Privacy Policy

Welcome to Aula's privacy policy.

Aula Education Limited (Aula) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when:

1. you visit our website www.aula.education (regardless of where you visit it from);
2. we send out marketing;
3. we handle the data of our customer contacts;
4. you enter your email address to be redirected to your university’s Aula platform.

‍It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

‍Are you a user of the Aula Platform?
‍If you are a student or tutor using the Aula platform provided to you through your university then we are a processor of your personal data processed on the Aula platform and your university is the controller. To find out how your personal data is used on the Aula platform please see your university’s privacy policy or contact your university directly.

Who we are
‍Aula Education Limited is the controller and responsible for the processing of your personal data as described in this privacy policy. We have appointed a data protection officer (DPO), Rune Kvist, who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our DPO using the details set out below.

‍Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
‍
Email address: privacy@aula.education
Postal address: Aula Education Limited, Unit 23 Canalot Studios, 222 Kensal Road, London, United Kingdom, W10 5BN

‍You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

‍Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Information we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Contact details being name, email address, telephone numbers, job title and your place of work or study.
• Your preferences in receiving marketing from us.
• Cookies and other tracking technologies. Details of how we use this information is found in our Cookie Policy.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or 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 policy.

How is your personal data collected?
‍We use different methods to collect data from and about you including through:

• You may give us your personal data, including contact details, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you send a query or book a demo.
• We will receive personal data about you from your university to enable us to contact you directly in relation to the contract we have with the university or are going to enter into with the university.
• As you interact with our website, we collect information by using cookies and other similar technologies. Please see our Cookie Policy for further details.

How we use your personal data
We have set out below the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

• If you are an employee or consultant for a university, we use your name, contact details, job role title and details of your place of work to contact you about the services we are providing or will provide to the university you work for. This is necessary for our legitimate interests (to carry out the contract with the university).
• If you log in into your University’s Aula platform through our website, we process your email address, and as a result process where you study, to direct you to your university’s platform. This is necessary for our legitimate interests to provide a good service to our clients and to enable you to access your university’s Aula platform. When you are using the Aula platform we are a processor and your university is the controller. Please see your university’s privacy policy for information on how they handle your personal data.
• We use your name and contact details to contact you if you book a demo or contact us through our chat function on the website.
• We use your contact details and information about your communication preferences to send marketing communications. This is necessary for our legitimate interests (to carry out business to business marketing and to promote our services).

Our promotional updates and communications
Our marketing is business to business marketing. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services we provide to the institution you work for.

Cookies and other technologies
‍You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose
‍We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data
We may share your personal data with the parties set out below:

• Service providers acting as our processors who provide IT and system administration services to us.
• Our professional advisers including lawyers, bankers, auditors and insurers.
• HM Revenue & Customs, regulators and other authorities who we may be legally obliged to share your information with.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers
Our website is hosted outside of the United Kingdom in Dublin, Ireland, but within the European Economic Area. Our emails and documents are also stored within the UK and European Economic Area.

Some of our service providers are based outside of the UK and European Economic Area. Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Government and/or European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission (standard contractual clauses) which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

How long will you use my personal data for?
‍We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. Personal data is retained in accordance with our retention policy which you can request from us by contacting us using the details set out in this policy.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

Your legal rights
‍Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact: privacy@aula.education

No fee usually required
‍You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you
‍We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
‍We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to the privacy policy
We keep our privacy policy under regular review. This version was last updated on August 10th 2020.