Here at Pamoja (we, us), we are committed to protecting your personal data and to respecting your privacy. We hope we have explained all you need to know in this policy, but if you need to know more or about the data that we hold or the way that we use it, or something is unclear to you, you can email us at firstname.lastname@example.org or call us on +44 (0) 1865 636100
What we have included in this policy
1. About this policy
This section explains who this policy is intended to be read by and who the data controller of your personal data is.
2. The way that we use your personal data
- What personal data do we collect? This section gives a summary of all of the personal data that we collect and process about you.
- How do we collect personal data? The majority of information we collect and process about you comes directly from you but sometimes we get it from other sources. This section sets out where we collect your personal data from.
- How do we use personal data? We use personal data in various ways to help us achieve different purposes, such as providing the services you request from us. This section sets out each of the ways we use personal data, why we use it and our legal basis for doing so.
- How do we share your personal data? Sometimes we need to share your personal data to achieve certain things (such as our suppliers to provide us with services). This section explains who we share personal data with and why we need to share it.
3. Security and retention of your personal data
The security of your personal data is very important to us. This section explains what we do to keep it safe.
4. Your rights and how to contact us
The law gives you rights over your personal data. This section explains which rights you have and how you can exercise them.
This section explains what will happen if we make any changes to this policy.
1. About this policy
The “data controller” of your personal data (in other words, the organisation that decides how to use your data) is Pamoja Education Limited (our company number is 06829167) and you can find us at Building 9400 Alec Issigonis Way, Oxford Business Park North, Oxford, England, OX4 2HN.
2. The way that we use your personal data
A. What personal data do we collect?
When we say “personal data” we mean any information that could be used to identify you in some way – so this covers quite a lot! The personal data that we collect from or about you may include the following:
• e-mail address;
• phone number;
• if you are a student, we may also collect information about your education status, the name and contact details of your parents/guardians, your progress on any Pamoja courses and your educational history as well as your age, gender, the languages you speak and your nationality,
• if you are a contact at a school that is a Pamoja customer, that has made an inquiry about Pamoja courses or that we have contacted to discuss Pamoja courses we may also collect your job title, the school you work for and any other information that you provide to us;
• if you are a parent or guardian that has contact us we may also collect the information that you provide to us about the child you are making a request about;
• your login details to the Pamoja portal (if you have one);
• location information from the device that you use to visit the site or the Pamoja portal;
• financial, credit and debit card information (if you purchase a course directly from us);
• any relevant information you give us if you contact our customer support team. This may include any personal data on your screen if we have to remotely access your device;
• if you are applying for a position with us, the information that you provide to us as part of your application;
• information about the products and services you have bought from us (including the courses you are studying (if you are a student) or made enquiries about/teach (if you are a school contact);
• information about your visit to our website and your use of the Pamoja portal, including information about how and when you came to visit, how you interacted with the website or the portal (page response times, download errors, length of visits to certain pages, page interaction information such as scrolling, clicks, text entry and mouse-overs), and the website you visit when you leave our website (including full URLs and methods used to browse away from the site);
• technical information about the way that you use web or mobile services, including the internet protocol (IP) address used to connect your computer to the internet, your login information if you register on our website, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information;
• information collected from our websites and elsewhere across the internet through cookies, web beacons, pixel tags, device identifiers and other technologies including information about your preferences; and
• information about your ethnicity (demographic information) and other information provided by you.
Sensitive personal data
If you are one of our students there may be some instances where we need to collect more sensitive data about you such as if you have any special educational needs or health conditions which could affect your studying. We may need this personal data in order to ensure the course is set up in the best way for you. Similarly, if you need to submit any extenuating circumstances information (for example sensitive information that may impact on your performance in an assessment) we may need to process some of this sensitive data so that it can be taken into account when assessing your performance in an exam or for a piece of work. If you are taking a course that requires us to keep a video record of an assessment, we may also obtain your biometric data (i.e. a video recording of you) in order to administer your course.
If you are applying for a role with us, we may process sensitive data about you that you provide to us that may be relevant for you role. This may, for example, include any specific work-related adjustments that you require to fulfil your role.
Where we process sensitive personal data about you we will make sure we will only do this with your explicit consent or as otherwise permitted under relevant data protection laws. Depending on a number of factors (including your age) we may need to get your parent or guardian to give consent on your behalf.
B. How do we collect personal data?
We may collect personal data in a variety of ways including:
• Directly from you:
Information such as name, address, telephone number, email address, as well as other information, such as your website registration details and preferred means of communication, may be collected when you voluntarily provide this information to us (for example when you enrol on a Pamoja course or set up and use your Pamoja portal account, take part in a survey or a recorded feedback session, participate in any user generated content facilities, get in touch with us as part of our recruitment process or send emails to us enquiring about our courses);
• From other sources:
o If you are a student at a school which offers Pamoja courses we may receive some information from your school in order to get you registered and set up on and administer the course;
o We also work closely with third parties providing services to us (including, for example, business partners, sub-contractors who provide us with services we cannot fulfil alone, these include advertising networks, social networking platforms, analytics providers, and search information providers) and we may also receive information about you from them;
o We work with the International Baccalaureate Organisation (“IB”) in order to offer students and teachers IB certified courses, as part of this relationship we will receive some personal data from the IB such as student exam IDs, results and some statistical analysis;
o If you are applying for a role with Pamoja, we may obtain data about you from references that you list on your application;
o In some circumstances we may obtain data from public databases such as the IB’s central register of contacts at International Baccalaureate affiliated schools or school websites and
o We may combine information that we collect about you from other sources with the information that you give to us directly. We may use this combined information as described in this policy;
• Through your browser or device, through our servers, or through your use of the Pamoja portal:
Certain information is collected by most browsers or automatically through your device, and we also collect your IP address or other device identifier (this enables us to recognise your computer or device when you use the site or our portal) via our server log files. Our portal currently records when you log in. We also use third party tools on our portal which provide us with information about how you (students, teachers, and course managers) use the portal including what you have clicked on and how you have interacted with and moved around the portal.
C. How do we use personal data, and what is our justification for doing so?
We use your personal data for lots of purposes which are all linked to the products and services that we provide. From a legal perspective, there are various reasons for doing so and we have set these reasons out below.
For purposes related to the provision of the products and services that we offer to you:
• to provide you with and administer our Pamoja courses (i.e. to complete certain tasks, processes on our website or within our portal, and take payment online (where applicable)), and to communicate with you regarding any Pamoja courses that you are studying or teaching and respond to your questions and comments;
• to measure student and teacher satisfaction and provide customer service and support (including troubleshooting the use of the Pamoja portal);
• for statistical purposes to facilitate enrolment into courses and ensure gender balance within a course;
• to provide teachers with a sample of student work as examples of where particular pieces of work sit alongside grade boundaries (where you have given us your consent to do so);
We use your data in this way either because we have a contract with you (for example, if you have enrolled on a Pamoja taught course we have obligations to ensure you are able to access and complete the course to your satisfaction) or because it is in our legitimate interests to do so (for example, it is in our interests to measure student and teacher satisfaction and ‘troubleshoot’ issues) but we will always ensure that your rights are protected.
We will rely on consent to use a student’s work as sample work.
For advertising and marketing purposes, including to measure how effective our marketing is:
• to send you emails or newsletters to let you know about Pamoja’s products, we may also combine this with information we collect from other sources to ensure we are only telling you about Pamoja products which would interest you;
• to measure the effectiveness of our marketing campaigns and our advertising (i.e. so that we can tell what interests our customers and what doesn’t);
We will either rely on your consent to contact you directly about Pamoja’s products and courses or in other scenarios (for example, where we are contacting you in a business to business context), we will rely on our legitimate interests as a business, always ensuring that your rights are protected.
For administrative and internal business purposes:
• to ensure that content on our site and on our portal is presented in the best and clearest manner for you and for your device and to tailor the site and portal’s experience and content based on the way that you use our services and courses;
• to administer our site and portal and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• for our internal business purposes, such as analysing and managing our businesses, audits, developing new products or courses, enhancing our site and portal, improving our services and products and identifying usage trends. ;
It is in our legitimate interests as a business to use your personal data in this way. For example, we have a clear interest in ensuring that our portal works properly so that students can access and use course materials efficiently and our teachers are able to fully support student learning. We want to ensure that our products and services are high quality and efficient. We will always ensure that your rights are protected.
For our internal recruitment:
• to consider your application for a role within our organisation;
• to carry out an internal recruitment process;
• if you are happy for us to do so, to contact you for other roles that we think you may be suitable for.
It is in our legitimate interests as a business to use your personal data in this way. For example, to make sure that we recruit the right people to join our team.
For security and legal and compliance purposes:
• as part of our efforts to keep our website and portal safe and secure;
• to detect or prevent fraud or other illegal activity;
• as we believe to be necessary or appropriate in each case in order to comply with laws or legal process (including laws or legal process in other countries);
• to protect our rights or property (or the rights or property of others) and to enforce our rights and pursue available remedies;
In some cases, we will need to use your personal data to fulfil a legal obligation (for example, if we receive a legitimate request from law enforcement agencies), and in other cases (such as the detection of fraud or ensuring the security of the site) we will rely on our legitimate interests as a business to use your data in this way.
International transfer of your data:
• some of the processes involved in our use of your personal data may require your data to be stored or processed in countries outside of your home country. For example, whilst we will always try to ensure that teachers and students on Pamoja Taught courses live in the same country this is not always possible. Where this occurs we will need to transfer personal data about both student and teacher outside of their home country so that they can communicate and participate in the course. Pamoja is also part of a group of companies which has a base in Dubai so we may need to transfer your personal data to Dubai from time to time.
Whenever we send (or permit a third party to send) your personal data outside of your home country (and in particular where this means sending personal data in or out of Europe) we will make sure that we take steps necessary to protect your data as required by applicable laws. For example, we may implement specific contract terms or we may rely on service providers who adhere to certain compliance programmes overseas, or we may select service providers based in countries with strong local laws to protect your personal data.
Monitoring and Profiling for Pamoja portal analysis
We use third party tools to monitor and improve our Pamoja portal. These tools provide us with information about how you use the Pamoja portal. We use this information to ensure that our customer support team are able to assist you in the most efficient way possible as they are able to identify any issues that are specific to your interaction with the Pamoja portal. We also use it to help improve the functionality of the Pamoja portal and to improve our course content and course design. We ensure that your rights to your personal data are adequately protected at all times.
D. How do we share your personal data?
We will never sell your personal data or give it to anyone else for them to use for their own purposes without making that clear to you. We do sometimes still need to share your personal data though. We’ve set out when we do this below:
(i) Sharing data within our group:
We are part of a group of companies that share some operations and business processes. We may share your personal data with any member of our group in order to fulfil our contractual obligations to you, or because it is in our legitimate interests to do so (for example, we share financial reports and other progress reports with our parent company in Dubai which may in rare instances include some personal data).
(ii) Sharing with the International Baccalaureate (“IB”):
The courses we offer are authorised by the IB and students will participate in the IB’s examination sessions. Our relationship with the IB means that sometimes we will need to provide the IB with student personal data so that the student can participate in the course and take exams, similarly, we will receive some personal data about our students from the IB such as student exam IDs, results and some statistical analysis. We do this because it is necessary in order to fulfil our agreements with both our students and schools but also our agreement with the IB itself.
(iii) Sharing between teachers and students:
If you are a student on any Pamoja Taught course your teacher will have access to certain information about you such as your name, your coursework, your exam results, your special educational needs (where applicable) information provided to a teacher during an online class or assessment or in email contact with your teacher, and any work you have submitted on the Pamoja portal. In most cases we need to do this to ensure that your teacher is given the right tools to support your learning and progression through the course.
If you are being taught in your school, your name, your coursework and any other assessments, your exam results and your special educational needs (where applicable) may be shared with one of our course advisers for review to ensure that you are being taught and graded in accordance with our, and IB’s, standards and to deal with any queries from your teachers.
(iv) Sharing with organisations providing services to us:
We engage various third parties to provide services to us for specific functions, and this will often mean that we need to share your personal data with them (it is in our legitimate interests to do so, since we may not have the capabilities to provide these services ourselves). In each case, we will ensure that these third parties are only allowed to use your personal data in order to provide the relevant services to us. We will always make sure that we use organisations that we trust to look after your personal data appropriately and as required by applicable laws.
Some examples of these third parties will include: credit card processing services if you make a payment directly to us, analytics, website management, information technology and related infrastructure provision, recruitment platforms, auditing, and other similar services.
(v) Sharing data with online advertising related service providers:
We may from time to time work with online advertisers, social media platforms and advertising networks to deliver, tailor and measure advertising to you and others both on the site and elsewhere on the internet (including on social media platforms such as Facebook and LinkedIn).The personal data that we allow to be shared with these third parties includes online identifiers such as data from cookies or similar technologies, or other device related information.
Similarly, we may share certain online identifiers with analytics and search engine providers that assist us in the improvement and optimisation of our site.
(vi) Sharing data in connection with changes to our group structure or the ownership of our business:
If we sell or propose to sell our business or part of it, we may need to disclose your personal data to prospective buyers.
Similarly, if there are changes to our group structure or if our ownership changes, we may need to disclose your personal data to the new owners or operators of this site or any of our apps as part of that process.
(vii) Sharing data to comply with laws:
Sometimes the law will require us to disclose or share your personal data, for example, if we are asked to do so by a law enforcement agency or public authority in order to prevent or detect crime.
3. Security and retention of your personal data
(i) Security of your personal data:
We take the security of your data very seriously and have put physical, technical and administrative strategies, controls and measures in place to help protect your personal data from unauthorised access, use of disclosure as required by law and in accordance with accepted good industry practice.
To help us keep your data safe please choose a strong, secure password for your Pamoja portal account and keep your password confidential and avoid sharing it with anyone.
(ii) Retention of your personal data:
4. Your rights and how to contact us
The law gives you a number of rights in relation to your personal data and our use of it. You have the right:
• to ask us not to use your personal data for direct marketing purposes;
• to ask to see what personal data we hold about you and to find out about the way that we process the data (and in some circumstances, you can ask us to provide a copy to a third party);
• to ask us to correct or update any personal data which is inaccurate;
• to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for us to continue to process it;
• to ask us to temporarily stop using your data if you don’t believe that we have a right to use it, or to stop us from using your personal data where there is no good reason for us to continue to use it; and
You also have the right to complain about our use of your personal data. As a UK based business we are regulated by Information Commissioner’s Office who you can contact via their website: https://ico.org.uk/concerns/ or by calling 0303 123 1113.
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