Kinteract Privacy Policy

The revised privacy policy will be effective starting on May 25, 2018

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:

This Privacy Policy covers the information we collect about you when you use our products or services, or otherwise interact with Kinteract (for example, attending Kinteract events), unless a different privacy policy is displayed. This policy also explains 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 business.

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.

The Service

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.

Institutional Sign Up

Specifically when an institution subscribes we store the following:

The institution may then store some or all of the following data on our Service

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 Services.

Information we receive from other sources

We receive information about you from other Service users and from select third party services,

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.

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.

Sharing with third parties

We share information with third parties that help us operate, provide, improve, integrate, customise, support and market our Services.

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 reasonable timeframe.

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 possible.

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.

Your Choices:

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.

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 also:

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 and in this Privacy Policy.

Changes to our Privacy Policy

We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

Contact Us

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: