Privacy PolicyPrivacy Policy

Who We Are

ThriveTech Learning Ltd provides tutoring, the Homeschool Hub, educational technology services, school-based workshops and after-school clubs, and Alternative Provision services.

This Privacy Policy explains how we collect, use, store, protect and share personal information in accordance with applicable data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

For questions or requests about personal information, please contact ThriveTech Learning Ltd using the contact details provided on our website.

ThriveTech Audio

ThriveTech Audio is a trading name of ThriveTech Learning Ltd, not a separate legal entity. This Privacy Policy therefore also applies to personal information handled when we provide audio, recording, AV installation and hearing-loop services.

For ThriveTech Audio, we may collect and use contact and enquiry details, quotation and booking information, site addresses and access arrangements, installation or service records, invoice and payment information, and communications with clients. The information collected will depend on the service provided.

ThriveTech Audio uses HubSpot and Google services for relevant customer information and business administration, in line with the storage and protection arrangements described in section 7 of this policy.

Where a client records music or other audio in our studio, the resulting music and project files may be created and worked on using Logic Pro. We retain studio music and project files for a minimum of two months after the relevant session or project, after which they may be deleted. We may retain files for longer where agreed with the client or where reasonably necessary for an appropriate business, legal or safeguarding purpose. Clients should not assume that project files will be available indefinitely and should keep their own copies of any files they need.

We handle recordings and project files securely and limit access to people who need them for the relevant service. Any use of identifiable recordings for marketing or other purposes beyond providing the agreed service will be handled in accordance with the permissions obtained and applicable law.

Personal Information We May Collect

Depending on the service being provided and the relationship with the individual, we may collect:

• Names of students, parents, guardians, school staff and other professional contacts.
• Contact details, including email addresses and telephone numbers.
• Emergency contact details and authorised collection arrangements.
• Attendance, booking and session records.
• Educational information relevant to the service.
• SEND, medical, allergy or other health information where needed to support learning, wellbeing or safety.
• Behavioural and safeguarding information where relevant.
• Records of communications, concerns, incidents and safeguarding reports.
• Payment, invoicing and transaction information.
• Information provided through registration forms, including the Homeschool Hub daily registration form.

How We Use Personal Information

We use personal information only where we have a lawful basis and for purposes connected with operating our services. These purposes may include:

• Providing and administering educational services, bookings and sessions.
• Communicating with parents, guardians, schools and commissioning organisations.
• Maintaining attendance and daily registration records, including collection arrangements.
• Understanding and supporting a child’s relevant educational, medical or additional needs.
• Responding to safeguarding concerns, incidents and emergencies.
• Managing invoices, payments and business records.
• Meeting legal, regulatory, insurance and safeguarding obligations.
• Maintaining the safety and security of our equipment, services and participants.

Lawful Bases for Processing

Depending on the purpose and the type of information, we may rely on one or more lawful bases under data protection law, including performance of a contract, compliance with a legal obligation, legitimate interests, protection of vital interests, or consent where appropriate.

Where we process special category information, such as health information, SEND-related information or certain safeguarding information, we will also identify and rely on an applicable additional condition under data protection law. Consent is not assumed to be the lawful basis for every type of processing.

Where we rely on consent, it can be withdrawn. Withdrawal does not affect processing that took place lawfully before consent was withdrawn, and we may still need to retain or use information where another lawful basis or legal obligation applies.

Special Category and Safeguarding Information

We may process health, SEND-related and safeguarding information where necessary to deliver services safely, support a child, respond to concerns or meet legal obligations. We limit access to such information to people who need it for an appropriate purpose.

Safeguarding information may need to be retained or shared with appropriate agencies to protect a child or another person, or to meet legal obligations. A request to delete or restrict information will be considered in accordance with applicable law and will not automatically override safeguarding or legal requirements.

How Information Is Stored and Protected

The customer-information systems currently used by ThriveTech Learning Ltd are HubSpot and Google services. Google Forms is used for relevant registration processes, including the daily Homeschool Hub registration form completed on the iPad provided by ThriveTech Learning Ltd.

We use these systems for relevant business and service-administration purposes, which may include contact details, communications, registration information, attendance-related information and other information needed to deliver services. The precise information held will depend on the service and the system used.

We take reasonable technical and organisational steps to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. These steps may include account access controls, passwords and limiting access to people who need the information for their role.

Only HubSpot and Google are identified in this policy as the systems ThriveTech Learning Ltd uses to store customer information. If our systems or practices change materially, this policy will be reviewed and updated.

Sharing Information

We do not sell personal information. We may share information where necessary and lawful with:

• Parents or legal guardians, where appropriate.
• Schools and Alternative Provision commissioning organisations involved in the child’s provision.
• Local authority children’s services and safeguarding teams.
• The police, healthcare professionals, emergency services or other relevant agencies where needed.
• Service providers that process information on our behalf, including HubSpot and Google, subject to appropriate arrangements.
• Insurers, professional advisers or regulatory bodies where necessary and lawful.

We share only information that is appropriate and necessary for the relevant purpose, taking account of safeguarding duties, confidentiality and data protection law.

International Transfers

HubSpot and Google may process personal information in countries outside the United Kingdom, depending on the services and account arrangements used. Where a restricted international transfer takes place, appropriate safeguards or another lawful transfer mechanism must be in place as required by UK data protection law.

Individuals may contact ThriveTech Learning Ltd for further information about the handling of their personal information.

Photographs, Video and Recordings

We will not use photographs, video recordings or other media containing identifiable children for promotional purposes without prior written consent from a parent or legal guardian and any other permissions required. Any recording made for an agreed educational or safeguarding purpose will be handled securely and in accordance with applicable policies and law.

Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including service delivery, safeguarding, legal compliance, accounting and the establishment or defence of legal claims.

Retention periods may differ depending on the type of record and the reason it is held. When information is no longer required, we will take reasonable steps to securely delete or destroy it, subject to any legal or safeguarding need to retain it.

Your Data Protection Rights

Depending on the circumstances and applicable law, individuals may have the right to:

• Request access to personal information held about them.
• Request correction of inaccurate or incomplete information.
• Request erasure of information in certain circumstances.
• Request restriction of processing in certain circumstances.
• Object to processing based on legitimate interests or for direct marketing, where applicable.
• Request transfer of information they have provided, where the right to data portability applies.
• Withdraw consent where processing relies on consent.

Requests should be made using the contact details on our website. We may need to verify the identity and authority of the person making a request, particularly where the request concerns a child. Rights are subject to legal conditions and exemptions, including those relevant to safeguarding.

Complaints

If you have concerns about how ThriveTech Learning Ltd handles personal information, please contact us first so that we can consider and respond to the concern.

You also have the right to complain to the UK Information Commissioner’s Office (ICO). The ICO’s website (opens in a new tab) provides information about how to raise a concern.

Changes to This Policy

This policy will be reviewed at least annually and sooner if needed to reflect changes in law, guidance, the services provided or our information-handling practices. The current version will be made available through our website.