What this policy covers
Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This
policy is intended to help you understand:
your choices about how we use information about you. Your choices include how you can object to certain uses of information about
you and how you can access and update certain information about you.
If you do not agree with this policy, please do not access or use our Services or interact with any other aspect of our
When we refer to "Kinteract," "we," or "us" in this policy, we mean Make It Plain Ltd., which controls the information Kinteract
collects when you use the Services. Kinteract offers a collaborative digital portfolio, including our web, desktop, and mobile
products, which help to track learner progression. We also own and operate a number of websites and offer related services, like
support. We refer to all of these products, together with our other services and websites as "Services" in this policy.
Education institutions, primarily Schools and Nurseries/Kindergartens, subscribe to Kinteract to use it as a digital portfolio and
assessment platform for students under their care and to share with their staff. In addition the institution may share this
information with parents and carers of those students.
Relationship with Kinteract and managed accounts
If your account was created through an institution subscribing to Kinteract then the institution own the data they place in our
service, and the institution are the Data Controller and Kinteract is just the Data Processor. Moreover where we provide the
Services under contract with an organisation (for example your employer), that organisation controls the information processed by
the Services. For more information, please see Notice to End Users below.
What information we collect about you
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as
further described below.
Information you provide to us
We collect information about you when you input it into the Services or otherwise provide it directly to us.
Account and Profile Information:
We collect information about you when you register for an account, create or modify your profile, set preferences. For example,
you provide your contact information when you register for the Services. You also have the option of adding a profile photo,
bio, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you
select settings within the Services.
Content you provide through our products:
The Services include the Kinteract web, desktop and mobile products you use, where we collect and store content that you post,
send, receive and share. This content includes any information about you that you may choose to include. Content also includes
the files and links you upload to the Services. Examples of content we collect and store include: narrative on a card, files you
attach to a card, tasks to do and completed, assessments and reports on student performance.
Content you provide through our websites:
The Services also include our websites owned or operated by us. We collect other content that you submit to these websites,
which include social media or social networking websites operated by us. For example, you provide content to us when you provide
feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.
Information you provide through our support channels:
The Services also include customer support, where you may choose to submit information regarding a problem you are experiencing
with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our
representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary
of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving
Institutional Sign Up
Specifically when an institution subscribes we store the following:
The name and address of the institution
The name, email address and telephone number of the person at the institution who plays the role of account owner/administrator
The institution may then store some or all of the following data on our Service
The names and email addresses of their staff
The names, dates of birth, addresses and email addresses of students
The names, addresses, email addresses of parents and carers of students
The components of a digital portfolio:
- Observations, posts, next steps
- Assessment and reports of student performance
- Rich media including audio, photos and videos
Information we collect automatically when you use the Services
We collect information about you when you use our Services, including browsing our websites and taking certain actions within the
Your use of the Services:
We keep track of certain information about you when you visit and interact with any of our Services. This information includes the
features you use; the cards, reports, assessments, next steps and other links you click on; the type, size and filenames of
attachments you upload to the Services; frequently used search terms; and how you interact with others on the Services.
Device and Connection Information:
We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information
includes your connection type and settings when you install, access, update, or use our Services. We also collect information
through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and
crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better
Service experience. How much of this information we collect depends on the type and settings of the device you use to access the
Cookies and Other Tracking Technologies:
device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more
information, please see our
, which includes information on how to control or opt out of these cookies and tracking technologies.
How we use information we collect
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have
communicated to us. Below are the specific purposes for which we use the information we collect about you.
To provide the Services and personalise your experience:
We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you
log in, provide customer support, and operate and maintain the Services. For example, we use the name and picture you provide in
your account to identify you to other Service users. Our Services also include tailored features that personalise your experience,
enhance your productivity and improve your learning by providing activity feeds, notifications, connections and recommendations that
are most relevant for you and your team. We may use your email domain to infer your affiliation with a particular organisation or
industry to personalize the content and experience you receive on our websites.
For research and development:
We are always looking for ways to make our Services smarter, faster, secure, integrated and useful to you. We use collective
learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage,
activity patterns and areas for integration and improvement of the Services. We also test and analyse certain new features with some
users before rolling the feature out to all users.
To communicate with you about the Services:
We may use your contact information to send transactional communications via email and within the Services, including confirming
your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer
support, and sending you technical notices, updates, security alerts, and administrative messages.
To market, promote, and drive engagement with the Services:
We may use your contact information and information about how you use the Services to send promotional communications that may be of
specific interest to you, including by email and by displaying Kinteract ads on other companies' websites and applications, as well
as on platforms like Facebook and Google. These communications are aimed at driving engagement and maximising what you get out of
the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you.
We may also communicate with you about new product offers, promotions and contests. You can control whether you receive these
communications as described below under "Opt-out of communications."
We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyse crash
information, and to repair and improve the Services.
For safety and security:
We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and
to identify violations of Service policies.
To protect our legitimate business interests and legal rights:
Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use
information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection
with the acquisition, merger or sale of a business.
With your consent:
We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may
publish testimonials or featured customer stories to promote the Services, with your permission.
Legal bases for processing (for EEA users):
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal
bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we
collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalised features
and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and
development, to market and promote the Services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time,
but this will not affect any processing that has already taken place. Where we are using your information because we or a third party
(e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may
mean no longer using the Services.
How we share information we collect
We provide a digital portfolio and assessment platform and we want this to work well for you. This means sharing information through
the Services and with certain third parties. We may share information we collect about you in the ways discussed below but you can be
rest assured that we are not in the business of selling information about you to advertisers or other third parties.
Sharing with other Service users
When you use the Services, we share certain information about you with other Service users.
You can create content, which may contain information about you, and grant permission to others to see, share, edit, copy and
download that content based on settings you or your administrator (if applicable) select. Some of the collaboration features of the
Services display some or all of your profile information to other Service users when you share or interact with specific content.
Managed accounts and administrators:
If you register or access the Services using an email address with a domain that is owned by your employer or organisation, certain
information about you including your name, profile picture, contact info, content, and account use may become accessible to that
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customise, support and market our Services.
We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage,
virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information
about you. If a service provider needs to access information about you to perform services on our behalf, they do so under
instruction from us, including abiding by policies and procedures designed to protect your information.
You, your administrator or other Service users may choose to add new functionality or change the behaviour of the Services by
enabling third party integrations within the Services. Doing so may give third-party apps access to your account and information
about you like your name and email address, and any content you choose to use in connection with those apps. If you are an
administrator or contact listed on an account, we share your details with the third-party app provider upon installation.
your information. We encourage you to review the privacy policies of third parties before connecting to or using their applications
or services to learn more about their privacy and information handling practices. If you object to information about you being
shared with these third parties, please disable the app.
Links to Third-Party Sites:
The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use
of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
With your consent:
We share information about you with third parties when you give us consent to do so. For example, we often display personal
testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights:
In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably
necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national
security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our
products and services, (d) protect Kinteract, our customers or the public from harm or illegal activities, or (e) respond to an
emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily
injury of any person.
How we store and secure information we collect
Information storage and security
We use data hosting service providers in the United Kingdom to host the information we collect, and we use technical measures to
secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to
the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our
systems or otherwise in our care, is absolutely safe from intrusion by others. We will respond to requests about this within a
How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such
time, we will either delete or anonymise your information or, if this is not possible (for example, because the information has been
stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is
We retain your account information until you delete your account. We also retain some of your information as necessary to comply
with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to
develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate
information that directly identifies you, and we only use the information to uncover collective insights about the use of our
Services, not to specifically analyse personal characteristics about you.
Information you share on the Services:
If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow
your team members or other users to make full use of the Services. For example, we continue to display comments and content you
provided to cards or made assessments/reports.
If the Services are made available to you through an organisation (e.g., your employer or that your child attends that institution),
we retain your information as long as required by the administrator of your account. For more information, see "Managed accounts and
administrators" above and “Notice to End Users” below.
If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you
specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a
reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them
and any limitations. We will respond to requests about this within a reasonable timeframe.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes),
to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below,
we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and
using settings available within the Services or your account. Where the Services are administered for you by an administrator (see
"Notice to End Users" below), you may need to contact your administrator to assist with your requests first. For all other requests,
you may contact us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about
another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate
interests to keep. Where you have asked us to share data with third parties, you will need to contact those third-party service
providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right
to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Access and update your information:
Our Services and related documentation give you the ability to access and update certain information about you from within the
Service. For example, you can access your profile information from your account and search for content containing information about
you using key word searches in the Service. You can update your profile information within your profile settings and modify content
that contains information about you using the editing tools associated with that content.
Deactivate membership to an institution:
You or an administrator can deactivate your access to an account associated with an institution. If you can deactivate your own
access, that setting is available to you in your account settings. Otherwise, please contact your administrator. If you are an
administrator and are unable to deactivate an account through your administrator settings, please contact Kinteract support. Please
be aware that deactivating access does not delete your information from content associated with that account; your information
remains visible to other Service users based on your past participation within the Services. For more information on how to delete
your information, see below.
Delete your information:
Our Services and related documentation give you the ability to delete certain information about you from within the Service. For
example, you can remove content that contains information about you using the key word search and editing tools associated with that
content and you can remove certain profile information within your profile settings. Please note, however, that we may need to
retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
Request that we stop using your information:
In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't
have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or
you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent
to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing
that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting
us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay
or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information
until the request is honoured or the dispute is resolved, provided your administrator does not object (where applicable). If you
object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.
Opt out of post notifications:
You may opt out of receiving post notifications that are linked to you or in the case of a parent or carer a child under their care.
You can update notification preferences within your Profile settings in your Services account.
Opt out of communications:
You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your
notification preferences within your Service account settings menu, or by contacting us as provided below to have your contact
information removed from our promotional email list or registration database. Even after you opt out from receiving promotional
messages from us, you will continue to receive transactional messages from us regarding our Services.
Mobile Push Notifications:
You can use the settings on your mobile device to enable or turn off mobile push notifications from Kinteract.
Turn off Cookie Controls:
Relevant browser-based cookie controls are described in our
Send "Do Not Track" Signals:
Currently, various browsers offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a
signal to websites visited by the user about the user’s browser DNT preference setting. Kinteract does not track its users over time
and across third-party websites to provide behaviourally-targeted advertising and therefore does not respond to Do Not Track (DNT)
signals. For more information on “do not track” please visit
Data portability is the ability to obtain some of your information in a format you can move from one service provider to another
(for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of
your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your
basic account information and the information you create on the spaces under your sole control.
How we transfer information we collect internationally
International transfers of information we collect
We collect information globally and primarily store that information in the United Kingdom. We transfer, process and store your
information outside of your country of residence, to wherever we, Kinteract, or our third-party service providers operate for the
purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
Other important privacy information
Notice to End Users
Our products are intended for both personal use and use by organisations. Where the Services are made available to you through an
organisation (e.g., your employer or that your child attends that institution) that organisation is the administrator of the Services
and is responsible for the end-users and/or Service sites over which it has control. If this is the case, please direct your data
privacy questions to your administrator, as your use of the Services is subject to that organisation's policies. We are not
responsible for the privacy or security practices of an administrator's organisation, which may be different than this policy.
Even if the Services are not currently administered to you by an organisation, if you are a member of a team administered by an
organisation, or if you use an email address provided by an organisation (such as your work email address) to access the Services,
then the administrator of that team or the owner of the domain associated with your organisational email address (e.g. your employer)
may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens.
Administrators are able to restrict your access to and privileges within your account. In some cases, enterprise administrators can
- require you to reset your account password;
- restrict, suspend or terminate your access to the Services or your account;
- control your ability to edit, restrict, modify or delete account information;
- change your account information, including profile information or the email address associated with your account;
- access information in and about your account;
- access or retain information stored as part of your account; and
- enable or disable third-party apps, or other integrations.
If you do not want an administrator to be able to assert control over your account or use of the Services, you should deactivate your
membership with the organisation or remove any email addresses containing a domain owned or controlled by the administrator entirely
from your account. Once an administrator asserts control over your account or use of the Services, you may no longer be able to
withdraw membership or change the email address associated with your account without administrator approval.
Please contact your organisation or refer to your administrator’s organisational policies for more information.
Our policy towards children
Kinteract is designed for students to take ownership of their digital portfolio and facilitate student directed learning. We expect
that any use by students, specifically those under the age of 13, will only be done with the guidance, supervision and consent of
their parents, carers and or authorised institution officials. Kinteract relies on parents and carers to ensure that minors only use
Kinteract if they can they understand their rights and responsibilities as laid out in our
Terms of Service
significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an
If you have questions or concerns about how your information is handled, please direct your inquiry to Make It Plain Ltd T.A as
Kinteract, as set forth below:
Make It Plain Ltd T/A Kinteract
Banbury, Oxfordshire, OX16 9PA