Privacy Policy

1. Scope
   All data subjects whose personal data is collected, in line with the requirements of the GDPR.
2. Responsibilities
   1. The Data Protection Officer / GDPR Owner is responsible for ensuring that this notice is made available to data subjects prior to Acorn Aspirations collecting/processing their personal data.
   2. All Employees/Staff of Acorn Aspirations who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
3. Privacy notice
   1. Who are we? Acorn Aspirations (“us”, “we”, or “our”) operates the http://acornaspirations.com/ website (the “Service”). We are a UK based company offering tech education services for children and teens.

Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here: elena.sinel@acornaspirations.co.uk

The personal data we would like to potentially collect or process about [collect from/process on] you is:

The personal data we collect will be used for the following purposes:
• Fulfill your booking
• Prevent fraud
• Enable us to communicate with you
• Our Financial records
• Child Safety/Care
• Analytics to optimise logistics and future event offerings
• Profiling to ensure we send only relevant marketing messages (e.g. avoid sending information about events in a region or age group that is not relevant)

Our legal basis for processing for the personal data:
• Fulfill a contract
• Legal Obligation
• Protect Vital Interests and provision of health or social care
• Consent Given

Any legitimate interests pursued by us, or third parties we use, are as follows:
• Ensure balance in gender/learning needs in class and tutor assignment
• Aid in logistics (e.g. ensure we have sufficient T-shirts available in the student sizes)
• Verify students are the right age for the course
• Determine if a region or school needs additional camps/events/resources to meet demand

The special categories of personal data concerned are:
• Provision of health or social care – we need to know how to respond to an emergency health care situation such as administering an EPI pen or to support students with additional learning needs.

1. 1. Consent
      By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
      Consent is required for Acorn Aspirations to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by requesting a Withdrawal of consent form by emailing elena.sinel@acornaspirations.co.uk.

1. 1. Disclosure
      We do not pass information to any other parties or for any other purpose without first obtaining your consent.
   2. Retention period
      Acorn Aspirations will process personal data and will store the personal data for up to 7 years from last contact with the data subject. Some data is retained for a shorter period but for HMRC financial reporting, prevention of fraud and customer service some data must be retained for the full 7 years.

1. 1. Your rights as a data subject
      At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
      • Right of access – you have the right to request a copy of the information that we hold about you.
      • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
      • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
      • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
      • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
      • Right to object – you have the right to object to certain types of processing such as direct marketing.
      • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
      • Right to judicial review: in the event that Acorn Aspirations refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data. You can request a Subject Access Request Form by emailing elena.sinel@acornaspirations.co.uk

1. 1. Complaints
      In the event that you wish to make a complaint about how your personal data is being processed by Acorn Aspirations (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Acorn Aspirations’ data protection representatives Data Protection Officer / GDPR Owner.

The details for each of these contacts are:

1. Privacy statement
   Personal Data
   Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
   “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information
This privacy notice tells you how we, Acorn Aspirations, will collect and use your personal data for fulfilling orders, child safety, marketing messages for mailing lists you have subscribed to, optimising our services (selection of courses offered in a region, ensure messages that are sent to you are relevant, logistics of equipment and tutors etc), financial records and prevention of fraud. We also require your information for customer services, managing complaints and requests.  [outline further information on services and activities that you collect personal data, for example: cookies, profiling, complaints, subscriptions, etc.)

Why does Acorn Aspirations need to collect and store personal data?
In order for us to provide you with our tech education services we need to collect personal data for us to know which courses you have booked, provide timely and relevant communications about your booking(s), inform you of any health, education or safety issues with your child, keep accurate records for accounting, logistics of running a camp. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes Acorn Aspirations would contact you for additional consent.

Will Acorn Aspirations share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Acorn Aspirations in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Acorn Aspirations’ procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Acorn Aspirations use the personal data it collects about me?
Acorn Aspirations will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Acorn Aspirations is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Acorn Aspirations contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?
Acorn Aspirations at your request, can confirm what information we hold about you and how it is processed. If Acorn Aspirations does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU. 
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Acorn Aspirations or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?
Acorn Aspirations accepts the following forms of ID when information on your personal data is requested:
• Current signed passport
• Current UK driving licence 
• Local authority council tax bill for the current council tax year
• Birth certificate 
• Utility bill or Bank Statement (from last 3 months)
• National identity card

Contact details of the Data Protection Officer / GDPR Owner:

Document Owner and Approval

The Data Protection Officer / GDPR Owner is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.

A current version of this document is available to all members of staff on the corporate intranet and is published at http://acornaspirations.com/privacy-policy.