PRIVACY POLICY

Numeracy Skills is a free online screener, created by Maths Circle, to enable teachers to assess their students' understanding, fluency and accuracy in their times tables facts.

Maths Circle ("we" or "us") is committed to protecting and respecting the privacy, safety and security of our users, including students, teachers, school administrators and parents (together "Users").

This Privacy Policy (together with our terms and conditions of use) explains in plain language who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights whilst using Numeracy Skills. Please read this carefully to understand how any personal information is used. If you have any questions or concerns about our use of your personal information, then please contact us using the contact details below.

Depending on the circumstances, we may process Personal Information either as a Processor or as a Controller, as defined in the UK GDPR, EU GDPR and CCPA. Where we provide our services in Australia, we are committed to protecting your privacy in accordance with the Privacy Act (Cth) ("Privacy Act"), which includes the Australian Privacy Principles (APPs) and any related privacy codes.

Please email us at [email protected] if you have any questions or concerns.

If you are based within the EU or Switzerland, you can contact DataRep, 77 Camden Street Lower, Dublin, D02 XE80, Ireland [email protected] .

You have the option to access and use Numeracy Skills in "Guest Mode" which means that no Personal Information needs to be provided to us. Please note however that all data and screening results will be automatically deleted as soon as you navigate away from the Numeracy Skills browser when using it in Guest Mode.

If you want to access and/or save the data and screening results of your students, you can log in to Numeracy Skills using your email address. We will then send you a one-time 6-digit authentication code to your email address to authenticate your identity when logging in. Once logged in to the Numeracy Skills platform, you can provide a unique 4-digit code to your students for them to type into their respective browsers, which will link their screening tests to your account. Each student is prompted to input 3 letters which are used to help you identify your students (i.e. initials or a student code/identifier). A simple 3-letter identifier is used instead of full student name, to minimise the amount of Personal Information collected. This then gives you the ability to save and access the results of any screening test carried out by your linked students.

We therefore collect the following information from you if you choose to log in to the Numeracy Skills platform:

• Teacher email address (to authenticate login)
• Student initials or other 3 letter identifier (to help you identify your students)

We collect the answers provided by users of Numeracy Skills to the questions raised on each screening test and the length of time taken to respond in each case. (This information is required to enable us to provide the student user, and any linked teacher user, with statistical feedback on their accuracy and speed, identifying strengths and weakness and next steps)

When users visit the Numeracy Skills site, we may collect certain information automatically from their device (e.g. a user's IP address, device type, unique device identification numbers and login information, browser-type and version, time zone setting, operating system and platform, broad geographic location (e.g. country or city-level location) and other technical information). In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws. (This information is required to ensure that the Numeracy Skills site works as it should for the specific user).

We may also collect information about how a user's device has interacted with the Numeracy Skills site, including the pages accessed and links clicked, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from any page. (This information is required to ensure that the Numeracy Skills site works as it should for the specific user and to help us make necessary improvements to the site).

We do not have targeted advertising on our Numeracy Skills site and we do not sell users' Personal Information. We will keep Personal Information confidential and will not knowingly share or divulge users' data or information to advertisers or any external third parties, however the following categories of recipients may access, process or be transferred your data:

• our sub-contractors who assist us in making, improving and delivering the Numeracy Skills site (these are notified to users in advance as are listed in our standard Terms and Conditions, and any material changes to this list are notified to users by email);
• third parties who provide services on our behalf to help with our business activities (these are notified to users in advance as are listed in our standard Terms and Conditions, and any material changes to this list are notified to users by email). These parties are authorised to process your personal information only as necessary to provide these services to us. This includes our server host Amazon Web Services who handle our electronic data storage, cloud server, email and transmission service and ensure that all Numeracy Skills data is held securely in Australia; and
• any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, (iii) to enforce our terms and conditions, or (iv) to protect your vital interests or those of any other person.

Your Personal Information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. Specifically, our Numeracy Skills site server is located in Australia through Amazon Web Services. We have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Policy and applicable data protection laws.

Where we refer to "lawful basis" in this section, this applies to the extent applicable under the relevant data protection laws.

Teacher email addresses are required in order to fulfil our contractual obligations to you as it is necessary to correctly identify and authenticate each logged in teacher as a site user and manage their account.

Student initials or other 3 letter identifier are required in order to fulfil our contractual obligations to you, so we can help teachers identify their students when reviewing the screening test results provided, so they can then take appropriate action and better support their students with targeted intervention. Initials are used instead of full names for extra anonymity and to minimise the amount of Personal Information we collect.

The data collected from the answers provided by users of Numeracy Skills to the questions raised on each screening test and the length of time taken to respond in each case, are required in order to fulfil our contractual obligations to you, as this information enables us to provide both the student user, and any linked teacher user, with statistical feedback on their accuracy and speed, identifying strengths and weakness and next steps.

Please note that children (under the age of 18 years) cannot register to use the Numeracy Skills site themselves, as they are not lawfully able to agree to our Terms and Conditions. A teacher, tutor, parent or guardian can login and ask them to link their screening test results to their account but it is the teacher, tutor, parent or guardian's responsibility to ensure that any consent to use the Numeracy Skills site has been collected.

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you whilst you use our products. The data that we collect from you is stored on secure servers located in Australia through Amazon Web Services. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. Security measures include data encryption, multi-factor authentication for systems, firewalls, anti-virus malware protection, staff training and security controls over physical access. As part of our privacy compliance processes we regularly review these security procedures to consider appropriate new technology and methods. We also have both UK Cyber Essentials accreditation and UK Cyber Essentials Plus accreditation.

We retain personal information we collect from users where we have an ongoing legitimate business need to do so.

All student screening test data created from an unlinked test or where the user is using Numeracy Skills in Guest Mode is automatically deleted 24 hours after the date of the test and cannot be retrieved.

Our policy is to automatically delete all student screening test data that has been linked to a logged-in teacher 12 months from the date of the test.

Our policy is to automatically delete all teacher email addresses 24 months from their last logged in interaction with the Numeracy Skills site.

Teachers can delete linked student data at any point when logged in to Numeracy Skills and can also delete their own data and accounts.

Pursuant to UK GDPR, the CCPA, COPPA, VCDPA, the Privacy Act and other applicable state legislation and data protection laws, users have the data protection rights set out in this section. Please note that your rights may change based on which of the data protection laws are applicable to you. Where there are differences, we have let you know below:

• Users have the right to know how we process their personal information. This is why we try to maintain transparency about what information we collect and how we use it, as explained elsewhere in this Privacy Policy. These rights can be exercised by contacting us using the contact details provided above. Please note Australian users are informed of these matters through this Privacy Policy.
• If a logged in teacher user wishes to access, correct, update or delete their Personal Information, they can do so at any time by logging into their Numeracy Skills and editing the data as appropriate. They can also delete all of their Personal Information and account by navigating to the Settings and pressing "Delete".
• Parents, guardians and caregivers have the right to access, review, correct, update, delete or refuse collection of their child's personal information. Please note that these requests are handled together with the child's school or tutor. This is in line with UK GDPR, COPPA and FERPA. These rights can be exercised by contacting the teacher directly or contacting us using the contact details provided above.
• Parents, guardians and caregivers have the right to stop the collection and use of their child's personal information. Please note that these requests are handled together with the child's school or tutor. These rights can be exercised by contacting the teacher directly or contacting us using the contact details provided above. Please note this does not apply to Australian users.
• In addition, users can object to processing of their personal information, ask us to restrict processing of their personal information or request portability of their personal information. Again, users can exercise these rights by contacting their teacher directly or contacting us using the contact details provided above. Please note this does not apply to Australian users.
• Teachers with logins have the right to opt-out of the sharing of data for targeted marketing communications we send at any time. Users can exercise this right by either clicking on the "unsubscribe" or "opt-out" link in any marketing e-mails we send, or by updating their settings when logged into the Numeracy Skills site. Alternatively, users can contact us using the contact details above. Please note this does not apply to Australian users.
• Users have the right to opt-out of the sale of their Personal Information, however we do not sell the Personal Information of our users. If Users have any questions about this they can contact us using the contact details provided above. Please note this does not apply to Australian users.
• If you want to make a complaint about the way we have processed your personal information or would like to exercise your rights to your personal information with us, we'd rather you brought it to us in the first instance (using the contact details provided above), but of course users have the right to complain to a data protection authority. For more information, please contact your local data protection authority. Contact details for data protection authorities in the UK are available at https://www.ico.org.uk/make-a-complaint , in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm and the contact details for the Australia data protection authority (the OAIC) are at https://www.oaic.gov.au/privacy/privacy-complaints .

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. We will always inform you by email communication (if we have your email) at least one week in advance of any material changes we make to our Privacy Policy. Users may also be advised at point of login to our Numeracy Skills site. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. Users will be deemed to have consented to any such changes by their continued use of the Numeracy Skills site following any changes being made.

You can see when this Privacy Policy was last updated by checking the "last updated" date displayed at the top of this Privacy Policy.