Privacy Policy

Pebble Learning LTD (We) are committed to protecting and respecting your privacy. 

This policy (together with our terms of use and any other documents referred to in them) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. If there is any conflict between this privacy policy and any other document in relation to the handling of your personal data, the provisions of this privacy policy will prevail.  

Please read the following carefully to understand how we treat your personal data.  

For the purpose of data protection law, the controller is Pebble Learning LTD of E-Innovation Centre, Shifnal Road, Priorslee, Telford, Shropshire, TF2 9FT. However, please note that, where your account for our services has been provided by a university or other institution, they will be the controller and we will be a processor. In such case, please refer to the privacy policy of the relevant institution to find out how your personal data is treated.    

Information we may collect from you

We may collect and process the following data about you: 

• Information you give us. You may give us information about you by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you , search for a product, participate in discussion boards or other social media functions on our website, enter a competition or engage with a promotion or survey and when you report a problem with our website. The information you give us may include your name, address, e-mail address, phone number, organisation, department, job role and dietary requirements.
  • When you subscribe to our services, you will provide the following information: name and email address and user name.  Although not essential, you may also provide us with details of your subject expertise and/or career destination. For “Alumni” accounts the name of the institution you were attached to when the account was created and an institutional user name are also collected.  
  • Where you are paying for an account payment and billing information will be processed by a third-party provider such as PayPal. We do not have access to nor store this information.
• Information we collect about you. With regard to each of your visits to our website or uses of our services we may automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; 
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. 
• Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
  • As a user of our service you will have the option to link your account to a third-party drive such as those provided by Apple, Google and Microsoft. If you do this we will pull information from that drive into our software to make it available to you but it will not be amended or stored in our software. You can disable this link at any time.   

Cookies

Our website uses cookies to distinguish you from other users of our website which helps us to personalise your browsing experience. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy. 

Uses made of the information

We use information held about you in the following ways: 

Information you give to us through our website OR your PebblePad Personal Account. We will use this information: 

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

Information you give to us through our website (including any marketing sign up forms) ONLY. We will use this information: 

• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about; 
• to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you will be given the opportunity to opt out at the point at which we collect the data about you; 
• to notify you about changes to our service; 

Information we collect about you through our website OR your PebblePad account. We will use this information: 

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; 
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer; 
• to allow you to participate in interactive features of our service, when you choose to do so; 
• as part of our efforts to keep our site safe and secure; 

Information we collect about you through our website ONLY. We will use this information to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them. 

Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive). 

• We may use marketing lists to contact people who we think may be interested in our services. We will ensure that these lists and their use are compliant with data protection law. 

Disclosure of your information 

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.  

We may also share your information with selected third parties including: 

• Business partners, suppliers and sub-contractors (such as, for example, companies who host our website and/or software) for the performance of any contract we enter into with them or you. As these third parties change from time to time, we cannot list them here but further details about them are available on request. 
• Analytics and search engine providers that assist us in the improvement and optimisation of our site and services. 
• The institution that provides your account for you provided we are required to do so under our contract with such institution.  

We may disclose your personal information to third parties: 

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. 
• If Pebble Learning LTD or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. 
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of Pebble Learning LTD, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data 

All data entered into PebblePad through a user account will remain within the territory in which it is originally hosted .The relevant regions are as follows:  

For UK and EU accounts the relevant region is the EEA  

For USA accounts the relevant region is the USA  

For Canada accounts the relevant region is Cananda 

For Australia accounts the relevant region is Australia   

Your data may also be processed by staff operating outside the relevant region who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. 

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.  

Unfortunately, the transmission of information via the internet is not completely secure. Although we have measures in place to protect your personal data, we cannot guarantee the security of your data transmitted to our site whilst it is in transit; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access

How long we store your data for

PebblePad data is held for the lifetime of an account. When a user account is deleted, the user’s data is automatically purged after a period of 30 days. In the case of an organisation discontinuing their PebblePad licence, all associated account and user data is purged 150 days after the licence expiry date. 

Support tickets are held for 5 years. 

Contact details gathered as part of marketing activities through our websites will be retained (even if they have unsubscribed from the receipt of further marketing) until a user makes a request to have data held about them deleted. Users shall be able to update their preferences or revoke consent to the processing of their data for marketing purposes via the options contained within all PebblePad communications. 

How do we destroy your data

Individual user data is removed using standard OS and database calls. Provisioned storage containing sensitive data is wiped using the DoD 5220.22-M sanitising method before being returned to cloud storage pools if it is no longer required. 

Your rights 

You have the following rights in relation to your personal data: 

Right to revoke consent 

If we process personal data on the basis of your consent, you have the legal right to revoke such consent at any time. We will then cease the relevant processing activity going forward.  

Right of access to your information 

If you want to know what personal data we have collected or process about you, you may request us to provide a copy of your personal data. We will ask you to identify yourself. Once you have identified yourself, we will provide the requested personal data as soon as reasonably possible however, we will not provide you with a copy of your personal data to the extent that the rights and freedoms of others are or may be adversely affected. 

Right to rectification and erasure of data, and restriction of processing 

If you believe that our processing of your personal data is incorrect, inaccurate, unlawful, excessive, incomplete, no longer relevant, or if you think that your data is stored longer than necessary, you may ask us to change or remove such personal data or restrict such processing activity.  

Right to data portability 

You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format.  

Right to object 

You have the legal right to object, on grounds relating to your particular personal situation, at any time to processing of your personal data.  Furthermore, you have the right to object at any time to our processing of your personal data for direct marketing purposes or to profiling.  

You can also exercise your rights at any time by contacting us at datasecurity@pebblepad.co.uk.

Links to other sites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. 

Removal of your data

You can ask us to provide details of and to remove all data we hold about you. 

Users accessing PebblePad through their university or another organisation should follow the steps outlined here:  

• The user should first contact their organisation (typically a PebblePad administrator) and make a formal request for their data to be removed.  

• The user’s organisation should then notify us of the request.  
• Upon receiving a request for the removal of a user’s data, we will create an inventory of all the data we hold for that user. The inventory will include: User account details, all PebblePad assets created or collaborated upon, submitted work, shared assets, information in logged files, support tickets, and information in marketing databases.  
• The inventory will be presented to the organisation who will enter into a conversation with the user about the implications of deleting the data within the inventory.  
• Following agreement between the user and their organisation, we should be informed in writing of the user’s consent to have their data removed. Following receipt of consent, we will remove the user’s data as a priority and notify all parties when the removal is complete.  

The process for removing data for users accessing PebblePad through Personal Accounts is exactly the same as the above with the exception that requests for an inventory of the data we store and the consent to have data removed should come directly to us at datasecurity@pebblepad.co.uk. 

For any other request to remove data please contact us at datasecurity@pebblepad.co.uk. 

Changes to our privacy policy 

Any changes we may make to our privacy policy in the future will be posted on this page and, where we choose to do so, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. 

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to datasecurity@pebblepad.co.uk.