Privacy Policy

Spiral Step Learning ("we", "us" or "our") respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use and protect personal information when you visit our website, contact us, or interact with us in connection with our digital educational resources.

Website: www.spiralsteplearning.co.uk
Email: contact@spiralsteplearning.co.uk 

1. Who we are

Spiral Step Learning is a partnership providing digital educational resources to schools and educators.

For the purposes of applicable UK data protection law, we are responsible for deciding how and why personal data is processed in connection with our website and business activities.

If you have any questions about this Privacy Policy or how we use personal data, please contact us at:

contact@spiralsteplearning.co.uk 

We do not currently operate from a separate business office.

2. Information we collect

Depending on how you interact with us, we may collect:

• your name;

• email address;

• telephone number;

• postal or business address;

• information you provide through our contact form;

• information contained in correspondence between you and us;

• information about your school, educational organisation or professional role where you choose to provide it;

• information relating to your communications and interactions with us.

We will only collect information that is reasonably necessary for the purposes described in this Privacy Policy.

3. How we collect personal information

We may collect personal information when you:

• complete our website contact form;

• contact us by email or telephone;

• request information about our educational resources;

• express an interest in our products or services;

• communicate with us in a professional capacity;

• otherwise provide information to us voluntarily.

We may also obtain limited business contact information from publicly available sources, such as school or educational organisation websites, where this is relevant to our business activities.

For example, we may record a general school contact address such as an admin@ or enquiries@ address for the purpose of identifying and communicating with the relevant school or organisation.

The fact that contact information is publicly available does not, by itself, mean that the individual or organisation has consented to receive marketing communications from us.

4. How we use personal information

We may use personal information to:

• respond to enquiries;

• provide information about our educational resources and services;

• communicate with schools, educators and other professional contacts;

• manage our business relationships;

• administer and improve our website;

• send marketing communications where permitted by applicable law;

• maintain records of communications and marketing preferences;

• maintain a record of requests not to receive marketing;

• protect the security of our website and business;

• comply with our legal and regulatory obligations.

We will not use personal information for purposes that are incompatible with the purposes described in this Privacy Policy without providing appropriate information or obtaining consent where required.

5. Our lawful bases for processing

Under UK data protection law, we need a lawful basis for processing personal data.

Depending on the circumstances, we may rely on:

Consent

Where appropriate, we may process personal data where you have given us your consent.

You can withdraw consent at any time.

Legitimate interests

We may process personal data where this is necessary for our legitimate interests, provided that those interests are not overridden by your interests, rights or freedoms.

Our legitimate interests may include operating and developing our business, responding to enquiries, communicating with professional contacts, providing and improving our services, maintaining appropriate business records and protecting our website and business.

Where we rely on legitimate interests, we will consider whether the processing is necessary and balance our interests against the individual's rights and expectations.

Contract

We may process personal data where necessary to take steps at your request before entering into a contract or to perform a contract with you.

Legal obligation

We may process personal data where necessary to comply with a legal or regulatory obligation.

6. Marketing communications

We may wish to communicate with schools and educators about our digital educational resources, services, updates and related information.

We will comply with applicable requirements under the Privacy and Electronic Communications Regulations (PECR) and UK data protection law when carrying out direct marketing.

We may use publicly available business contact information, including general school contact addresses such as admin@ or enquiries@, where we have a lawful basis to do so and where the applicable electronic marketing rules permit the communication.

The fact that an email address is publicly available does not, by itself, constitute consent to receive marketing emails.

Because Spiral Step Learning operates as a partnership, we will take particular care when determining whether the recipient is subject to the rules applicable to an individual subscriber or a corporate subscriber under PECR.

Where consent is required, we will obtain appropriate consent before sending marketing emails.

Where we process personal data for direct marketing, individuals have an absolute right to object to the use of their personal data for direct marketing.

Every marketing email we send will identify Spiral Step Learning and provide a straightforward method of opting out of further marketing communications.

If you ask us not to send you marketing communications, we will respect that request.

We may retain limited information necessary to record your marketing preference and ensure that we do not contact you again for marketing purposes.

The ICO's current guidance confirms that publicly available contact details do not automatically provide permission for unsolicited electronic marketing and that additional PECR requirements can apply to partnerships. (ICO)

7. Contact forms

If you use our website contact form, we will collect the information you choose to provide.

This may include:

• your name;

• email address;

• telephone number;

• address;

• the contents of your enquiry.

We use this information to respond to your enquiry and, where appropriate, communicate with you about our products and services.

Please do not provide sensitive personal information through our contact form unless we specifically request it.

8. Cookies

Our website may use cookies or similar technologies that are necessary for the website to function.

We do not currently use analytics or advertising tracking technologies such as Google Analytics or Meta Pixel.

If this changes, we will update our cookie information and, where required, obtain appropriate consent before using non-essential cookies or similar technologies.

9. Who we share your information with

We do not sell personal information.

We may disclose personal information where reasonably necessary to:

• service providers who help us operate our website or business;

• professional advisers, where necessary;

• regulators, government authorities or law enforcement where legally required;

• other parties where disclosure is necessary to protect our legal rights, property or the safety of our business or others;

• other parties where you have given us permission to share the information.

We will only share personal information where there is an appropriate legal basis for doing so.

10. International transfers

We do not currently intentionally transfer personal data outside the United Kingdom.

If this changes, we will ensure that any international transfer is carried out in accordance with applicable UK data protection law and that appropriate safeguards are used where required.

11. How long we keep your information

We will only retain personal information for as long as reasonably necessary for the purposes for which it was collected, including where necessary to meet legal, accounting or reporting requirements.

Contact and enquiry information will generally be retained for as long as necessary to deal with the enquiry and for a reasonable period afterwards.

Marketing information will be retained for as long as reasonably necessary for our marketing activities and to manage marketing preferences.

Where someone asks us not to contact them for marketing purposes, we may retain limited information on a suppression or "do not contact" list so that we can respect that request.

We will periodically review the personal information we hold and securely delete or anonymise information that we no longer need.

12. How we protect your information

We take reasonable technical and organisational measures to protect personal information against accidental loss, unauthorised access, alteration, disclosure or destruction.

However, no method of transmitting information over the internet or storing information electronically can be guaranteed to be completely secure.

13. Your data protection rights

Depending on the circumstances, you may have rights under UK data protection law, including the right to:

• request access to the personal information we hold about you;

• ask us to correct inaccurate or incomplete information;

• ask us to erase your personal information in certain circumstances;

• ask us to restrict how we process your personal information in certain circumstances;

• object to certain processing;

• object to the processing of your personal data for direct marketing;

• withdraw consent where we rely on consent as our lawful basis;

• receive certain personal information in a portable format where the right to data portability applies.

You can exercise your rights by contacting:

contact@spiralsteplearning.co.uk 

We may need to verify your identity before responding to certain requests.

14. Complaints

If you have concerns about how we have handled your personal information, please contact us first so that we can try to resolve your concern.

You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO).

ICO website: https://ico.org.uk/ 

15. Children's privacy

Our website and services are intended for schools, educators and other professional users.

Our website is not specifically directed at children, and we do not knowingly collect children's personal information through our website for marketing purposes.

If you believe that a child has provided us with personal information inappropriately, please contact us so that we can investigate and take appropriate action.

16. Future accounts and services

At present, schools and educators do not need to create an account or log in to use our website.

We may introduce user accounts, logins or additional online services in the future.

If we do so, we will review and update this Privacy Policy to explain what additional personal information we collect, why we collect it, how it is used, how long it is retained and any additional rights or choices that apply.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our business, website, technology or legal requirements.

When we make changes, we will update the "Last updated" date at the top of this Privacy Policy.

18. Contact us

If you have any questions about this Privacy Policy or how we process personal information, please contact Spiral Step Learning:

contact@spiralsteplearning.co.uk 

Website: www.spiralsteplearning.co.uk