KATIE COX DANCE STUDIO PRIVACY POLICY

This Privacy Policy outlines Dancekids trading as Katie Cox Dance Studio (the “School”) (" we ", " our " or " the Company ") practices with respect to information collected from users who access our website at www.katiecoxdancestudio.com (" Site "), or otherwise share personal information with us (collectively: " Users "). 

In order to carry out its ordinary duties to instructors, students and parents, the School needs to process a small range of personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter " Personal Information ") about individuals (including current, past and prospective instructors, students or parents) as part of its daily operation. Some of this activity, the School will need to carry out in order to fulfil its legal rights, duties or obligations – including those under a contract with its instructors, or parents of its students. Other uses of personal data will be made in accordance with the School’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.

The School expects that the following uses will fall within that category of its “legitimate interests”:

• To provide dance and performance arts education and artistic services,

• Maintaining relationships with alumni (see below) and the School community

• For the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as tax, diversity or gender pay gap analysis);

• To enable relevant authorities to monitor the School’s performance and to intervene or assist with incidents as appropriate;

• To give and receive information and references about past, current and prospective students, including relating to outstanding fees or payment history, to/from any educational institution that the student attended or where it is proposed they attend; and to provide references to potential employers of past students;

• To enable students to take part in examinations, and to publish the results of examinations or other achievements of students of the School;

• To safeguard students’ welfare

• To make use of photographic images of students in School publications, on the School website and (where appropriate) on the School’s social media channels

• To carry out or cooperate with any school or external complaints, disciplinary or investigation process; and

• Where otherwise reasonably necessary for the School’s purposes, including to obtain appropriate professional advice and insurance for the School.

In addition, the School will on occasion need to process special category personal data (concerning health, ethnicity, religion) or criminal records information (such as when carrying out DBS checks) in accordance with rights or duties imposed on it by law, including as regards to safeguarding and instructor agreements, or from time to time by explicit consent where required. These reasons will include:

• To safeguard students’ welfare and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual’s medical condition or other relevant information where it is in the individual’s interests to do so: for example, for medical advice, for social protection, safeguarding and cooperation with police or social services, or for insurance purposes;

• To provide educational services in the context of any special educational needs of a student;

• In connection with employment of its instructors

This privacy policy is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

When you use this Site and the associated online database systems, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information, Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
  
• Names, addresses, telephone numbers, e-mail addresses and other contact details;
• Past, present and prospective students’ attendance records, information about any special needs, and examination marks;
• Personnel files, for the use of safeguarding;
• Where appropriate, information about student and staff health, and contact details for their next of kin;
• References given or received by the School about students, and information provided by previous dance education establishments and/or other professionals or organisations working with students;
• Correspondence with and concerning instructors, pupils and parents past and present;
• Transaction and order details
• Demographic information
• Information relating to surveys and other feedback
  

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We may use the information for the following:

• Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
• To communicate with you and to keep you informed of our latest updates and services;
• To serve you advertisements when you use our Site (see more under "Advertisements"); 
• To market our websites and products (see more under "Marketing"); 
• Conducting statistical and analytical purposes, intended to improve the Site.
  

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

• Hosting and operating our Site;
• Providing you with our services, including providing a personalized display of our Site;
• Storing and processing such information on our behalf; 
• Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
• Providing you with marketing offers and promotional materials related to our Site and services; 
• Performing research, technical diagnostics or analytics;

 Occasionally, the School will need to share personal information relating to its community with third parties, such as professional advisers (lawyers, insurers, PR advisors and accountants), government authorities (HMRC, DfE, police or the local authority); and appropriate regulatory bodies (e.g. The Royal Academy of Dance, the Imperial Society of Teachers of Dancing, the Information Commissioner).

For the most part, personal data collected by the School will remain within the School and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis). Particularly strict rules of access apply in the context of medical records held and safeguarding files.

However, a certain amount of any SEN student’s relevant information will need to be provided to instructors more widely in the context of providing the necessary care and dance education that the student requires.

Instructors, students and parents are reminded that the School is under duties imposed by law and statutory guidance (including Keeping Children Safe in Education) to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This is likely to include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities such as the local authority or police.

Finally, in accordance with Data Protection Law, some of the School’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the School’s specific directions.

Individuals have various rights under Data Protection Law to access and understand personal data about them held by the School, and in some cases, ask for it to be erased or amended or have it transferred to others, or for the School to stop processing it.

The School will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, the School may ask you to reconsider or require a proportionate fee, but only where Data Protection Law allows it.

You should be aware that certain data is exempt from the right of access. This may include information which identifies other individuals, or information which is subject to legal professional privilege by the School for the purposes of the education, training or employment of any individual.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below:

katie@katiecoxdancestudio.com

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals (and parents need to be aware this may include their own children, in certain limited situations – please see further below), or information which is subject to legal professional privilege (for example legal advice given to or sought by the school, or documents prepared in connection with a legal action).



You may have heard of the “right to be forgotten”. However, we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your (or your child’s) personal data: for example, legal requirement, or where it falls within a legitimate interest identified in this Privacy Policy. All such requests will be considered on their own merits.

It should be clearly understood that the rules on subject access are not the sole basis on which information requests are handled. Parents may not have a statutory right to information, but they and others will often have a legitimate interest or expectation in receiving certain information about pupils without their consent. The school may consider there are lawful grounds for sharing with or without reference to that student.

Parents will in general receive verbal updates about their children when requested. Where parents are separated, the school will, in most cases, aim to provide the same information to each person with parental responsibility, but may need to factor in all the circumstances including the express wishes of the child.

All information requests from, or on behalf of, or concerning students – whether made under subject access or simply as an incidental request – will therefore be considered on a case by case basis.

Where the School is relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations as above). Please be aware however that the School may have another lawful reason to process the personal data in question even without your consent.

That reason will usually have been asserted under this Privacy Policy, or may otherwise exist under some form of contract or agreement with the individual (eg an employment or parent contract, or because a purchase of goods, services or membership of an organisation such as a parents’ association has been requested).

The rights under Data Protection Law belong to the individual to whom the data relates. However, the School will often rely on parental authority or notice for the necessary ways it processes personal data relating to students.

Where consent is required, it may in some cases be necessary or appropriate – given the nature of the processing in question, and the student’s age and understanding, to seek the student’s consent.

Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents’ rights at law or under their contract, and all the circumstances. In general, the School will assume that students’ consent is not required for ordinary disclosure of their personal data to their parents, eg for the purposes of keeping parents informed about the student’s activities, progress and behaviour, and in the interests of the student’s welfare. That is unless, in the School’s opinion, there is a good reason to do otherwise.

However, where a student seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, the School may be under an obligation to maintain confidentiality unless, in the School’s opinion, there is a good reason to do otherwise; for example where the School believes disclosure will be in the best interests of the student or other students, or if required by law.

Students are required to respect the personal data and privacy of others. Instructors are under professional duties to do the same.

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google AnalyticsTerms of Use and the Google Privacy Policy .

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy . Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site or those of our partners or suppliers, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you. 

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at katie@katiecoxdancestudio.com

Dancekids trading as Katie Cox Dance Studio (the “School”) acts as the Data Controller for the purpose of Data Protection Law.

Registered Address: 73 Park Lane, Croydon, CR0 1JG

Company Number: 06577124 



Last Modified 9th October 2020