What does this Privacy Notice do?

This Privacy Notice (“Notice”) explains Shaping Little Minds information processing practices. It applies to any personal information you provide to us and any personal information we collect from other sources. This Notice is a statement of our practices and of your rights regarding your personal information. This is not a contractual document, and it does not create any rights or obligations on either party, beyond those which already exist under data protection laws.

This Notice does not apply to your use of a third party site linked to this website.

Who is responsible for your information?

Throughout this Notice, “Shaping Little Minds” refers to Shaping Little Minds Ltd.,  Shaping Little Minds is responsible for your personal information (and the controller for the purposes of data protection laws) that we collect from or about you.

When and how do we collect your information?

We collect personal information in the following ways:

• When we perform services for our clients.
• When you request a service from us.
• When you register with or use any of our websites or applications.
• When you attend a Shaping Little Minds site or event.
• When you apply for a position at Shaping Little Minds.
• If you contact us with a complaint or query.
• When you engage with us over social media.
• Request information on our products or services or for other marketing to be sent to you;
• Enter into a competition or promotion; and
• Complete a survey from us or give us feedback
• Automated technologies, such as CCTV or other recording systems, 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 for further details.

What information do we collect?

Information you provide to us

When you request services, we ask that you provide accurate and necessary information that enables us to respond to your request. When you provide personal information to us, we use it for the purposes for which it was provided to us as stated at the point of collection or as obvious from the context of collection, for example providing an insurance quote, applying for a position with us or creating a profile on our website or application. 

When we provide the services listed above for our clients, we may collect personal information such as:

• Individual Data: this includes personal data which relates to your identity (and that of your child if applicable), such as first name, middle name, last name, username or similar identifier, title, date of birth and gender and your contact details such as your billing address, delivery address, email address and telephone numbers that you provide to us in person, via our website or by telephone, including the details you supply when establishing a profile on our website (including health-related personal data);
• ·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, purchases or orders made by you, your interests, preferences, feedback and survey responses;
• Audio and Visual Data: this includes personal data which is gathered using our CCTV or other recording systems in the form of images, video footage and sound recordings that is taken at any of the venues where the Shaping Little Mind activity is carried out or for promotional purposes;
• Advertising Data: this includes personal data which relates to your advertising preferences, such as information about your preferences in receiving marketing materials from us and our third parties and your communication preferences;
• Health Data: this includes personal data which is gathered for health and safety purposes including any accident report or claim log or any information you provide about allergies or other medical conditions during the booking process or in one of our locations;
• Sales Data: this includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you, details of subscriptions to our Shaping Little Minds Club or publications;
• 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; personal data gathered using cookies; and
• Personal data you provide when applying to either become a franchise owner, or for a job advertised or to submit a speculative job application and/or your CV.
• We may also create personal data about you if you contact us by telephone to make a complaint, for example 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 complaint.
• 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. 
• In addition, we may obtain certain special categories of your data (“Special Categories of Data”), and this Privacy Notice specifically sets out how we may process these types of personal data.
• The Special Categories of Data are: (i) personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; and (ii) the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

More information about the personal information collected for each of our services, together with the purpose and legal basis for collecting the information is provided below.

We will not collect any sensitive personal information unless this is required. Sensitive personal information includes a number of types of data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life.

If you provide us with sensitive personal information, you understand and give your explicit consent that we may collect, use and disclose this information to appropriate third parties for the purposes described in this Notice. If you provide personal information about other individuals such as employees or dependents, you must obtain their consent prior to your disclosure to us.

Information we collect over Shaping little Minds websites, and social media

We may ask you for some or all of the following types of information when you register for events, request services, manage accounts, access various content and features or directly visit our websites. This includes, but is not limited to:

• Contact information, such as name, e-mail address, postal address, phone number and mobile number;
• User name, password, password reminder questions and password answers;
• Communication preferences;
• Search queries;
• Contact information about others when you refer a friend to a particular site or service (note: this information is used solely to facilitate requested communications); and
• Information posted in community discussions and other interactive online features.

In some instances, we automatically collect certain types of information when you visit our websites and through e-mails that we may exchange. Automated technologies may include the use of web server logs to collect IP addresses, “cookies” and web beacons. Further information about our use of cookies can be found in our Cookie Notice. [All remaining detail should go in the Cookie Notice]

Social Media

You can engage with us through social media websites or through features such as plug-ins or applications on our websites that integrate with social media sites. You may also choose to link your account with us to third party social media sites. When you link your account or engage with us on or through third party social media sites, plug-ins, or applications, you may allow us to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the ‘likes’ you make).

If you post information when you interact with our websites through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. You can control what information you share through privacy settings available on some social media sites. For more information about how you can customize your privacy settings and how third party social media sites handle your personal information, please refer to their privacy help guides, privacy notices and terms of use.

Mobile Devices

If you access our websites on your mobile telephone or mobile device, we may also collect
your unique device identifier and mobile device IP address, as well as information about
your device’s operating system, mobile carrier and your location information. We may also ask you to consent to providing your mobile phone number (for example, so that we can send you push notifications).

How do we use your personal information?

The following is a summary of the purposes for which we use personal information. More information about the personal information collected for each of our services, together with the purpose and legal basis for collecting the information will be provided to you below.

Performing services for our clients

Administering our client engagements

We process personal information about our clients in order to:

• carry out “Know Your Client” checks and screening prior to starting a new engagement;
• carry out client communication, service, billing and administration;
• deal with client complaints;
• administer claims;

Contacting and marketing our clients and prospective clients

We process personal information about our clients and the individual representatives of our corporate clients in order to:

• contact our clients in relation to current, future and proposed engagements;
• send our clients newsletters, know-how, promotional material and other marketing communications;
• invite our clients to events (and arrange and administer those events).

Conducting data analytics

We are an innovative business, which relies on developing sophisticated products and services by drawing on our experience from prior engagements. We are not concerned with an analysis of identifiable individuals, and we take steps to ensure that your rights and the legitimacy of ouractivities are ensured through the use of aggregated or otherwise de-identified data.

If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected for, we will request your consent. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations to make sure that your personal information is not subject to unnecessary risk.

Legal basis

All processing (i.e. use) of your personal information is justified by a “lawful basis” for processing. In the majority of cases, processing will be justified on the basis that:

• the processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to collect certain information about our clients for tax or accounting purposes, or where we are required to make disclosures to courts or regulators); or
• the processing is in our legitimate commercial interests, subject to your interests and fundamental rights (e.g. where we use personal information provided to us by our clients to deliver our services, and that processing is not necessary in relation to a contract to which you are a party).

In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required to obtain your prior consent in order to send you marketing communications.

Before collecting and/or using any personal information, or criminal record data, we will establish a lawful basis which will allow us to use that information. This basis will typically be:

• your explicit consent;
• the establishment, exercise or defense by us or third parties of legal claims; or

How long do we retain your personal information?

How long we retain your personal information depends on the purpose for which it was obtained and its nature. We will keep your personal information for no more than the time required to fulfil the purposes described in this privacy notice unless a longer retention period is permitted by law. We have implemented appropriate measures to ensure your personal information is securely destroyed in a timely and consistent manner when no longer required.

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Do we disclose your personal information?

Except where we have stated otherwise in this Privacy Notice, we do not share your personal data with any third party that is not connected to us. The Shaping Little Minds business operates through a franchise network, so we share the personal data we collect from you with each of our franchisees (who may also share it with their authorised teachers and administrative personnel) so that the franchisees can use your personal data for the purposes to which you have consented via the Parent Zone as well as the purposes set out in the table above.

In addition, we may disclose the personal data you provide to us to:

·our payment service providers such as PayPal (where you purchase any of our products via our online shop) or Opayo where you make an online booking;

·HMRC, legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;

·external professional advisers such as accountants, bankers, insurers, auditors and lawyers;

·law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;

·third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

·third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation);

·third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website which you choose to interact with.

Legal Requirements and Business Transfers

We may disclose personal information (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search
warrant, or other legal request. (ii) in response to law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity or (v) in the event that we are subject to a merger or acquisition to the new owner of the business. Disclosure may also be required for company audits or to investigate a complaint or security threat.

Do we have security measures in place to protect your information?

The security of your personal information is important to us and we have implemented reasonable physical, technical and administrative security standards to protect personal information from loss, misuse, alteration or destruction. We protect your personal information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and limited access. Only authorized individuals access your personal information, and they receive training about the importance of protecting personal information.

What choices do you have about your personal information?

We offer certain choices about how we communicate with our customers and what personal information we obtain about them and share with others. When you provide us with personal details, if we intend to use those details for marketing purposes. At any time, you may opt out from receiving interest-based advertising from us by visiting our opt-out page.

How can you update your communication preferences?

We takes reasonable steps to provide you with communication about your information. You can update your communication preferences in the following ways.

Profile

If you have created a profile or account on one of our websites, you can update your contact information after you log into your account.

Mobile Devices

If you previously chose to receive push notifications on your mobile device from us but no longer wish to receive them, you can manage your preferences either through your device or the application settings. If you no longer wish to have any information collected by the mobile application, you may uninstall the application by using the uninstall process available on your mobile device.

Email

Contact us by e-mail or postal address as noted below. Please include your current contact information, the information you are interested in accessing and your requested changes.

If we do not provide you with access, we will provide you with the reason for refusal and inform you of any exceptions relied upon.

Other rights regarding your data

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right to Access

You have right to access personal information which we hold about you. If you have created a profile, you can access that information by visiting your account.

Right to Rectification

You have a right to request us to correct your personal information where it is inaccurate or out of date.

Right to be Forgotten (Right to Erasure)

You have the right under certain circumstances to have your personal information erased. Your information can only be erased if your data is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the data.

Right to Restrict Processing

You have the right to restrict the processing of your personal information, but only where:

• its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want it erased; or
• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

Right to Data Portability

You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.

Right to Object to Processing

You have the right to object the processing of your personal information at any time, but only where that processing is has our legitimate interests as its legal basis. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Automated Decision Making

You have the right to not be subject to decisions based solely on automated decision making, which produce legal or significant effects for you, except where these are (i) necessary for a contract to which you are a party; (ii) authorized by law; (iii) based on your explicit consent.

Even where such decisions are permitted, you can contest the decision and require us to exercise human intervention.

International Transfers

As noted above, you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

Contact Us

If you have any questions, would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, or would like to make a complaint about a breach of the law or this Privacy Notice, please contact the Privacy Officer: info@shapinglittleminds.uk.Alternatively, you have the right to contact your local Data Protection Authority.

If you have any questions relating to this Notice, please contact us at 116 Park Avenue North or info@shapinglittleminds.uk

Changes to this Notice

We may update this Notice from time to time. When we do, we will post the current version on this site, and we will revise the version date located at the bottom of this page.

We encourage you to periodically review this Notice so that you will be aware of our
privacy practices.

This Notice was last updated in December 14, 2022.