Effective date: 30th day of May, 2022

The Website is offered from the United Kingdom by Clavis Aditum Ltd (referred to in this Notice as “our”, “us”, “Clavis Aditum” and “we”), a company registered in England and Wales.

Purpose

The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:

1. The personal data we will collect;

2. Use of collected data;

3. Who has access to the data collected;

4. The rights of Site users; and

5. The Site’s cookie policy.

This Privacy Policy applies in addition to the terms and conditions of our Site. For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Clavis Aditum Ltd, where data is inputted directly by parents; and the Data Processor is Clavis Aditum Ltd, where data is submitted by a parent.

GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

Consent

By using our Site users agree that they consent to:

1. The conditions set out in this Privacy Policy.

Legal Basis for Processing

We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal bases to collect and process the personal data of users in the EU:

Your Personal Information

Information We collect from You

We collect and process some or all of the following types of information from you:

1. Information that you provide when you submit an enquiry. This includes information provided through our enquiry form, via email, via phone and/or by any other method. In

particular, We process personal details such as name, email address, telephone number, postal address, role, organization you work for, and business requirements or any other

details in the enquiry that you provide to Us.

2. If you contact Us, We may keep a record of that correspondence.

3. Details of all actions that you carry out through the use of the Services.

4. Details of your visits to Clavis Aditum’s Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Clavis

Aditum’s Website and the resources that you access.

How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

Who We Share Personal Data With

Employees: We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

1. If the law requires it;

2. If it is required for any legal proceeding;

3. To prove or protect our legal rights; and

4. To buyers or potential buyers of this company in the event that we seek to sell the company.

5. If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

Information We Collect From Other Sources

We do not collect additional information on our clients from any other sources.

Purposes of Processing

We use information held about you in the following ways:

1. On the basis that there is a contract between Us and you. We process your data in order to fulfill this contract.

2. To communicate with you in response to enquiries.

3. To enhance any information that we receive from you with information obtained from third party data providers.

4. To help improve the usefulness and effectiveness of our website and marketing channels.

How We Store Your Personal Data

Security:

We take appropriate measures to ensure that all personal data is kept secure including security measures 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 information will do so only in an authorized 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.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore, we are unable to guarantee the security of user data beyond what is reasonably practical. Transmission remains at your own risk.

Where We Store Your Personal Data

Where We store your personal data in our own systems and on the cloud, within the European Economic Area (“EEA”). If you would like further information please contact Us via info@clavisaditum.com. We will not otherwise transfer your personal data outside of the EEA or to any organization (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

How Long We Store Your Personal Data

User data will be stored until the purpose the data was collected for has been achieved.

Children

We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our data protection officer.

Your Rights

Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:

1. Access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address. 

2. Require Us to correct any mistakes in your information which We hold.

3. Require the erasure of personal data concerning you in certain situations.

4. Receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format.

5. Object at any time to processing of personal data concerning you for direct marketing.

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

7. Object in certain other situations to our continued processing of your personal data otherwise restrict our processing of your personal data in certain circumstances.

8. Claim compensation for damages caused by our breach of any data protection laws.

Do Not Track Notice

Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We do not track the users of our Site over time and across third party websites and therefore do not respond to browser-initiated DNT signals.

Cookie Policy

A cookie is a small file, stored on a user’s hard drive by a website. Its purpose is to collect data relating to the user’s browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

We use the following types of cookies on our Site:

1. Third-Party Cookies

Third-party cookies are created by a website other than ours.

Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our data protection officer here:

Yacoba Debrah

11 Russell Hill, Purley, Surrey, CR8 2JB

info@clavisaditum.com

We hope that we will be able to address any of your requests. However, you have the right to make a complaint about the processing of your personal data to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.