This policy applies to the following sites and products:
This Policy explains our approach to online information collection, storage and use in connection with Twig Education sites, as well as the specific choices you can make about your own information. Please read this Policy carefully. By using Twig Education sites you will be deemed to have agreed to this Policy, so if you do not agree please do not use the site.
Please note: Where applicable, this policy can be used in conjunction with other policies where a specific agreement between you, your school, district or local educational authority and Twig Education has been reached.
- In Europe where Twig Education complies with GDPR regulations
- In California, USA where Twig Education signs the CSDPA upon a school district’s request
Under such conditions, the stricter set of restrictions will apply.
This Policy contains details on the following:
- Information we collect and why
- Who we will share your personal information with
- Where we store your personal information
- Your rights, including opt-in and opt-out
- Your rights to access your personal information, keep it up to date and ask us questions
- Cookies & Third Party Services
- Data retention policy
- Data breach procedure
We may post changes to this Policy from time to time, so do review it regularly. This Policy was last reviewed on 7th April 2020. If you have any questions about this Policy or the information that we hold, please contact us. Our contact details can be found at twigeducation.com/contact
1. Information We Collect and Why
Information collected on your visit to our site: We do automatically collect certain non-personally identifiable information when you visit our site – such as the type of browser you are using, the type of operating system you are using, the domain name of your Internet service and your IP address. This enables us to review site usage, e.g. information on which pages are more popular than others, which allows us to improve the design and content of our site. Details of IP address are not linked to user records so cannot be used to identify individuals.
Information collected when you register or contact us: We collect personally identifiable information about you, e.g. your name, address, telephone number, email, etc., only when you choose to complete and submit a registration application to us or if you contact us directly. This information enables us to administer your registration and to provide you with the personalized features and the particular site service(s) for which that registration was necessary. We also use the personally identifiable information you provide to us when you contact us directly to respond to your specific inquiry or to administer the relevant site activity to which it relates e.g. to enter you into a site competition or to supply information or goods you have requested.
Information collected when you post on our site: You should be aware that you may be making available personally identifiable information about yourself when you submit material to be posted to the site e.g. for forums or other interactive elements of the site. Please take care when doing so. You can always contact us if you wish to remove any such information (see Your Rights, Including Opt-In and Opt-Out Provisions section below).
Information we collect from third parties: we may collect information from third parties about you from time to time. This information is necessary for us to recognize you as a registered subscriber. This may include rostering information for district, local education authority and school users.
Information we collect for rostering purposes: we collect information for rostering of district, local education authority and school users. This data is for district, local education authority and school purposes only and is not sold, used for any marketing purposes or shared with 3rd parties outside of the requirements of providing the service through our platform.
2. Who We Share Your Personal Information With
We do not share or make commercial use of any personal information provided by educational institutions for rostering purposes.
When you provide your registration application, and in some cases when you supply personally identifiable information directly to us from certain parts of the site, we may provide you with the opportunity to opt-in to certain uses e.g. to provide you with information about the site or other services that you may find of interest. We will only use your personally identifiable information for marketing purposes or share your personally identifiable information with anyone else for marketing purposes if you have specifically consented to that. Remember that you can opt-out of these again at any time (see Your Rights, Including Opt-In and Opt-Out Provisions section below).
Please be aware that it is possible, though unlikely, that we might be forced to disclose personally identifiable information in response to legal process or when we believe in good faith that the law requires it, e.g., in response to a court order or a law enforcement agency’s request.
Twig Education does not sell any personal data to third parties.
3. Where We Store Your Personal Information
Your information is stored in a secure database and we employ appropriate technical and organisational security measures to prevent unauthorized access to information that we collect online. Twig Education aims to ensure that any data uploaded to our systems is secure in transit and at rest on our servers. To ensure this we make use of SSL certificates for transfer of data to and from our website.
If you reside in the EEA, personal information you provide to us will, in general, be stored within the EEA. In the event that we need to store your personal data outside of the EEA, we will ensure that any service providers are compliant with the GDPR.
Our underlying technology and data storage provider is Amazon Web Services. Information on their position on data privacy for your local region can be found here aws.amazon.com/compliance/data-privacy/
We also make use of:
- Salesforce CRM Services – please find their compliance information here: www.salesforce.com/crm
- Pardot CRM Services – please find their compliance information here: www.salesforce.com/pardot
Your personal information will only be stored as long as we need to use it to service your usage of Twig Education’s sites and services.
Anonymization of data is carried out on a regular basis as appropriate.
4. Your Rights, Including Opt-In and Opt-Out Provisions
You have the option at any time to request that we provide a copy of the personal information we hold relating to you and we shall try to provide this information to you within one month of your request.
You have the right to ask us to update or remove any such personal information.
Parents and guardians have the right to request the deletion of personal information relating to themselves or their ward or dependant. This should be requested through the relevant district, local education authority or school.
You have the right to ask us to stop contacting you where we do this in accordance with your previous consent.
You have the right to complain to your local or national data protection authorities and governance bodies if you do not think we have handled your data in accordance with this policy.
5. Contact Us for Access to Your Personal Information
To contact us please visit twigeducation.com/contact to view our most up to date contact details.
6. Cookies & Third Party Services
A cookie is a text-only string of information that a website transfers to the cookie file of the browser on a user’s device local storage so that the website can remember who the user is. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number.
When you visit our site we send you a cookie. Cookies may be used in the following ways:
To enable the personalization features on our site, which give you the ability to recall recently viewed pages and see information which you have provided online.
To compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our site. We cannot identify you personally in this way.
Two types of cookies may be used on this site, session cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site, and persistent cookies, which remain in the cookie file of your browser for much longer, though how long will depend on the lifetime of the specific cookie.
You have the ability to accept or decline cookies by:
- modifying the settings in your browser. You may not, however, be able to use all the interactive features of our site if necessary cookies are disabled.
- using the cookie options dialog that is presented when you visit our sites. Using this option should allow you to decline all but the necessary cookies required for the site to function.
You can block cookies using the methods above but please remember that if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
7. Data Retention
For personal information not provided for rostering purposes, we will retain this information for no longer than 3 years after our last contact with you or the date of your agreement to allow us to store your information. You may, at any time, request this information to be removed from our systems.
Information provided for rostering purposes will be retained only as long as it is directed by the district, local education authority or school making use of our systems.
8. Data Breach Procedure
In the event of a data breach, we will endeavour to report this breach to the relevant district, local education authority, school or individuals as soon as possible after becoming aware of the breach. As a result of investigating the breach, we will make all efforts to prevent any further breach from happening.