Privacy notice

Draft. This notice has not yet been reviewed by a qualified adviser. Text in square brackets will be completed before the website launches.

This notice explains how we use personal data when you visit this website or contact us, including when you ask about the Inclusion Studio pilot. It does not cover learner records in the Inclusion Studio service. The service is pre-pilot and holds no real learner data. When it does, the college or training provider will be the controller and will give learners its own privacy information. See data protection for how that will work.

Who is responsible for your data?

Tech Geek UK Ltd (“Inclusion Studio”, “we”, “us”), which operates Inclusion Studio, is the controller for the personal data described in this notice. We are a company registered in England and Wales with company number 09834597. Our registered office is Rourke House, Kingsbury Crescent, Watermans Business Park, Staines-upon-Thames, TW18 3BA. You can contact us about this notice or your data at hello@inclusionstudio.co.uk or through our contact page.

What personal data do we collect?

When you contact us or ask about the pilot. We collect what you choose to send: usually your name, email address, job title, organisation and the content of your message. If we talk by phone or video, we may keep brief notes of what was discussed. Please do not send us information about individual learners, health or disability details, or any other sensitive information. We do not need it to answer an enquiry.

When you visit this website. We do not use cookies, analytics or tracking. Our cookie policy explains this in more detail. Like any website, our hosting provider receives technical data when your browser requests a page, such as your IP address, browser type, the page requested and the time. Our hosting provider uses this to deliver the website and keep it secure. [Name of hosting provider and how long its logs are kept, to be confirmed.]

When you use our free tools. Our free tools run entirely in your browser. What you type is not sent to us or stored by us, and it is lost when you close or reload the page unless you copy or print it.

Why do we use your data, and on what lawful basis?

UK GDPR requires a lawful basis for each use of personal data.

Where we rely on legitimate interests, we have considered whether your interests and rights override ours. You can ask us for more detail, and you have the right to object.

Who do we share your data with?

We do not sell your data. We share it only with:

• service providers who help us run our business, such as our email and hosting providers, under contracts that require them to protect it. Today these are Vercel (website hosting) and Cloudflare (domain name service and forwarding of email sent to our address); the provider of the inbox that receives forwarded email will be added here;
• professional advisers, such as lawyers or accountants, where needed;
• law enforcement or regulators, where the law requires it.

Is your data transferred outside the UK?

Some of our service providers may process data outside the UK, for example in the United States. Where they do, we will make sure an appropriate safeguard is in place, such as UK adequacy regulations or the UK International Data Transfer Agreement or Addendum. [Details for each provider, to be confirmed.] You can ask us for more information.

How long do we keep your data?

We keep enquiry correspondence for [retention period] after our last contact, unless it becomes part of an agreement with your organisation, in which case we keep it for as long as needed for that agreement and any legal claims. If you asked for updates, we keep your details until you unsubscribe.

What are your rights?

You have the right to:

• ask for a copy of your personal data (right of access);
• ask us to correct inaccurate data;
• ask us to delete your data in some circumstances;
• ask us to restrict how we use your data in some circumstances;
• object to our use of your data where we rely on legitimate interests;
• withdraw consent at any time, where we rely on consent;
• in some circumstances, receive your data in a portable format.

These rights have conditions and exceptions. To use them, contact us. We will normally respond within one month. We do not make decisions about you using solely automated processing.

How do I complain?

Please tell us first, through our contact page. You have the right to complain to us about how we use your personal data, and we will acknowledge your complaint within 30 days and respond without undue delay.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection:

• website: ico.org.uk/make-a-complaint
• helpline: 0303 123 1113

Changes to this notice

We will update this notice when how we use personal data changes, for example before adding any analytics or before the pilot handles real data. The date at the top shows when it was last updated. Related policies: cookie policy, website terms.