Cookie & Privacy Policy

  1. 1 Important notice

    This is the privacy notice of Atkey Solutions Limited (company number: 03927663) whose registered office is at Howard Buildings, 69-71 Burpham Lane, Guildford, Surrey GU4 7NB (referred to in this notice as we, us or our). Please read this privacy notice to understand how we may use your personal data.

    The notice sets out how we may collect and process your personal data depending on the nature of your interactions with us (for example, whether you are a browser of our website, a recipient of information about our products and services or a customer of our products and services). The notice also provides certain information that is legally required to be provided to you and lists your rights in relation to your personal data.

    The notice relates to personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual who browses our website or an individual outside our organisation with whom we interact. If you are an employee, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead). We refer to this information throughout this privacy notice as personal data and section 3 sets out further detail of what this includes.

    Please note also that this notice is not intended to cover how we handle the personal data of our clients’ employees and contractors when they use our products and services (as purchased by our clients). In those circumstances: (i) each of our clients will be a controller and we will be their processor, processing such personal data on their behalf; and (ii) if you are such an employee or contractor you should refer to your employer’s own privacy notice to understand how we may process your personal data on their behalf.

    This privacy notice may vary from time to time so please check it regularly.

  2. 2 How to contact us

    Controller and contact details

    For the purposes of relevant data protection legislation, we are a controller of your personal data. As a controller we use (or process) the personal data we hold about you in accordance with this privacy notice.

    If you need to contact us in connection with use or processing of your personal data, then our contact details are gdpr@blueskyeducation.co.uk and our representative is Darren Inwood.

  3. 3 Categories of personal data we collect

    The categories of personal data about you that we may collect use, store, share and/or transfer are:

    • Individual Data. This includes personal data which relates to your identity, such as your name, username or similar identifier and your contact details
    • Account and Profile Data. This includes personal data which relates to your account or profile on our website or app, such as your username and password, feedback and survey responses
    • Advertising Data. This includes personal data which relates to your advertising preferences, such as, if applicable, information about your preferences in receiving marketing materials from us and your communication preferences as well as your personal interests
    • Advertising Data. This includes personal data which relates to your advertising preferences, such as, if applicable, information about your preferences in receiving marketing materials from us and your communication preferences as well as your personal interests
    • Information Technology Data. This includes personal data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website
    • Sales Data. This includes personal data which relates to the transactions you have conducted with us, such as details about payments from you including bank account, details of subscriptions to our services or publications and other details of products and services you have purchased from us
    • Market Research Data. This includes personal data which is gathered for the purposes of market research and surveys

    We may also create personal data about you, for example, if you contact us by telephone with a query about our services or goods, then we may make a written record of key details of the conversation so that we can take steps to address the query.

    We also obtain and use certain aggregated data such as statistical or demographic data for any purpose (Aggregated Data). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Information Technology Data to calculate the percentage of users accessing a specific feature on our website. However, if we re-combine or re-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 privacy notice.

  4. 4 The sources from which we obtain your personal data

    We obtain your personal data from the following sources:

    • directly from you, either in person, via our website; by telephone or via mobile devices. This could include personal data which you provide when you:
      • establish an account on our website
      • subscribe to any of our mailing or newsletter services
      • personal data gathered using cookies
      • enter into a competition or promotion
      • complete surveys from us, and
      • submit a query to us or participate in discussion boards and social media functions on our website, and
      • details of your visits to our website including but not limited to traffic data, location data, weblogs and other communication data
    • automated technologies, such as cookies, server logs and other similar technologies. We may automatically collect Information Technology Data about your equipment, browsing actions and patterns by using cookies, server logs and other similar technologies. We may also receive Information Technology Data about you if you visit other websites employing our cookies. Please see our cookie policy in section 13 below for further details
    • third parties, such as:
      • analytics providers
      • service providers
      • providers of social media platforms (such as Facebook, Twitter and Instagram) for example where you share our content through social media, for example, and
    • publicly available sources.

    We also work closely with third parties (for example payment service providers, technical business partners, advertising analytics providers, search engine information providers, logistics service providers and subcontractors who provide services and goods to us to enable us to fulfil our customer contracts). If we receive information about you from them, we will inform you of this and the purposes for which we intend to use that information.

  5. 5 How we use your personal data and the legal basis

    We may rely on one or more of the following legal bases when processing your personal data for the following purposes:

    Purposes for which we process your personal data Categories of personal data The basis on which we can do this (this is what the law allows)

    In order to perform our contractual obligations to you. This would include our fulfilling orders you have placed for goods or services

    • Account and Profile Data
    • Individual Data
    • Sales Data

    The processing is necessary in connection with any contract that you may enter into with us

    In order to comply with our own legal obligations, e.g. health and safety legislation, or to assist in an authority’s investigation

    • Account and Profile Data
    • Individual Data
    • Information Technology Data
    • Sales Data

    The processing is necessary for us to comply with the law and our legal requirements

    In order to use your personal data to operate our business, but otherwise than in performing our contractual obligations to you, for example:

    • to send you important notices such as communications about changes to our terms and conditions and policies
    • to provide you with important real-time information about products or services you have ordered from us
    • to send you information you have requested
    • to deal with your enquiries
    • to develop, deliver and improve our goods or services
    • to assess the effectiveness of marketing and advertising campaigns
    • to help us develop our website to be more useful
    • in order to take steps to keep the website and your information safe and secure
    • to deal with any misuse of our website
    • for internal purposes for troubleshooting, testing and analytical purposes
    • for consumer research purposes to help us learn more about our customers and how they use our website
    • for risk management and administrative purposes
    • to protect and defend our rights or property
    • to sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers, or
    • in order to enforce or apply our terms of use, terms and conditions of supply and other agreements with third parties
    • Account and Profile Data
    • Advertising Data
    • Individual Data
    • Information Technology Data
    • Market Research Data
    • Sales Data

    We have a legitimate interest in carrying out the processing, which is not overridden by your interests, fundamental rights or freedoms. Our legitimate interest is as follows:

    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the provision of goods and services
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in informing our market strategy
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the management and operation of our business
    • our legitimate interest in the management and operation of our business

    How we contact you about other products and services

    We may from time to time process your personal data to let you know about similar products and services that may be of interest to you, to deliver relevant website content and advertisements to you and to measure or understand the effectiveness of our advertising. This is because we value your custom and we pride ourselves in offering a professional and high quality service.

    Our lawful basis for processing your personal data in this way, unless we have otherwise obtained your consent to do so, is as is necessary to pursue the legitimate interests of our business to develop our products and services and ensure our marketing is relevant, to grow our business and to inform our marketing strategy. We may contact you by post, telephone or e-mail.

    We give you the option to stop receiving any communications from us in this regard at any time by providing you with details in such communications of how to unsubscribe from such communications, however please note that this will not affect us contacting you about the servicing of products that you have specifically requested from us.

  6. 6 Who receives your personal data

    We may disclose your personal data:

    • to our third party data processers who may process data on our behalf to enable us to carry out our usual business practices (these include performing a range of business related functions for us such as hosting and maintaining our website, maintaining our databases, processing payments and, mailing information services) and logistics and other suppliers and subcontractors that help us perform any contract we have entered with you. In each case any such disclosure will only be so that we can process your personal data for the purposes set out in this privacy notice
    • to analytics and search engine providers that help us improve our website and third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website which you choose to interact with
    • to legal and regulatory authorities who request your personal data or to report any potential or actual breach of applicable law or regulation
    • to external professional advisers such as accountants, auditors and lawyers, provided that they are under duties of confidentiality
    • where we are under a duty to disclose your information in order to comply with any law, in order to enforce our terms of business or to protect the rights, property or safety of our customers or the public, or protect against legal liability
    • to law enforcement agencies, courts or other relevant parties, to the extent necessary for the establishment, exercise or defence of legal rights
    • to third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties
    • to third parties which are considering or have decided to buy some or all of our assets or shares (including in the event of a reorganisation, dissolution or liquidation)
  7. 7 Personal data about other people that you provide to us

    If you provide personal data to us about someone else (such as one of your employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this privacy notice.

    You must ensure the individual concerned is aware of the various matters detailed in this privacy notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

  8. 8 Where we store your personal data

    We take the security your personal data seriously and have technical and organisational measures to ensure a level of security appropriate to the risk.

    We use a mixture of measures including utilising technology to combat cybersecurity, data management techniques, user access and management procedures, physical security and guidelines for personnel.

    Our measures are aimed at having the ability to:

    • ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services, and
    • restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
  9. 9 How long we store your personal data

    We will store your personal data in accordance with our data retention policy, which sets out the categories of information we hold as a business and specific retention periods for each such category. These retention periods take into consideration the requirements of data protection law, the requirements of other laws to keep information for certain minimum periods, the limitation periods for legal action and good industry practice. The period for which we may keep your personal data in line with our data retention policy will depend on the nature of your interactions with us. If you would like to know more about a specific retention period for your personal data we process you can contact us at gdpr@blueskyeducation.co.uk. Finally, please do also note that where you unsubscribe or opt out from a marketing communication, we need to keep a record of your email address to ensure we do not send you marketing emails in the future.

  10. 10 Contractual or statutory requirements on you to provide personal data

    In certain circumstances the provision of personal data by you is a requirement:

    • to comply with the law or a contract; or
    • necessary to enter into a contract.

    It is your choice as to whether you provide us with your personal data necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal data then the consequences of failing to provide your personal data are that we may not be able to perform to the level you expect under our contract with you. An example of this would be where we are unable to provide you with certain products or services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal data you provide in order to do so.

  11. 11 Your rights in relation to your personal data

    Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data (see section 5), you may have a number of rights in connection with the processing of your personal data, including:

    • the right to request access to your personal data that we process or control. You can also update your personal information yourself by logging in to your account and updating your account details
    • the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed
    • the right to request, on legitimate grounds as specified in law:
      • erasure of your personal data that we process or control, or
      • restriction of processing of your personal data that we process or control
    • the right to object, on legitimate grounds as specified in law, to the processing of your personal data
    • the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent or for the performance of a contract with you, and
    • the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.

    If you would like to exercise any of the rights set out above, please contact us using the contact details set out in section 2.

  12. 12 Links to other websites

    This policy only applies to us. If you link to another website from our website, you should remember to read and understand that website’s privacy policy as well. We are not responsible for any use of your personal data that is made by third party websites.

  13. 13 Cookies

    What is a cookie?

    A cookie is a small text file which is placed on your hard drive by the websites which you visit. Cookies collect information about how the website is being used by those accessing it and allow websites to remember information. You can find out more about cookies at www.allaboutcookies.org.

    Which cookies does this website use?

    The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide. Please see below for descriptions of categories of cookies this website uses.

    Strictly Necessary Cookies

    These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for cannot be provided.

    Performance Cookies

    These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All the information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

    Functional Cookies

    These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

    How can cookies be removed?

    You can remove cookies set by this website and/or block the placing of further cookies on your hard drive by changing the browser settings on your computer. For practical guidance on how to do this, please refer to the “help” menu on your browser or visit the following website http://www.allaboutcookies.org/manage-cookies/future. Please be aware however that blocking cookies may hamper the website’s functionality or restrict how much of the website you can access.