Privacy Notice

This Privacy Notice tells you how we, Spottest, will collect and use your personal data to provide our service which allows educators, of any kind, to create a private space online, filled with tools that easily create courses and activities, all optimized for collaborative learning. This notice will tell you how Spottest uses your data.

Who are we?

Spottest is which allows educators, of any kind, to create a private space online, filled with tools that easily create courses and activities, all optimized for collaborative learning .

What’s covered by this Privacy Notice?

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

where Spottest is hosting a website on its own behalf, it is the Data Controller for all the data collected. Where Spottest is hosting someone else’s installation of the Spottest Platform (as with Spottest Cloud) it is the Data Processor for the site admin for that installation.
when Spottest is not hosting an installation of the software platform, it is neither the Data Controller nor the Data Processor and those duties fall on the people or organizations who have installed and are hosting those installations.

Why does Spottest need to collect and store personal data?

In order for Spottest to provide you with Spottest Cloud and other Spottest hosted services we need to collect personal data for correspondence purposes and/or to allow us to provide you our service(s). We are committed to ensuring that the information we collect and use is appropriate for this purpose. Spottest values its users’ data protection and privacy rights and we have no interest in collecting data beyond what we need to make our service(s) work for you.

If you are going to be contacted by us for marketing purposes, we will not rely solely on this notice, but will always seek an additional confirmation from you that it’s ok to do that.

In general we collect personal data relating to you for specific purposes, with the nature of the data collected depending on your interaction with Spottest. We are committed to transparency in this and have provided a very detailed breakdown of these processes in Annex 1 of this Privacy Notice.

Our legal basis for the processing of personal data are:

Article 6.1(a), GDPR, Consent
Article 6.1(b), GDPR, Contract
Article 6.1(f), GDPR, Legitimate Interest

Any legitimate interests pursued by us, or third parties we use, are as follows:

Emergency Contacts for people who work with us, such as employees and contractors for health and safety purposes.
Business Development
Providing login systems to users via their existing social media accounts

Will Spottest share my personal data with anyone else?

We Do not pass your personal data to any one else and will be that way until there is a need to engage with third-party service providers contracted to Spottest in the course of dealing with you. We might do this because there are some services, such as our video conferencing facility, which will not work unless we are able to make these transfers. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our- and of course, your-behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Spottest procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, or if it is necessary to comply with an employment contract, unless we are legally required to do otherwise. If you would like an up-to-date register of all our third-party service providers, please contact us and we will be happy to provide it.

How will Spottest use the personal data it collects about me?

Spottest will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Spottest maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed. Spottest is required to retain certain information in accordance with the Law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Can I find out the personal data that the organization holds about me?

Spottest at your request, can confirm what information we hold about you and how it is processed. If Spottest does hold personal data about you, you can request the following information:

Identity and the contact details of the person or organization that has determined how and why to process your data.
Contact details of our data protection officer in the EU, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of Spottest or a third party, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
If we intend to transfer the personal data to a third country or international organization, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority.
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

Agreeing to these terms is your Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for Spottest to process both standard and sensitive types of personal data, it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used. Agreement with this Privacy Notice and its accompanying terms and conditions (as applicable) (and any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.

You may withdraw consent at any time by:

contacting us.

Please identify your role in relation to Spottest (if you are a contractor, employee, Spottest partner, end-user, site admin etc.), and the data you wish to withdraw consent to be processed.

Retention period

Spottest will processes different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. For further details on the retention period for any particular type of data, please contact us.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

right of access – you have the right to request a copy of the information that we hold about you.
right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
right to object – you have the right to object to certain types of processing such as direct marketing.
right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
right to judicial review: in the event that Spottest refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the section named “Complaints” below.

Where Spottest are your Data Controller, you may make a request directly to the Data Protection Officer .

Where Spottest are a Data Processor, and act on behalf of a data controller (such as SpottestCloud) any requests received by Spottest will be passed on to the Data Controller.

Where Spottest are not involved with your data, such as where the Spottest platform has been self-hosted, you should address your requests to the data controllers of those sites. Spottest will have no access to your data.