COACH CLARE EDUCATION LIMITED TRADING AS KUUL PLAY is a Company incorporated under Irish law with Company Number 72435 and having its registered office at Blarney Street, Cork (the “Company”). We are fully compliant with the General Data Protection Regulation (“GDPR”) and all applicable legislation made in the Republic of Ireland thereunder. The purpose of this policy is to explain how our organisation uses the personal data we collect from you when you use our website and services. This privacy policy sets out how the Company uses and processes any information which you give to us. We respect your privacy and are committed to protecting your personal information.
Our Data Protection Representative is Clare McSweeney who can be contacted at clare@kuulplay.com.
What Data do we collect?
Our Company collects data comprising personally identifiable information from our subscribers and users, including education providers, parents and students, including the following;
- Name
- Email address
- Photographs and videos uploaded by our users
We may also obtain certain sensitive personal data from our Data Subjects with their consent where necessary for the use of our platform including in particular certain health related data. Where sensitive data is obtained, it will not be retained for any longer than necessary for the performance of the contract with the Company. We will not disclose sensitive personal data without your consent. We will ensure that processing of sensitive personal data is carried out in compliance with the GDPR at all times.
How do we collect your Data?
The Company collects data from our Data Subjects and processes it in the provision of our platform. We will collect data from our Data Subjects through our website and from the application forms, contact forms, registration forms and any questionnaires which you may be asked to complete together with personal data from records of any correspondence, telephone calls, emails, details of your visit to our website, publicly available information including social media and through use of browser cookies. The Company will operate as a Data Controller in respect of the personal data supplied by its service users. Our Company will collect data primarily by way of direct production of same by our users. In particular, we will collect personal data comprising photographs and videos uploaded by our users. On occasion we may also receive your Data indirectly via publicly available information including on social networking sites.
Where the Company collects personal data relating to minors, such data will only be collected and maintained with the consent of the parent or guardian of such data subject, and where necessary to perform the services. In order to provide the services via our platform, the Company must process personal data. Where photographs and videos are provided by users in relation to minors, such data will only be shared to the teacher of the relevant class assigned to such user, and the Company. No other third party will be permitted to access such data via our platform.
How will we use your Data?
Our Company collects your data so that we can provide our services via our physical education platform. Our Company collects your Data so that we can;
- Process your registration for our platform
- To enable you and us to manage your account in relation to the access to our platform ➢ To engage with you and respond to any requests which you may have.
- To enable the users of our Site to send photographs and videos of their progress to their educational providers while using our service
- To improve our level of service
- For general marketing purposes which are in the legitimate interest of our business ➢ To meet our legal and statutory obligations (including, defence of legal claims, if applicable)
Basis of processing Data
The Company will process data on behalf of natural persons comprising our subscribers and users and will ensure that your data is processed in a lawful, clear and transparent manner at all times for a specific and legitimate purpose. The Company relies on the following legal basis for the processing of data.
a. Processing necessary for the performance of a Contract
b. Processing necessary for the compliance with a legal or statutory obligation c. To protect the vital interest of a Data Subject
d. With the consent of the Data Subject for one or more specific and legitimate purposes. e. Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller
f. Processing necessary for the purposes of the legitimate interest pursued by the Controller or a third party except where such interest is overridden by the fundamental rights and freedoms of the Data Subject.
Where we rely on the legitimate interest of the Company for the processing of the personal data, we will take all reasonable measure to ensure that the interests of the Data Subject are protected. The legitimate interests of the Company in this context include direct marketing, prevention of fraud and information system security.
We will rely on our legitimate interests as a company to process your data for direct marketing purposes. We consider it to be a legitimate interest of our company in promoting its services, products and in the administration operation of our business. Any such processing will not be carried out where such interest is overridden by the rights and freedoms of the Data Subject. In all direct marketing communications, we will give an unsubscribe option. A Data Subject can unsubscribe at any time.
We will only rely on consent as the basis for processing in limited circumstances. Where consent is utilised as the basis for processing, such consent can be withdrawn at any time. In that event, we will cease processing your data, unless there is a separate basis upon which we can rely to process your data, such as same being necessary for the performance of the contract between us or necessary for us to comply with our legal and statutory obligations.
How do we store your Data?
The Company will ensure all appropriate technical and organisational measures are put in place commensurate with the level of security required for the data held on your behalf. We will use all
appropriate and reasonable measure to ensure integrity and confidentiality of the personal as maintained at all times.
Marketing
Our Company would like to send marketing information to you about the products and services which we think will be of relevance to you. We will always give you an option to unsubscribe from our marketing list, support@kuulplay.com if you wish to unsubscribe from our marketing list. You have a right to object to our processing your data for direct marketing purposes at any stage.
Sharing of Personal Data
It may be necessary for us to share your personal data with third parties to enable us to comply with our legal and statutory obligations, to provide our services and to perform the contract between us. In particular, it may be necessary for us to share your personal data with schools, education providers, parents and pupils to facilitate access to our platform and use of our platform. We will never provide your data to third parties for marketing purposes.
For the avoidance of doubt, the Company does not process financial information. All financial information is processed via Stripe. You are advised to consult the Stripe privacy policy in connection with same. We may also share your data with our professional advisors where necessary including lawyers, bankers, auditors and insurers who provide professional services necessary for the operation of the business of the Company.
We do not propose to transfer personal data to any parties not resident within Europe.
Data Retention
The Company will keep your data for no longer than necessary for the purpose for which the data was provided taking into account the basis for processing the data. Customer Contact Information shall be retained for a period of one year after termination or deletion of your account. We are obliged to retain our data compliance records for a period of five years in accordance with data law and GDPR.
With regard to photographs and videos, we will retain any photographs and videos uploaded by our users for the duration of the school term or calendar year, depending on the subscription selected by the educational institution. At the expiration of the school term or the one year subscription as appropriate, the data will be deleted.
Rights of Data Subject
You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:
- Right to access data – you have the right to request a copy of the personal data that we hold about you together with other information about our processing of that personal data.
- Right to rectification – you have the right to request that any inaccurate data that is held about you is corrected or if we have incomplete information you may request that we request that we update the information such that it is complete.
- Right to erasure – you have the right to request us to delete personal data that we hold about you. This is sometimes referred to as a right to be forgotten.
- Right to restrict processing or object to processing – you have the right to request that we no longer process your personal data for particular purposes or object to our processing of your personal data for a particular purpose
- Right to data portability – you have the right to request us to provide you or a third party with a copy of your personal data in a structured commonly used readable format.
- Right to object to processing – you have the right to object to processing of data under certain conditions.
If you wish to exercise any of the rights set out above, please contact Clare McSweeney at clare@kuulplay.com.
We ask that you ensure that all data which you furnish to us is kept accurate and up-to-date at any stage. If we were processing personal data on the basis of your consent, you may withdraw consent at any time. This does not affect the lawfulness of processing which should take place prior to its withdrawal.
You can object to the processing of your personal data for direct marketing purposes at any stage. If you are unhappy with how we process your personal data we ask that you contact us so that we can rectify the situation. You may lodge a complaint with the Supervisory Authority of the Irish Supervisory Authority of the Data Protection Commission.
Cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our website we may collect information from you automatically through Cookies or similar technology. For further information visit Allaboutcookies.org. Our Company uses Cookies in a range of ways to improve your experience on the website including:
- Keeping you signed in
- Understanding how you use our website
- Improve your user experience
There are a number of different types of Cookies, however our website uses the following:
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cookielawinfo-checkbox-others
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You can set your browser not to accept Cookies. In certain cases however, if you decline to accept Cookies certain of our website features may not function as a result.
Automated decision-making and profiling
We do not use personal data for the purposes of automated decision-making or profiling.
Changes to this Privacy Notice
Our privacy notice may change from time to time. Please check back frequently to see if there are updates or changes to our privacy policy which have been implemented. If you do not agree to these changes or any of the terms of this policy, please do not continue to use this website to submit personal information.
Date: 16th March 2021
