We at EtonX want to make sure all the information we hold about you (known as “personal data”) is safe and secure. We have written this privacy policy to tell you how we make sure we do that and what to do in case you have any questions for us or want to see what information we have.

This privacy policy is for students, students’ parents/carers and staff at students’ education providers other than EtonX. It also applies to all employees, workers, contractors, agency workers, consultants, directors, EtonX tutors and others who work for us; this group are called “staff” in this policy. Finally, it applies to people at other organisations which work with EtonX.

Staff must read, understand and comply with this policy when processing personal information on our behalf and attend training on its requirements. This policy sets out what we expect from staff to comply with applicable law. This policy is non-contractual. However, compliance with this policy is mandatory. Any breach of this policy by staff may result in disciplinary action up to and including dismissal.

When we process your personal information in the course of our business we are what is known as a data controller. This means we have control over how we use your personal information and who we pass it to.

If you have any questions about our collection or use of your personal information you can email us on support@etonx.com

This privacy policy covers:

 

Who is EtonX?

EtonX (EtonX Limited, company number 09624046) is a trading company wholly owned by Eton College. We offer online courses to teenagers and young adults.

Why read EtonX’s privacy policy?

EtonX needs to collect and use some personal information about students, tutors and others. This privacy policy applies to personal information that EtonX collects when you interact with EtonX and other users through the EtonX marketing website (https://etonx.com), the EtonX course website (https://learn.etonx.com), the EtonX helpdesk website at https://help.etonx.com, during the sign up process (https://signup.etonx.com), by email and in any other form of interaction. This privacy policy explains what personal information we collect about you, and how we use this information.

If you choose not to provide information that EtonX requires in order to provide you with an account on the EtonX course website, then you will not be able to join in the courses.

What types of personal information does EtonX collect?

We collect personal information about past, present and future: students, students’ parents/carers; staff at students’ education providers other than EtonX, EtonX tutors, other EtonX staff and people at other organisations which work with EtonX.

The personal information we collect includes the information we need about your identity, course registration and completion information, expressions of opinions, personal feedback on courses and video recordings of courses, and other material which you submit, or which is submitted about you, on the EtonX website. If you are a member of EtonX staff the personal information we collect includes start and end date, payroll information, assignments, performance reviews and feedback.

Examples can include:

    • details of how we can contact you such as your name, country of residence, telephone numbers, Skype address and email addresses
    • when you created an account on our website and when you deleted your account
    • name and contact details of staff at your education provider other than EtonX
    • name and contact details of your parents/carer
    • names and contact details of someone who has introduced you to EtonX
    • your date of birth
    • your gender
    • passport, national identity card, residence permit, driving licence, school or student identity card
    • records of pre-admission English language level check
    • course scores, grades, records of attendance and certificates
    • safeguarding and disciplinary-related records
    • feedback from our staff about you
    • feedback you provide to us about our staff
    • references, education, engagement, performance and other employment data for our staff
    • images and video recordings of you participating in courses
    • your course assignments, transcripts, content uploads and contributions to our online forums
    • all records of when you contacted us or we contacted you via the websites, on the phone or by email or when you asked us to do something
    • how you use our websites (including any content you submit to us) and any passwords, user names and other things that may identify you to us online.

We may also hold and use what we refer to as “special information” (known as “special category data”) such as:

    • your nationality
    • your political opinions, if you volunteer them to us
    • any information about your health such as any disabilities or injuries you have/have had or times you may not have been very well if you become ill in class or choose to tell us about these things.

In the table below, where your personal information might include this special information you will see this symbol *. We will only use your special information if we have a really good reason to do so such as:

    • if it is in the interests of the public and we have a lawful reason to use it;
    • we need it to help us with a legal case we are involved in;
    • certain laws allow or require us to use it; or
    • you have told us you are happy for us to use it.

In the table below we refer to these as the “special reasons”.

As a company dealing with students under the age of 18, we must process special information about staff including criminal records information as part of our recruitment process for our tutors and other staff members.

Where does EtonX get personal information from?

We will normally collect personal information about you when you create an account on our website or buy anything from us online, or when you use the EtonX course website, or when you talk to us via our websites, social media, on the phone, by e-mail or in some other way.

If your school, other education provider or your parent/carer has arranged for you to take one of our courses we may get personal information about you from the staff at your school or other education provider, or your parent/carer, or another organisation that has introduced you to EtonX. Examples are: name, date of birth, contact details, class or house/tutor group within a school, year group, gender, identification documents, English language certificate or proficiency level, and parent name.

In the case of our tutors and other staff members, we collect personal information from third parties (for example, referees, the Disclosure and Barring Service in the UK, Department for Education and overseas equivalent bodies who may provide information about criminal records).

How does EtonX use your personal information?

We process personal information to enable us to provide online courses to teenagers and young adults. Here are more details:

What we use your information for What type of information we use What legal reason we have for using it
The creation and management of user accounts Your email address, date of birth, country of residence and EtonX user name We need all this information to make sure we do a good job of managing your account with us
The verification and admissions of students All contact details

Your date of birth and gender

Your EtonX user name

Passport or national identity card, residence permit, driving licence, school or student identity card*

Any correspondence we have had with you about your needs

Results of any English language level checks

We need all this information to make sure we deal properly with our students’ application to do one of our courses.

We will only use this ‘special information‘ on the basis of one of the ‘special reasons‘ we talked about above, in this case to check your identity and age.

the provision of educational courses to students, including administration of EtonX courses; responding to student questions; monitoring student progress and educational needs; grading assignments, responding to other materials provided by students, reporting on student engagement and performance internally and externally to parents/carers and education providers other than EtonX; providing assignments, transcripts and certificates to students (including after a student has left); administration of virtual classroom and courses (and monitoring of this). All contact details

Your EtonX user name

Course scores, grades, assignments, transcripts, certificates and records of attendance, records of time spent and number of logins on EtonX websites

Safeguarding and disciplinary-related records

*Images and video recordings of you participating in courses

*Your contributions to our online forums

*Any chats we have had with you about your needs

We need all this information to make sure we provide our students with the courses they order, help our students to complete the courses, obtain optimal benefit from the courses and a positive experience.
the safeguarding of student’s welfare by EtonX when students use EtonX services (especially in the virtual classroom) *Any chats we have had with you about your welfare

*Feedback from our staff about your welfare

*Images and video recordings of you participating in courses

*Content posted from or about you on the EtonX course website

It is in everyone’s interests to make sure that our online environment is safe for our students to study.

Sometimes we may have to keep your details because the law tells us we have to.

We will only use this ‘special information’, on the basis of one of the ‘special reasons’ we listed above.

research into educational trends and best practice for current and future courses We combine this information with information about others and anonymise this information before we share it with anyone outside EtonX for research purposes:

Country of residence

School

Date of birth

Gender

Course scores, grades, assignments, transcripts, certificates and records of attendance

Safeguarding and disciplinary-related records

Feedback from our staff about you and from you about our services

References, education, engagement and employment data for our staff

Records of our chats with you

How you use our websites

It is in our interests to improve the courses we offer.
operational management, including compilation and maintenance of student records; and administration and implementation of EtonX’s policies and rules for students, tutors and other staff All contact details

Your EtonX user name

Date of birth

Gender

Course scores, grades, assignments, transcripts, certificates and records of attendance

*Safeguarding and disciplinary-related records

*Feedback from our staff about you and from you about our services

*Images and video recordings of you participating in courses

*Your contributions to our online forums

*Records of our chats with you

How you use our websites and any user names and other things that may identify you to us online;

It is in our interests to make sure that EtonX operates well.

If we use any ‘special information’, we will only do so on the basis of one of the ‘special reasons‘ we talked about above.

*staff administration, including the recruitment of staff and engagement of contractors (including compliance with Disclosure and Barring Service 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 All contact details

*Any medical data provided by staff

*References, education, engagement and employment/contract data for our staff

*Feedback from you about our services

*Passport or other identity documents

National insurance number

*Safeguarding and disciplinary information

*Criminal records information.

It is in our interests to make sure that we recruit good staff, take care of our staff properly and deal with any staff problems.

If we use any ‘special information’, we will only do so on the basis of one of the ‘special reasons‘ we talked about above.

the promotion of EtonX through its own websites, other publications and communications including through our social media channels Photos or videos of you and your feedback and testimonials about the courses – only where you have told us you are happy with this It is in our interests to promote the courses EtonX offers
direct marketing purposes All contact details

All account information

Details of courses you have undertaken

– only where you have told us you are happy with this

It is in our interests to let you know about other courses you might be interested in
maintaining relationships with current and former students and their parents/carers and education providers. All contact details

Your EtonX user name

Details of courses you have undertaken

– only where you have told us you are happy with this

It is in our interests to stay in touch with current and former students and their parents/carers who may be interested in other courses in the future or may request copies of certificates, transcripts or assignments from us.
To help you if you have a question or are not happy with something we have done Contact details and any chats we have had It is in our interests to make sure we deal quickly with any issues you have.
We will keep all of your personal data on our files *All of your personal data It is in our interests to hold your details on file so we can deal with any issues with your account and to make sure we do a good job in managing your account.

Sometimes we may have to keep your details because the law tells us we have to.

If we use any ‘special information’, we will only do so on the basis of one of the ‘special reasons‘ we talked about above.

To protect our IT systems Details about how you use our websites It is in our interests to make sure that our IT systems are safe and secure for all of our staff and you to use.
If your school or other education provider is involved in you joining the course, to provide the school with information about how you are getting along Your contact details, course scores, grades, assignments, transcripts, certificates and records of attendance and any other information about your progress It is in our interests to ensure your school knows how you are progressing if your school has been involved with you joining the course
Data we collect when you visit our website(s) IP address, browser type, operating system, location, mobile carrier, device information, referral websites, search terms, the pages you visit on the website(s) and the time and date that you access them. It is in our interests to support and improve our information systems
If we sell, transfer or merge parts of our business or our assets, or acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. *All of your personal data It is in our interests to be able to buy and sell companies or parts of them.

If you have given us information and told us we can use it in a certain way, you can tell us to stop using it at any time by contacting support@etonx.com. Please note that there may be reasons why we might continue to use your information after such a request; we will let you know if this applies at the relevant time.

Is your personal information safe?

We have put in place lots of security measures to make sure your details don’t go missing or get used in a way they shouldn’t be. We have a great team of people working with us who are trained to know how to use your details securely and will only use your details when and how we tell them to.

Did you know that all ‘data controllers’ based in the European Union and the UK like us are subject to data protection laws that make sure that your personal data is safe?

We store your personal information on computer servers in the UK. We work with our suppliers: Zeus Learning Limited which helps us to develop our software and create and manage your account effectively, NCR Eduservices Pvt. Limited which helps us by staffing our helpdesk, Zendesk which provides us customer support software we use to help you answer your questions and help with your problems, Hootsuite which helps us with social media and Hubspot which provides us with the software we use to store your contact details and course choices and to send your marketing messages. Some of your personal information may be transferred to and stored by part of the Zeus, NCR, Zendesk, Hootsuite or Hubspot team some of which are outside of the UK and the European Union, and so not subject to the laws that make sure your details are safe. Where this happens, we will do everything we can to make sure that your information is only used in the way we say it will be and is kept secure. At the moment we do this by having agreements with Zeus, NCR, Zendesk, Hootsuite and Hubspot called data processing agreements. The data processing agreements require Zeus, NCR, Zendesk, Hootsuite and Hubspot to respect the security of your personal information, to treat it in accordance with the law, to use your personal information only in accordance with our instructions and, if your information does need to be transferred outside of the UK or EU to a country which has a lower level of protection for your personal information (and so has not been assessed as being “adequate” by the EU Commission or the UK’s data protection regulator, the Information Commissioner’s Office), we will make sure that we also put in place any additional contractual safeguards required by the Information Commissioner’s Office. If someone else is using your personal information because we have told them to, we will also make sure that we put measures in place with them to protect it.

How long does EtonX keep your personal information?

We collect personal information from you for different reasons and so we might keep it for different lengths of time. We retain data of student performance (including grades, transcripts, assignments, and certificates) and course participation dates indefinitely. Video recordings are stored for 6 months from the date of the recording. We may need to retain some information for longer for legal reasons, for example information relating to safeguarding incidents. This will be retained in a secure environment and access will be restricted. Most of the time, we will keep your contact details for 1 year after you last get in touch with us.

It is important to make sure that the details we hold about you are accurate and up to date, so make sure you let us know if anything like your email address or phone number changes. You can do this through your account on our website.

What are your rights?

Did you know you can ask us to do lots of things with your personal information?

You can ask us:

  • to tell you how your personal information is being used
  • to provide you with a copy of all personal information we hold on you
  • to correct some of the personal information we hold if it is not correct or out of date like your contact details for example
  • to delete all of the personal information we hold on you (unless we have a good reason not to!)
  • to stop using your personal information in a certain way
  • to send your personal information to you or another organisation like your school for example

Some of the rights may not always apply to the personal information we hold for you as there are sometimes requirements and exemptions attached which means we need to hold on to certain information and other times the rights may not apply at all.

DON’T FORGET though, if you have told us we can use your personal information in a certain way and you would like us to stop, you can tell us to stop at any time and you can always tell us to stop sending you marketing messages. More information about these rights can be found online here https://ico.org.uk/your-data-matters/

If you are unhappy about something, you can make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would like the chance to deal with your concerns before you approach the ICO so please contact us first at support@etonx.com

What if you contact EtonX via social media?

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

What about privacy and other websites?

Our websites contain links to other websites. These other websites do not operate under this privacy policy, they should have their own policy to explain how they keep your data safe. If you follow a link to another website we suggest you read the privacy policy there.

What about cookies?

Please see our cookie policy here.

What happens if EtonX needs to change this privacy policy?

Keep an eye out for changes to this notice online. If we make big changes the version date at the top of the notice will be updated. Of course where we are required to do so by law, we will ask for your permission before we change the reason for using your details.

How do you get in touch with EtonX?

Please contact us if you have any questions about our privacy policy by email at support@etonx.com.