Holmwood’s Privacy Policy

At Holmwood’s, we value and respect your privacy. That is why we handle your personal information with care. In this privacy policy document, we explain which types of information we gather and what we do to protect your information.

This privacy policy applies to the use of the website https://learning.holmwoods.eu and the online learning environment and teacher area. This privacy policy is valid from 19/06/2018. When a new version is published, all previous versions will become invalid.

Types of information we gather

Personal details

Students

Contact details

• First name or initials
• Last name or first letter of last name
• Email address (it is possible to use fake email addresses)
• Optional: student number

Progress

• Progress in course and results
• Grouping in classes or virtual classes
• ECK-ID, if applicable

Teachers and school admins

Contact details

• First name or initials
• Last name or first letter of last name
• Email address (it is possible to use fake email addresses)

• Optional: gender (for personalization of emails)

Progress

• Assignment to classes

Individual users

Contact details

• First name or initials
• Last name or first letter of last name
• Email address

Progress

• Progress in course and results

Contact form

When you use the contact form on this website, the information you fill in will be submitted to our customer service department. This information will be treated confidentially. All employees who handle personal details have signed a confidentiality agreement.

Screenshot functionality

If you use the screenshot functionality in the learning environment, personal information might be visible. This information will be treated confidentially. In the screenshot functionality, you can render personal information invisible.

Google Analytics

We use Google Analytics to improve our website. Your information is never shared with Google. Your IP address is anonimized. The information we obtain from you as a user cannot be traced back to your personal details.

Payment information

Payments are processed by a trusted third party. We do not gather credit card details.

Access to personal details

The following groups of employees have access to personal details:

• Sales & Support employees: for giving support to schools and users
• Development team: for website and database maintenance

All employees who handle personal details have signed a confidentiality agreement.

Data storage and processing

Information is stored in databases in the Netherlands and Ireland. Information processing takes place in the Netherlands.

Third parties

Holmwood’s uses services from the following third parties:

• Holmwood’s Online Learning Ltd, London.
• Microsoft Corporation, Washington, specifically Azure, for storage and processing of data. Storage and procession takes place in the Netherlands and Ireland.
• Google LLC, California, specifically Google Apps for Business for email and data storage, and Analytics with anonimized IP address for website usage analysis (not on personal level). Data is processed outside the EEA, under Privacy Shield certification.
• The Rocket Science Group LLC d/b/a MailChimp, Georgia, to inform teachers of important developments within the learning environment. We use the following details: name, email address and gender. Data is processed outside the EEA, under Privacy Shield certification.
• SendGrid Inc, Colorado, to send automated emails (e.g. password reset links and progress reports). Data is processed in the USA, under Privacy Shield certification.

Data retention

Data in learning environment

Individuals: until 2 months after subscription expiry date

Students, teachers and school admins: until 7 months after subscription expiry date

Customer details

Customer details are kept until a request for deletion is received.

Delete account (individual users)

Individual users can delete their own account using the link “Delete account” on the page https://learning.holmwoods.eu/Account.

Request deletion

Schools can submit a deletion request when they want data to be deleted before the legal deletion date. Deletion requests can be submitted to support@holmwoods.eu or through the contact form on the website.

 

Version 1.0 - 19/06/2018