CAMBRIDGE LEARNING MANAGEMENT SYSTEM ('CLMS')
PRIVACY NOTICE
Privacy Notice
Cambridge University Press & Assessment (we, us, our) are committed to protecting and respecting your privacy.
This privacy notice (together with our Website 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. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting https://www.cambridgelms.org (our Platform) you are accepting and consenting to the practices described in this notice.
1. Important information and who we are
Controller
For the purposes of the UK Data Protection Act 2018, and the General Data Protection Regulation ((EU) 2016/679), the data controller is Cambridge University Press & Assessment of Shaftesbury Road, Cambridge, CB2EA.
We do not sell, share or transfer personal information except as set out in this privacy notice.
We use up-to-date industry procedures to keep personal information as safe and secure as possible and to protect against loss, unauthorised disclosure or access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Platform; 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.
Contact details
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to the Privacy Team at Cambridge University Press & Assessment, Shaftesbury Road, Cambridge, CB2 8EA, or email: [email protected]
Changes to the privacy notice and your duty to inform us of changes
Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Third-party links
Our Platform 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 notices and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal information to these websites.
2. The data we collect about you
Personal data, or personal information, 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).
It is necessary for you to register with us in order to access this Platform. We do not permit children under the age of 13 to register directly on this Platform; an appropriate adult should register on their behalf. We may also collect, use, store and transfer some information from interactive features such as contact and registration forms and online surveys, which may include different kinds of personal data about you, including:
• Identity Data includes first name, last name, username or similar identifier, profile picture, role (student/teacher) and date of birth.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Platform.
• Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
• Usage Data includes information about how you use our Platform, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Learning data – includes data generated by users (writing activities, speaking activities, blog and forum posts); data auto-generated by the Platform (test scores, progress for auto-scored activities); and if you are registered to a class, teacher generated data (grades, feedback, comments).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You or your school may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our Platform;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.• Other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Platform. We may also collect information from third party sites, such as Facebook or Google, if you use social logins. 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.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
• To perform the contract we are about to enter into or have entered into with you, and to provide you with the information, products and services that you request from us.
• To notify you about changes to our service.
• To ensure that content from our Platform is presented in the most effective manner for you and your computer.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer or user. | (a) Identity (b) Contact | (i) Performance of a contract with you (ii) Necessary for our legitimate interests (to supply content or products purchased on your behalf) |
| To process and deliver your order including: • Manage payments, fees and charges; • Collect and recover money owed to us. | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (i) Performance of a contract with you (ii) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: • Notifying you about changes to our terms or privacy notice; • Asking you to leave a review or take a survey. | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (i) Performance of a contract with you (ii) Necessary to comply with a legal obligation (iii) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (i) Performance of a contract with you (ii) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | (a) Identity (b) Contact (c) Technical | (i) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (ii) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the content and advertising we serve to you. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Learning | (i) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to provide feedback, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences. | (a) Technical (b) Usage (c) Learning | (i) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | (i) Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. We do not knowingly market to anyone under the age of 13.
We may use the information you have provided 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.
We may also use the information 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 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, we 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, please tick the relevant box situated on the form on which we collect your data.
Opting out
You can ask us to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, product/service experience or other transactions.
Cookies
Our Platform uses cookies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platform. 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 our Platform may become inaccessible or not function properly.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
Our Platform sets cookies which remain on your computer or device for differing times. Some expire at the end of each session and some remain for longer so that when you return to our Platform, you will have a better user experience.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Where a visitor has posted one of our links onto a third party platform in order to share the content with other users, we may also use cookies (likely to be analytical/performance cookies) to help us track the type of engagement and interaction the content is receiving.
Change of purpose
We will only use your personal information 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
As part of the functionality of the Platform, other users may be able to see your personal data when you carry out certain activities, such as participating in forums, or chats. If you join a school/class when using the Platform, teachers or administrators of the school/class may be able to see your personal data.
We may share your personal information with any member of our group, which means the other parts and departments of the University of Cambridge, including our and their subsidiary companies.
We may share your information with selected third parties, including:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.• Analytics and search engine providers that assist us in the improvement and optimisation of our Platform.
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
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 information to the prospective seller or buyer of such business or assets.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6. International transfers
The data that we collect from you may be transferred to, and stored at, a location outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or 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 information, 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 notice.
All information you provide to us is stored on our secure servers or those of our service providers. 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 Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
7. Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We will normally store your information for at least one year following the last recorded transaction or interaction between us. Your account will be closed after a period of twelve (12) months of inactivity, and for all subscriptions that expired twelve (12) or more months ago.
9. Your legal rights
You can update or retrieve a copy of your personal information by accessing your account via the ‘My Account’ button. If your school has registered your account, you can ask them to edit your personal information as required.
You have the right to ask us to correct any incorrect personal information we store about you, to delete personal information, or otherwise restrict our processing, or to receive an electronic copy of the personal information you provided to us.
To ask for a copy of the information we hold, or to ask us to correct or otherwise alter our current processing, please email us at [email protected].
No fee usually required
You will not have to pay a fee to access your personal information (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 may 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 information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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 may 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.
10. Data Protection Officer
The University of Cambridge has a statutory Data Protection Officer – Trilateral Research Ltd. Should you wish to contact them, you can do so by email: [email protected] Alternatively, please write to them at Trilateral Research Ltd, Crown House, 72 Hammersmith Road, London W14 8TH.
11. Complaints
If you are not happy with the way your information is being handled, or with the response received from us, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) at Wycliffe House, Water Lane, Wilmslow, SK9 5AF.