you click on the SUBSCRIBE/PAY NOW), we will acknowledge it by This acknowledgement does not, however, mean that your order or subscription has been accepted by us.

We may contact you to say that we do not accept your order or subscription. This is typically for the following reasons:

the Digital Learning Material is unavailable;

we cannot authorise your payment;

you are not allowed to buy or subscribe to the Digital Learning Material from us;

we are not allowed to sell or provide the Digital Learning Material to you; or

there has been a mistake on the pricing or description of the Digital Learning

We will only accept your order or subscription when we email you to confirm this (Confirmation Email). At this point:

a legally binding contract will be in place between you and us; and

the Digital Learning Material will be available for you to stream

If you are under the age of 18 you may buy or subscribe to any Digital Learning Material from our site or app, but you need to ensure that you have parental or guardian consent to do so. If you are under the age of 13, please do not attempt to register for membership or send any information about yourself without parental or guardian consent. This will be verified when you sign up via the app by your parent or guardian clicking a consent box on your

2. Payment

If you wish to participate in a Trial, you must provide your payment details to us in order to start the

By providing such payment details, you agree that we will automatically begin charging you for the Services on the first day following the end of the Trial on a recurring basis in accordance with your selected Subscription Period or other interval that we disclose to you in advance. If you do not want this charge, you must cancel the subscription before the end of the Trial by contacting You acknowledge and agree that if you fail to cancel the subscription prior to the end of the Trial, you are not entitled to a refund for any portion of the Subscription Fee.

You may purchase any of our subscriptions directly from us by paying a Subscription Fee in advance of each Subscription Period. Details of our subscription tiers are available here https://studeo.app/en/upgrade

We may change the price for our subscriptions, including any recurring Subscription Fees from time to time, and will communicate any price changes to you in advance and, if applicable, how you can accept those

Price changes will take effect at the start of the next subscription period following the date of the price change. Subject to applicable law, you accept the new price by continuing to use our services after the price change takes effect. If you do not agree with a price change, you have the right to reject the change by unsubscribing from your current subscription prior to the price change going into effect as per these terms and conditions or as otherwise set out on our subscription information page: https://studeo.app/en/upgrade

Subject to section 4 above and section 10 below, if you purchase a subscription, you authorise us to charge you automatically at the commencement of each Subscription Period until you cancel in accordance with these terms and conditions or the terms of our subscription tiers available here: https://studeo.app/en/upgrade

Studeo uses third-party online payment partners, currently Stripe, Apple Pay and Google Pay (each an Online Payment Partner) to process debit and credit card payments for your Studeo account and access to the Digital Learning

The processing of payments by the Online Payment Partner will be, in addition to this agreement, subject to the terms, conditions and privacy policies of the Online Payment

You warrant that you have read, understood and agree to be bound by (as applicable):

Stripe’s terms at https://stripe.com/gb/legal/ssa and privacy policy at https://stripe.com/gb/privacy
Apple Pay’s terms at https://www.apple.com/legal/applepayments/direct-payments/ and privacy policy at https://www.apple.com/uk/legal/privacy/data/en/apple-pay/;
Google Pay’s terms at https://payments.google.com/payments/apis- secure/u/0/get_legal_document?ldo=0&ldt=googlepaytos&ldl=und and privacy policy at https://policies.google.com/privacy.
- You understand and agree that Studeo shall not be held liable for any payments and monetary transactions that occur through your use of the Online Payment Provider and that all such payments and transactions are handled by the respective Online Payment You agree that Studeo shall not be held liable for any issues regarding financial and monetary transactions between you and any other party, including the Online Payment Provider.

You are solely responsible for all transactions (one-time, recurring, refunds and cancellations) processed through Studeo and/or the Online Payment Provider. Studeo will not be liable for any losses or damages arising from invalid or fraudulent transactions processed with the Online Payment Provider. This includes but is not limited to transactions that were not processed due to a network communication issue. If you process a transaction, it is your responsibility to ensure it has been fully settled.

You understand that Studeo uses the Online Payment Provider’s API to run this service and that the Online Payment Provider’s API is subject to change at any time and such changes may adversely affect the service. You understand and agree to not hold Studeo liable for any adverse effect that actions (whether intentional or unintentional) on the part of the Online Payment Provider may cause to your account with the Online Payment Provider or your Studeo’s account.