ALADDIN PRIVACY POLICY

(last updated on 29th March 2023, view previous version here.)

  1. INTRODUCTION/WHO ARE WE?
  2. WHO DOES THIS POLICY APPLY TO?
  3. WHAT INFORMATION DO WE COLLECT?
  4. WHAT DO WE DO WITH YOUR PERSONAL DATA?
  5. DISCLOSURE OF YOUR PERSONAL DATA
  6. SAFE-GUARDING YOUR PERSONAL DATA
  7. HOW WE PROTECT YOUR PERSONAL DATA
  8. COOKIES
  9. THIRD PARTY WEBSITES
  10. YOUR RIGHTS
  11. ACCESS TO INFORMATION
  12. RETENTION OF INFORMATION
  13. AMENDMENTS TO POLICY
  14. HOW TO CONTACT US

1. INTRODUCTION/WHO ARE WE?

Any reference to "We", "Us" and "Our" is to Cloudware Limited t/a Aladdin Schools, incorporated and registered in Ireland with company number 476869 and our registered office at First Floor, Block 1, Deansgrange Business Park, Co. Dublin, Ireland and which terms also includes Our affiliates and subsidiaries, Our ultimate holding company and its subsidiaries, as defined in the Companies Act (Ireland) 2014 (the “Group”). We are a cloud based service provider which provides services to primary schools in Ireland (the “Schools”) in the ed-tech sector (the “Business”).

Your privacy is of paramount importance to us. This Privacy Policy (the “Policy”) (together with Our terms of use available at https://www.aladdin.ie/content/terms (the “Terms of Use”)) applies to the Business and the https://www.aladdin.ie/ website (“Our Site”), applications and services related thereto (our “Services”). This Policy sets out the basis on which any Personal Data We collect from You, or that You provide to Us, will be processed by Us. Please read the following carefully to understand Our practices regarding the Personal Data We collect and how We will treat it. Your use of Our Site is subject to Your agreement with this Policy.

Please read the following carefully. Registering for an account on Our Site or any mobile application, use of Your account, Our Site or any mobile application or otherwise accepting the terms of this Policy indicates that You have reviewed this Policy and have agreed to be bound by it. If You do not agree to these terms, You must leave Our Site and cease to use any mobile application immediately.

We will handle Your Personal Data in accordance with Data Protection Laws. Data Protection Laws means the Data Protection Acts 1988 to 2018, the General Data Protection Regulation (EU) 2016/679 (GDPR), and any other applicable law or regulation relating to the processing of Personal Data and to privacy, including the E-Privacy Directive 2002/58/EC and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011, as such legislation shall be supplemented, amended, revised or replaced from time to time and all guidance and codes of practice issued by a relevant supervisory authority, from time to time and which are applicable to Us.

In this Policy, the term “Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes Personal Data as described in Data Protection Laws.

For the purposes of Data Protection Laws, in providing Our Services, We act as a data processor which processes information on behalf of the Schools, who are the data controllers for the purposes of such Data Protection Laws. The School allows Us to process Your Personal Data in connection with the School’s use of Our Services. It is the responsibility of the School to determine how Your Personal Data is processed by Us and We will follow the School’s instructions at all times. You should refer to the Privacy Policy of the School for further information, as the School determines the purpose for which Your Personal Data will be processed in connection with Our Services in its role as controller.

You may be a data subject (as defined in Data Protection Laws) or You may be a controller. When You are a controller in respect of the Personal Data of other data subjects, then You must comply with all of your controller obligations under Data Protection Laws. We do not knowingly provide Our Services to people under the age of 18. If you are aged under 18, please get your parent/guardian’s permission before you provide Your Personal Data to us/use Our Services.

We may update this Policy from time to time and will post the updated Policy on Our Site so it might be a good idea to come back and read through it again, from time to time.

2. WHO DOES THIS POLICY APPLY TO?

This Policy applies to any person whose information We process on behalf of the School and who would be considered a data subject for the purposes of the Act. References to “You” and “Your” shall include School staff (both current and past), School pupils (both current and past) and their family, applicants for placement at the School and parents/guardians of children.

3. WHAT INFORMATION DO WE COLLECT?

The information that We collect about You includes:

  1. GENERAL DATA – This is information that You may give Us or the School by correspondence by phone, e-mail or otherwise. This includes information You provide when You use Our Site, Our Services and any mobile applications and when You report a problem or receive support services in connection with Our Site and/or Our Services or any mobile applications. The information You give Us may include but is not limited to the following information that We process on behalf of Schools:
    • Your name, address, email address and phone number;
    • information relating to staff and teachers who use Our Site and/or Our Services including (but not limited to) their name, address, email address and phone number;
    • information relating to children who are connected with or attend the School, including (but not limited to), name, address, contact information (including emergency contacts), date of birth, ethnic origin, religion, nationality, photographs, medical information, family history, performance, evaluation, punctuality and attendance information; and
    • information relating to parents or guardians of those children including (but not limited to) their name, address, contact information, and ethnic origin.
  2. TECHNICAL DATA - We may collect the following technical information on behalf of Schools:
    • technical information, including the Internet protocol (IP) address used to connect Your device to the Internet, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
    • information about Your visit to Our Site or use of Our Services, including the full Uniform Resource Locators (URL) clickstream to, through and from Our Site and Our Services (including date and time log); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Our customer service number.

4. WHAT DO WE DO WITH YOUR PERSONAL DATA?

We may use the information collected in the following ways:

  1. GENERAL DATA - We will use this information on behalf of the School to:
    • carry out Our obligations arising from any contracts entered into between Us and the School, including the Terms of Use, and to provide Our Services including all products and services requested from Us;
    • send communications to You about Our Site and/or Our Services including by SMS and push notification. We cannot guarantee that You will receive all communications from Us and We shall not be liable in the event that You do not receive such communications. You can opt out of receiving such communications by contacting us using the details below;
    • make notifications about changes to Our Services; and
    • ensure that content from Our Site is presented in the most effective manner.
  2. If any sensitive Personal Data is collected (i.e. data relating to racial or ethnic origin, political or religious opinions, membership of a trade union, physical or mental health or condition or sexual life, the commission of any offence or related documentation) then You consent to Our processing this data in the manner set out in this Policy for and on behalf of the School. We do not control nor do We have any input into the content and information submitted to Our Site and Our Services, the School is responsible for ensuring that all appropriate consents or other lawful basis of processing are in place to allow Us to process the information on the Schools behalf.
    TECHNICAL DATA - We will use this information on behalf of the School to:
    • administer Our Site and Our Services and for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • provide information to Schools;
    • improve Our Site and Our Services and to ensure that content is presented in the most effective manner for You and for Your device;
    • allow You to participate in the interactive features of Our Service, when You choose to do so; and
    • as part of Our efforts to keep Our Services and Our Site safe and secure.

5. DISCLOSURE OF YOUR PERSONAL DATA

We may share Your Personal Data with any member of Our Group. We will take every care to protect Your Personal Data and use it in accordance with the Schools instructions. We endeavour to keep Your Personal Data up to date. As such, it is your responsibility to inform the School of any changes to Your Personal Data that You are aware of as soon as possible. In certain circumstances, We may disclose Your Personal Data to certain third parties as follows:

  • the School;
  • business partners and sub-contractors for the performance of any contract We enter into with them in connection with Our Site and Our Services including; payment processors, approved API integrators, 3rd party provider for remote access and hosting service providers;
  • at the Schools request, We may disclose the information or receive information about You with government departments including with respect to the Primary Online Database run by the Department of Education and Skills;
  • We may disclose the information relevant to any backup or hosting services to Google Inc. You can read more about the measures taken by Google to protect the security of their services and the information at: https://cloud.google.com/security/compliance.
  • analytics (Fathom Analytics) and search engine providers that assist Us in the improvement and optimisation of Our Site. This consists of aggregated anonymous information only and relates to the web pages visited on Our Site and not the information included on those web pages;
  • to prospective purchasers, investors, advisers and other parties, if We or substantially all of Our assets are acquired by or merged with a third party, in which case Personal Data held by Us may be one of the transferred assets;
  • if We are under a duty to disclose or share Your Personal Data in order to comply with any legal or regulatory obligation, or in order to enforce or apply the Terms of Use and other agreements or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding in Ireland or abroad; and/or
  • to protect Our rights, property, or safety, or that of the School, You or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

6. SAFE GUARDING YOUR PERSONAL DATA

The information processed by Us, on behalf of the School, may be transferred to, and stored at Our hosting centres in the European Union. By submitting Your Personal Data, You and the School agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that the information is treated securely, in compliance with the instructions of the School and in accordance with this Policy and the relevant law. In particular, We have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information We manage on behalf of Schools and the information We collect and manage on their behalf.

Aladdin uses Google Inc as its Third-Party Sub-Processor, which stores School Data in Google data centres in the EU using the Google hosting service. Under the EU Regulation 679/2016 (the GDPR) and the Data Protection Act 2018, Schools remain the data controllers of the School Data and Aladdin and Google act as data processors and sub-processors respectively, on your behalf. For further information on the Google hosting services please go to https://cloud.google.com/terms/ or such other address notified by Google from time to time. The Google hosting service provides state of the art security, reliability, scalability and performance.

Aladdin Schools has and maintains in place technical and organisational measures to ensure that all data processed as part of the Service is kept secure and confidential. In particular, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we manage on behalf of our customers and the information we collect and manage. To protect the privacy and security of Our Services, We also take reasonable steps to verify Your identity before granting access to information. We also use secure connections to protect sensitive information during its transmission. Where You have been given (or where You have chosen) a password which enables You to access Our Services, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone.

You should be aware that when You disclose personal information that information is available to the School and may be used by the School. Schools are solely responsible for the uses made of Your Personal Data in their role as controllers and We have no responsibility for the actions of the Schools in this regard. Schools are responsible for ensuring that they have a lawful basis for processing Your Personal Data.

You should contact the School in the event that Your Personal Data needs to be updated or changed, for example in the event that Your contact details have changed. We shall not be responsible for any failure of the School to contact You, including where You have not provided the correct contact details.

If You have provided information to the School You understand that We process that information as an agent of the School. We may hold a back-up copy of the information that You submit, but only on behalf of the School. If You wish to modify or otherwise deal with Your Personal Data submitted directly to Us then You should contact the School directly, as they have responsibility for that personal information. We will comply with the School’s instructions in respect of that personal information. If You wish to understand the School’s data protection or Privacy Policy with regards to the dealings that it has with Your Personal Data then You should contact the School directly to establish such terms.

7. HOW WE PROTECT YOUR PERSONAL DATA

We do our utmost to protect user privacy through the appropriate use of security technology. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Your Personal Data. In particular, we consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Your Personal Data transmitted, stored or otherwise processed.

We restrict access to Your Personal Data to employees, contractors and agents who need to know Your Personal Data in order to operate, develop or improve the Services. We ensure that we have appropriate physical and technological security measures to protect Your Personal Data; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Personal Data, we cannot guarantee the security of any data transmitted to us and any such transmission is at Your own risk.

Once we have received Your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that our Service may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of Your Personal Data arising from such risks.

8. COOKIES

Our Site only uses strictly necessary cookies when you sign in to the website.

9. THIRD PARTY WEBSITES

This Policy applies to websites, services and applications that are owned and operated by Us. We do not exercise control over the sites/applications that may be linked from the Service. These sites/applications have their own cookies and privacy practices, which are controlled by them. These other sites/applications may place their own cookies or other files on your computer, collect data or solicit personal information from You. You acknowledge that the Service may enable or assist You to access the website content of, correspond with, and purchase goods and services from, third parties via third-party websites and that You do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by You, with any such third party and the use by any such third-party of your Personal Data. We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the Service. We encourage You to carefully familiarize yourself with the terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

10. YOUR RIGHTS

As a data subject, You have a number of rights under Data Protection Laws which you are entitled to exercise with the Schools. You should refer to the Privacy Policy of the relevant School for further information in this regard. If you are not satisfied, you can complain to the Data Protection Commission (“DPC”) or exercise any of your other rights pursuant to Data Protection Laws. Information about how to do this is available on the DPC website at: https://www.dataprotection.ie.

11. ACCESS TO INFORMATION

Data Protection Laws give You the right to access information held about You by the School. Your right of access can be exercised in accordance with such Data Protection Laws. You should contact the School directly in connection with any such access request.

You have a right to have Your Personal Data rectified or erased free of charge if it is inaccurate or no longer required by Us or the School for the purpose for which it was collected. You can do this by contacting the School directly.

12. RETENTION OF INFORMATION

We will retain Your Personal Data for as long as We are directed by the School or for as long as We are required under relevant laws.

If You would like Us to delete Your Personal Data, please contact the School directly with Your request.

13. AMENDMENTS TO POLICY

We may change or update this Policy from time to time and at our sole discretion. The date of the most recent revisions will appear on the top of this Policy. If You do not agree to the Policy, please do not continue to use Our Services to submit Your Personal Data. If material changes are made to the Policy, we will notify You by placing a prominent notice on Our Site.

14. HOW TO CONTACT US

Please contact Us if You have any questions about this Policy or information We hold about You:

  • by email at: dpm@aladdin.ie
  • or write to Us at: DPM, Aladdin, Block 1, Deansgrange Business Park, Co. Dublin, Ireland.