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Schoolworks Student App
Effective date: 13 May 2025

1. Introduction
Schoolworks Ltd (“Schoolworks”, “we”, “us”, or “our”) operates the Schoolworks Student App (the “App”) as part of the schoolworks.io school management platform. We are a company registered in England and Wales.
This Privacy Policy explains how we collect, use, store, and share your personal data when you use the App, and describes your rights under applicable data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
The App is made available to students through their language school (our customer). In the context of data protection law, your school is the data controller and Schoolworks acts as a data processor on their behalf. This policy describes how Schoolworks handles your data within the platform.
Please read this policy carefully. If you have any questions, contact your school or reach us directly using the details in section 11.

2. Data We Collect
When you use the App, we may collect and process the following categories of personal data:
2.1 Identity and Contact Details
• Full name
• Email address
• Phone number (where provided)
• Date of birth (where required by your school)
• Nationality and country of origin (where required by your school)
2.2 Course and Enrolment Data
• Course name, type, level, and dates
• Class schedules and timetables
• Attendance records
• Academic progress notes and assessments (where recorded by your school)
• Enrolment status and booking history
2.3 Device and Technical Data
• Device type, operating system, and version
• Device identifier (e.g. advertising ID or device UUID)
• App version and session data
• Crash and error logs used to maintain and improve the App
2.4 Push Notification Preferences
• Whether you have opted in or out of push notifications
• Notification delivery status (sent, received, opened)

We do not use push notifications for marketing purposes. Notifications are used solely to deliver course-related information such as schedule changes, class reminders, and messages from your school.

3. How We Use Your Data
We process your personal data for the following purposes:
Providing the App: To authenticate your account and present your course, schedule, and school information within the App.
Push notifications: To send you relevant updates from your school, including timetable changes, reminders, and announcements.
App performance and support: To monitor the technical performance of the App, diagnose errors, and provide technical support.
Legal compliance: To comply with our obligations under applicable law and to respond to lawful requests from authorities.

4. Legal Basis for Processing
As a data processor, Schoolworks processes your data on behalf of your school (the data controller) under their documented instructions. The legal bases your school relies upon will typically include:
• Performance of a contract – to deliver the educational services you have enrolled in.
• Legitimate interests – for example, to maintain the security and functionality of the App.
• Consent – where you have opted in to push notifications.
For details of the specific legal bases your school relies upon, please refer to your school’s own privacy policy.

5. How We Share Your Data
We do not sell, rent, or trade your personal data. We may share data in the following limited circumstances:
5.1 Your School
Your personal data is managed and controlled by your language school. School administrators and authorised staff can access your data within the Schoolworks platform for the purposes of delivering your course.
5.2 Salesforce (Platform Infrastructure)
The Schoolworks platform is built on Salesforce infrastructure. Your data is stored within a Salesforce environment operated by Schoolworks. Salesforce acts as a sub-processor and is bound by appropriate data processing agreements.
5.3 Push Notification Services
To deliver push notifications, we use third-party notification services (such as Apple Push Notification Service (APNs) and Google Firebase Cloud Messaging (FCM)). These services receive device identifiers and notification content. They act as sub-processors and are governed by their own data processing terms.
5.4 Legal Obligations
We may disclose your data where required to do so by law, regulation, or court order, or to protect the rights and safety of Schoolworks, your school, or others.

6. International Data Transfers
Schoolworks is a UK-registered company and your data is primarily processed within the UK and European Economic Area (EEA). Where data is transferred outside these areas (for example, via infrastructure providers such as Salesforce or notification services), we ensure appropriate safeguards are in place, such as UK International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs).

7. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this policy, or as required by law. In practice, your data is retained in accordance with the data retention policy set by your school. When your school instructs us to delete your data, we will do so in accordance with our contractual obligations and secure deletion procedures.

8. Security
We take the security of your personal data seriously. Schoolworks implements appropriate technical and organisational measures to protect your data against unauthorised access, disclosure, alteration, or destruction. These measures include:
• Encrypted data transmission (TLS/HTTPS)
• Access controls limiting data access to authorised users and staff
• Regular security monitoring and logging
• Data processing agreements with all sub-processors

No system is completely secure. In the event of a data breach that is likely to affect your rights and freedoms, we will notify the relevant supervisory authority and, where required, affected individuals, in accordance with our legal obligations.

9. Children’s Data
The App may be used by students who are under 18 years of age. We recognise the importance of protecting children’s privacy. Where students are minors, we rely on the school to obtain any necessary consent from parents or guardians in accordance with applicable law. We do not knowingly collect data from children for our own purposes beyond what is necessary to deliver the App’s educational functionality.

10. Your Rights
Depending on your location and the legal basis for processing, you may have the following rights in relation to your personal data:
• Right of access – to request a copy of the data held about you.
• Right to rectification – to request correction of inaccurate or incomplete data.
• Right to erasure – to request deletion of your data in certain circumstances.
• Right to restriction – to request that we limit how we use your data.
• Right to data portability – to receive your data in a structured, machine-readable format.
• Right to object – to object to processing based on legitimate interests.
• Right to withdraw consent – where processing is based on consent (e.g. push notifications), you can withdraw at any time in the App’s notification settings.
Because Schoolworks acts as a data processor, many of these rights are best exercised directly with your school. Your school, as data controller, is responsible for responding to data subject requests. We will assist your school in fulfilling any such requests as required by law.
If you are located in the UK, you also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk.

11. Contact Us
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact:

Schoolworks Ltd
schoolworks.io
Email: privacy@schoolworks.io
If your query relates specifically to how your school manages your data, please contact your school directly.

12. Changes to This Policy
This Privacy Policy was last updated on 13 May 2025. We may update it from time to time to reflect changes in our practices, legal requirements, or the App’s functionality. We will notify you of significant changes via the App or by email. Continued use of the App after any changes constitutes acceptance of the updated policy.