Triple Three Holdings Limited trading as Summa Summarum Education (“Summa Summarum”)
Privacy Policy
Introduction
Welcome to Summa Summarum's privacy policy.
Summa Summarum respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or engage us to provide services and tell you about your privacy rights and how the law protects you.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Summa Summarum collects and processes:
(a) your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or purchase a product or service; and
(b) any personal data you may provide or which we collect as a result of you engaging us to provide tutoring and consultancy services.
Where you enquire about or engage us to provide tutoring and consultancy services, you may provide and we may collect personal data about the student(s) who receive (or may receive) tutoring or consultancy. Children’s personal data has special protections and this privacy policy sets out the basis on which we will process such data, where relevant.
Summa Summarum is the controller and responsible for your personal data (referred to as "Summa Summarum", "we", "us" or "our" in this privacy policy). Summa Summarum is a trading name of Triple Three Holdings Ltd, a UK limited company (company number: 10591334) with registered offices at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
Identity Data includes first name, last name, title and gender.
Contact Data includes billing address, address for delivery of services, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes purchases or orders made by you, your preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Student Data is data that is necessary to enable us to deliver tuition, including first name, last name, age, gender, school details, school year, educational needs and capabilities of any student who is the subject of your enquiry about our services or to whom we deliver tutoring (a “Student”).
Special Educational Needs Data includes any special educational needs relating to the Student.
Tuition Session Data is data contained in any video or telephone tuition session or in a tuition session delivered in writing, which may include the likeness or voice of any person participating in a tuition session and anything said or written during a tuition session by any person participating in a session.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Other than any Special Educational Needs Data, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial Data, Student Data, Special Educational Needs Data and Tuition Session Data by filling in forms or by corresponding with us by post, phone, email or otherwise or during the course of tutoring services we deliver. This includes personal data you provide when you:
apply for our products or services;
receive our products or services;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
The Student Data will normally be provided by the person with parental responsibility for the Student, but may also be provided by a Student in the course of tuition.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from analytics providers such as Google based outside the UK.
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
As Special Educational Needs Data may be categorised as Special Category Data (i.e. where it includes health information) we will only be able to process and store this data and use it to assist us in providing the service with the prior consent of whomever holds parental responsibility for the Student.
Purposes for which we will use your personal data
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer | (a) Identity | Performance of a contract with you |
| (b) Contact | ||
| (c) Student | ||
| (d) Special Educational Needs | ||
| To process and deliver services to you including: | (a) Identity | (a) Performance of a contract with you |
| (a) Manage payments, fees and charges | (b) Contact | (b) Necessary for our legitimate interests (to recover debts due to us) |
| (b) Collect and recover money owed to us | (c) Financial | (c) Consent in relation to Special Educational Needs |
| (c) Provide educational and consulting services | (d) Transaction | |
| (e) Marketing and Communications | ||
| (f) Student | ||
| (g) Special Educational Needs | ||
| (h) Tuition Session | ||
| To manage our relationship with you which will include: | (a) Identity | (a) Performance of a contract with you |
| (a) Notifying you about changes to our terms or privacy policy | (b) Contact | (b) Necessary to comply with a legal obligation |
| (b) Asking you to leave a review or take a survey | (c) Profile | (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| (d) Marketing and Communications | ||
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity | (a) Performance of a contract with you |
| (b) Contact | (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) | |
| (c) Profile | ||
| (d) Usage | ||
| (e) Marketing and Communications | ||
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| (b) Contact | (b) Necessary to comply with a legal obligation | |
| (c) Technical |
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| (b) Contact | ||
| (c) Profile | ||
| (d) Usage | ||
| (e) Marketing and Communications | ||
| (f) Technical | ||
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| (b) Usage | ||
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| (b) Contact | Consent in relation to Special Educational Needs | |
| (c) Technical | ||
| (d) Usage | ||
| (e) Profile | ||
| (f) Marketing and Communications | ||
| (g) Student | ||
| (h) Special Educational Needs |
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above, in section "Purposes for which we will use your personal data".
Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, auditors and insurers based in the U.K. who provide legal, insurance and accounting services.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to 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.
Some of our external third parties are based outside the UK so their processing of your personal data may involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
How long will you use my personal data for?
In some circumstances you can ask us to delete your data: see your legal rights section below for further information.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of these rights, please contact us.
Consent – where it is necessary for us to obtain your prior consent to the processing in order for us to be able to do it, we will obtain and rely on your consent. You are able to withdraw your consent at any time. For children, we rely on the consent of the person with parental responsibility.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Summa Summarum Education
