EtonX is a wholly owned trading subsidiary of Eton College offering soft skills courses to students aged 14-20. EtonX needs to collect certain personal data about students and those with whom it communicates. This privacy policy applies to information that EtonX collects when you interact with EtonX and other users through the EtonX marketing site (https://etonx.com) and the course site (https://learn.etonx.com). The privacy policy explains what personal information we collect about you, and how we use this information.

If you do not accept the terms in this Privacy policy, please do not access, browse, or register for an EtonX account or register for any courses. If you choose not to provide information that EtonX requires in order to provide you with an account offered on the EtonX Site, then you will not be able to participate in the courses.

The Privacy policy covers:

  • Types of personal data we collect
  • How we collect your personal data
  • How your information is used
  • Storage and Security
  • Your Rights
  • How long we keep personal data
  • Cookies
  • Data logs
  • Social Media
  • Third-party websites
  • Changes to our Privacy policy
  • How to contact us

Types of personal data we collect

We collect personal data about prospective, current and past students and their parents; teachers, staff members and freelance tutors.

The personal data we collect takes different forms, including but not limited to factual personal information, expressions of opinions, personal feedback or video recordings.

Examples include:

  • names, country of residence, telephone numbers, email addresses, date of birth, gender and other contact details including teacher and school information;
  • personal identification;
  • family or guardian details;
  • course scores and grades, transcripts, records of attendance;
  • safeguarding and disciplinary-related recording;
  • references, education and employment data; and
  • images and video recordings.

As a company dealing with students under the age of 18, we are required to process special category personal data as part of the admission process and criminal records information about individuals as part of the recruitment process (particularly staff members and freelance tutors). We do this according to applicable law (including with respect to safeguarding or employment) or by explicit consent.

How we collect your personal data

EtonX collects data by relying on consent. For students, parents and teachers, we collect most of the personal data from the individual when they register their interest or purchase an EtonX course.

In the case of staff members and freelance tutors, we collect data from third parties (for example, referees, the Disclosure and Barring Service or third-party recruitment agencies).

How your information is used

We process personal data to support our operation as a provider of online courses to students aged 14-20, and in particular for:

  • the selection and admission of students;
  • the creation and management of user accounts;
  • the provision of educational courses to students, including administration of EtonX courses; responding to student questions; monitoring student progress and educational needs; reporting on student engagement and performance internally and externally to parents/guardians and teachers; providing transcripts to students (including after a student has left); administration of virtual classroom and courses (and monitoring of this) in accordance with our Monitoring Policy;
  • the safeguarding of student’s welfare by EtonX when students use EtonX services (especially in the virtual classroom);
  • research into educational trends and best practice for current and future courses;
  • operational management, including compilation and maintenance of student records; and administration and implementation of EtonX’s policies and rules for students, staff and tutors;
  • staff administration, including the recruitment of staff and engagement of contractors (including compliance with DBS procedures); administration of payroll, pensions and sick leave; review and appraisal of staff performance, conduct of any grievance, capability or disciplinary procedures; and the maintenance of HR records for current and former staff; and providing references;
  • the promotion of EtonX through its own websites, other publications and communications including through our social media channels;
  • direct marketing purposes; and
  • maintaining relationships with current and former students and their parents/guardians.

Storage and security

We transfer and store your data outside of the European Economic Area (EEA) to our data processor with your consent. We take the appropriate measures to ensure that your data is protected in accordance with principle 8 of the Data Protection Act (1998). Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that we use specific contracts approved by the European Commission which give personal data the same protection that it has in Europe.

Our data processor, Zeus Learning, uses personal data to create and manage your account effectively. Zeus Learning only processes data under a Data Processing Agreement

Under the new GDPR regulations, you have the right to access and ask for deletion and/or correction of data that we hold about you. For students, much of your personal information is available in your EtonX account. You are not able to edit your username or email address as this is an EtonX system restriction. If you wish to change these at any time, please follow the procedure below. Your account dashboard lists all current and archived courses and contains copies of your answers and other participation and performance in courses. Please contact support@etonx.com to access or update other information.

You have the right to:

Request access to your personal data. This allows you to receive a copy of the personal data we hold about you.
Request correction of the personal data that we hold about you. We try to make sure that all personal data we hold is up to date and as accurate as possible.
Request deletion of your personal data and/or account. This allows you to ask us to delete or remove any personal data where there is no good reason for us to continue processing it. We may not always be able to comply with your request of deletion for specific legal reasons which we will notify of, if applicable, when you request deletion.
Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to do any of the above, please contact us using the contact details listed below. We will try to respond to all legitimate requests within one month.

How long we keep your personal data

We only keep personal data for as long as is necessary or required by law. We retain data of student performance (including grades transcripts, and certificates) and course participation dates indefinitely. Video recordings are stored for 6 months after the date after the final group class. We may need to retain information relating to safeguarding incidents for legal purposes. This will be retained in a secure environment and access will be restricted accordingly.

We keep your data for 365 days from our last point of contact with you. If you are not eligible for our courses and will not be eligible for our courses within the next 365 days, we will delete your information immediately.

Cookies

Use of cookies

EtonX collects information about users visiting its website and undertaking its service by placing cookies on your computer, tablet or mobile device (“device”). A cookie is a small text file that the browser deploys on your device. A cookie stores information about visits to websites and recognizes you and your preferences every time you visit site, usually for a period of time. This allows us to provide you with a consistent service based on what you are expecting.  When you visit etonx.com or our related sites, a session cookie is deployed on your device that lasts the duration of your visit. We also deploy persistent cookies to remember you and make your experience faster and more convenient. You can change the settings of your browser to block cookies but this may result in a worse user experience. In some cases, you may not be able to use some of our services unless you allow us to deploy a cookie on your device. You can, of course, delete your cookies at any time.

We use cookies to give you the best and most relevant experience in a timely manner, to identify you and provide you with a personalised service, whether we are advertising to you or you have paid for one of our services. Our intention is that this will provide you with an exceptional learning experience. We also deploy cookies to make sure that your account is secure and that you meet the terms and conditions of our service. Finally, we use cookies to help in safeguarding and security.

We use a range of different types of cookies, including the following:

Site Analysis Cookies: Our website uses Google Analytics (an analytics service provided by Google, Inc). Google Analytics uses cookies which help EtonX analyse how users interact with and use the website(s) in order to help us improve the functionality and experience of our website(s). You can opt-out of this by going to the Google Analytics opt-out browser here: https://tools.google.com/dlpage/gaoptout

Advertising Cookies: We use cookies from Facebook to help improve the site. We also deploy Crazy Egg to understand what areas of the site and our courses are important to users. These cookies are non-identifiable to us but help us report information about users and potential users

Tracking Cookies: Crazy Egg is a tracking cookie to identify usage on the site, to see what users are most interested in reading. The cookie also identifies whether the user is new or returning. If a visitor has set the setting on their browser to not allow cookies to be stored then tracking will not occur.

Session Cookies: A mix of session and “permanent” cookies lasting 30 minutes, 6 months, or 1–2 years. Anonymously tracks use of website.  These cookies are set or updated on any page visited. See here for full details. Several cookies are set but all serve the same purpose: to see how people reached the site and used it, including search terms used and referring sites.

Authentication Cookies: these help to understand who you are and at what stage you are at in your learner journey

Performance Cookies: we need to use some cookies to ensure that you have an excellent experience, by loading pages early and allowing faster response times between what you request and what you receive from our server.

 

For further information about cookies, including to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

These are the main intentions of why we have cookies. Please re-visit this page to understand any changes that we make. In some cases, we use other third-party services that may allow a third party to deploy cookies onto your device. The third party that deploys the cookie on your device is responsible for how you process your data and we recommend that you read their privacy policies.

Data logs

Data we collect when you visit our website(s) can include but is not limited to: IP address, browser type, operating system, location, mobile carrier, device information, referral site, search terms, the pages you visit on the website(s) and the time and date that you access them.

Social media

If you contact us via social media, the message will be stored by Hootsuite (a third party provider) for three months. It will not be shared with any other organisations.

Third-party websites

Our website contains links to third-party websites. Where the marketing site and course site links to other websites such other websites do not operate under this Privacy policy. EtonX recommends that you look at the privacy policies posted on such other websites to understand their procedures and how they process your data.

Changes to our Privacy Policy

We keep our privacy policy under regular review and we will place any updates on this webpage.

Contact us

Please contact us if you have any questions about our privacy policy. If you’d like to access the personal information that EtonX holds about you, please contact us by email at support@etonx.com.

Last updated: 23 May 2018.