Privacy Policy

1. Introduction: 

1.1 At Educe Trading Ltd (“The PE Hub” or “us” or “we” or “our”), a UK registered company  with company number 08918344 and registered address of Grosvenor House, 11 St. Paul’s Square, Birmingham, England, B3 1RB, we respect the privacy rights of our online visitors and users of our website (“Site”) (https://classic.thepehub.co.uk/) and our Learning Management System (“LMS”) [https://thepehub.co.uk/]. We recognise the importance of protecting the information we collect about you. This Policy is designed to help you understand how we collect, hold, use, disclose and delete personally identifiable information (“personal data”) about you.

1.2 This Policy, together with our Terms and Conditions and any other documents referred to in it, sets out the basis on which we will process any personal data we collect from you, or which you provide to us, in the course of using our Site and/or our LMS.

1.3 For the purpose of the UK Data Protection Act 2018 (“DPA’18”) and the UK General Data Protection Regulation (“UK GDPR”), we are both a processor where we are processing personal data on behalf of our users, and a controller where we are onboarding users and collecting personal data for marketing purposes. We can be contacted at the following email address info@thepehub.co.uk.

2.Users of our Site and LMS

2.1 Our Site and LMS are designed to be used by our users to aid them in lesson planning by providing resources and tools in line with the national curriculum. The following terms are used throughout this policy to describe the different types of users:

  • Organisation – an Organisation is a school, academy or coaching company that has signed up to use the website or LMS.
  • User – a User is a direct user of the website or LMS. This includes teachers and other staff members of the Organisation.

2.2 The personal data of data subjects (both students and teachers) will be used for the purposes of creating profiles and records. In most instances, this personal data is not collected directly from the data subjects themselves, and therefore it is the responsibility of the organisation, to ensure that the individual data subjects have access to this Policy to ensure they understand how their personal data is collected, processed, stored, disclosed and deleted, as well as understanding how they can exercise their individual data subject rights.

2.3 For the purposes of this Policy, “Data Subjects” are defined as those whose personal data is inputted into The PE Hub system by users, including both pupils and teachers.

3.Your information:

 3.1 The personal data of users of our Site and/or LMS is processed under the UK GDPR and DPA’18.

3.2 The personal data relating to pupils and teachers is processed on the lawful basis of legitimate business interest for the purposes of providing lesson plans and resources for both teachers and students.

3.3 All other personal data collected, including commercial data relating to users who visit our Site or make an enquiry by filling in a contact form, is processed on the lawful basis of legitimate business interest to facilitate sales and marketing information relating to the provision of our services.

3.4 The provision of personal data is necessary in order to facilitate the provision of the service.

4.Information that may be collected:

4.1 The following personal data may be collected from you as a user of our Site and/or LMS, when you either 1) fill in our contact form, 2) create an account, 3) login to an existing account, or 4) interact with The PE Hub:

  1. Your full name;
  2. Your email address;
  3. Service name or name of institution;
  4. Your full address or the full address of the service or institution;
  5. Your contact number;
  6. Any evidence submitted, including but not limited to pictures, video recordings and audio recordings etc.; and
  7. Your payment information, including your account number, sort code, CVC number and expiry date.

4.2 During the course of using our Site and/or LMS other personal data may be collected from you as a user. The personal data that may be collected includes:

  1. Your Internet Protocol (“IP”) address;
  2. Any referring or exit pages taking you to or from our Site;
  3. Your web and browser type;
  4. Your device type, for example, iOS or Android;
  5. Your time zone and location;
  6. Date and time stamps;
  7. Any browser plug-ins; and
  8. Your operating system.

4.3 The following information is collected about pupils whose personal data is provided by the Organisation during the course of using our Site and/or LMS:

  1. Full name; and
  2. DOB

4.4 The following information is collected about teachers and employees whose personal data is provided by the Organisation during the course of using our Site and/or LMS:

  1. Full name;
  2. Organisation email address;
  3. Phone number; and
  4. Photo/image for an LMS avatar (optional).

5.Special category personal data:

5.1 During the course of using our Site and/or LMS, we may disclose special category personal data relating to Data Subjects including, but not limited to, racial and ethnic origin, religious or philosophical beliefs and health or sexual orientation. Whilst we do not encourage the disclosure of such data, we recognise that the processing of such data may be necessary as part of the pupil and teacher profiles created by the Organisation and their associated users.

5.2 The PE Hub and the Organisation shall ensure that additional safeguards are in place to protect such data.

6.How your personal data may be used:

6.1 The personal data we collect about you during the course of your use of our Site and/or LMS may be used in a number of ways including, but not limited to, the following:

  1. To respond to any enquiries made through our contact form;
  2. To provide any resources or services requested;
  3. To fulfil our obligations under any contract we have with the users of our Site and/or LMS;
  4. To collect payment for our services;
  5. To provide you with updates regarding our Site and/or LMS;
  6. To ensure that the content on our Site and/or LMS is presented in the most optimised and effective manner for you and your device;
  7. To diagnose and fix technology problems;
  8. To control unauthorised use or abuse of our Site and/or LMS, or otherwise detect, investigate or prevent activities that may violate our policies or are otherwise illegal;
  9. To carry out our obligations arising from the interactive features of our software, when you choose to do so;
  10. To notify you about changes to our software, our services or our policies;
  11. To deliver support where necessary;
  12. To administer our Site and/or LMS, including data analysis, testing, traffic monitoring, research, statistical and survey purposes;
  13. To send you newsletters and other marketing information from time to time;
  14. To keep you up to date with our services; and
  15. To provide you with information regarding our Site and/or LMS that you request, or we feel may interest you.

6.2 If you do not wish to be contacted for marketing purposes, please tick any relevant box on which you submit your personal data or unsubscribe from any marketing communication using the unsubscribe function in the footer of the email.

7.Where your personal data may be stored:

7.1 The personal data you provide to us through our Site will be stored on our UK-based secure servers, which are encrypted using SSL encryption to 256 bits. Our backup AWS servers are also located in the UK.

7.2 The personal data you provide to us through our LMS will be stored on our UK based AWS servers, which are encrypted using TLS 1.2 bits.

7.3 We take your privacy seriously and will take all reasonable steps to protect your personal data. However, please beware that any data that you send to us via our Site and/or LMS is sent at your own risk.

7.4 In order to provide services to you, we may transfer your personal data to third parties, parent companies, affiliates, subsidiaries and other service providers, some of which may process and/or store your personal data outside of the European Economic Area (“EEA”). In such instances, all reasonable steps will be taken to ensure that your personal data is treated securely and in accordance with this Policy (where possible). Any data transfers that take place outside of the EEA will be covered by appropriate safeguards, for example, Standard Contractual Clauses (“SCCs”) and Data Transfer Agreements (“DTAs”) or the relevant UK adequacy decision.

8.How your personal data may be disclosed:

8.1 In accordance with clause 7.4 above, the third parties to whom your personal data may be disclosed include, but are not limited to:

  1. Auth0 – https://auth0.com/
  2. Eject – https://eject.tech/privacy/
  3. WooCommerce – https://automattic.com/privacy/
  4. PipeDrive – https://www.pipedrive.com/en/privacy
  5. Microsoft 365 – https://privacy.microsoft.com/en-gb/privacystatement
  6. QuickBooks – https://www.intuit.com/privacy/statement/
  7. PlanetScale – https://planetscale.com/legal/privacy
  8. AWS – https://aws.amazon.com/privacy/?nc1=f_pr
  9. PayPal – https://www.paypal.com/myaccount/privacy/privacyhub

9.Additional information regarding the storage of your personal data:

9.1 The PE Hub acts as a Data Processor on behalf of its users. The PE Hub is consequently processing personal data under instructions from the Organisations that are defined as Data Controllers under DPA’18. As Data Controllers, Organisations are responsible for collecting the personal data of individual data subjects and making decisions with regards to the retention, transmission, processing, review and deletion of that personal data. Consequently, Organisations as Data Controllers remain responsible for the personal data that they collect and provide to The PE Hub for processing. Each Organisation is its own unique institution and should be aware of any specific data retention legislation that applies to it regarding the ongoing retention of the personal data of their data subjects.

9.2 The PE Hub’s general data retention period is outlined at 9.6 below. However, The PE Hub’s users will be aware of the data retention legislation applicable to their organisation. Please contact any such organisation for more information on this.

9.3 We hold your personal data in a combination of hard copy and electronic files for the period necessary to support our Site and/or LMS, comply with our legal obligations, resolve disputes, or otherwise fulfil the purposes outlined in this Policy.

9.4 In order to provide our services, we may use third-party systems that may process, store and/or have access to your personal data. These third parties will act as data processors on our behalf and will operate in line with this Policy where possible.

9.5 We may also retain backup information on our servers for some time in order to comply with applicable laws and regulations, and our internal security policies and procedures. Where applicable, we do not always remove or delete all of your personal data for a number of reasons, including due to technical and system constraints, contractual requirements or legal requirements.

9.6 In line with our internal procedures and applicable laws and regulations, we operate the following data retention periods:

  1. Data such as usernames and passwords, contact information, and other personal data that is collected from a user through the general use of our Site or LMS will be retained for 7 years from the last date of interaction.
  2. Any profile data added to the LMS by an Organisation cannot be accessed by The PE Hub. Any profile data uploaded will be subject to the internal data retention period of the Organisation using the LMS.

9.7 At the end of the above data retention periods, all of the data stored, including personal data, will be reviewed and securely deleted/destroyed.

9.8 Please note that no method of transmission over the internet, method of electronic storage or other security methods are 100% secure. Therefore, while we strive to use commercially acceptable means of security, such as firewalls, encrypted databases with limited physical and electronic access, and other encryption methods, to protect your personal data against unauthorised use, disclosure or modification, we cannot guarantee its absolute security.

10.Processing of personal data of those below the age of 13:

10.1 As described above in section 2 of this Policy, our Site and LMS is designed to be used by companies and local authorities that operate within the education, health and social care sectors. Due to this, some of the users of our system, may input the personal data of Data Subjects who are defined as children under the DPA’18 and are therefore below the age of 13. This personal data is processed on the lawful basis of contract.

10.2 Please note that all of the personal data that is collected and processed through our Site and/or LMS is treated with a high standard of care. This applies whether the personal data relates to a child under the age of 13 or any individual above the age of 13.

11.Data subject rights:

11.1 Subject access request – Under the DPA’18 you have the right to access the personal data we hold about you. If you wish to exercise this right, please send your request to  info@thepehub.co.uk.

11.2 Right to rectification – Under the DPA’18 you have the right to request the amendment or updating of all the personal data that we hold about you. If you wish to exercise this right, please send your request to  info@thepehub.co.uk.

11.3 Right to erasure – Under the DPA’18 you have the right to have all of the personal data that we hold about you deleted in line with our statutory and legal responsibilities. If you wish to exercise this right, please send your request to  info@thepehub.co.uk.

11.4 Right to restriction of processing – Under the DPA’18, and in line with Article 18 (1) (a) to (d) of the GDPR, you have the right to obtain from us the restriction of processing. If you wish to exercise this right, please send your request to  info@thepehub.co.uk.

11.5 Right to data portability – Under the DPA’18, where applicable, you may have the right to request a copy of all of the personal data we hold about you in a structured, commonly used and machine-readable format. If you wish to exercise this right, please send your request to  info@thepehub.co.uk.

12.Enforcement:

12.1 The PE Hub regularly reviews its compliance with relevant data protection laws and regulations, and this Policy.

12.2 Where applicable, we cooperate with the appropriate regulatory authorities, including data protection authorities, for example the UK Information Commissioners Office (“ICO”), to resolve any complaints regarding the collection, processing and disclosure of personal data that cannot be resolved between us and the individual.

13.Notices and provisions:

13.1 Please note that this Policy applies to The PE Hub Site and LMS only. If you, as a user of the Site and/or LMS, click on, or follow, any links from our Site or LMS to an external website or application, this Policy will no longer apply. Please ensure you check the privacy policies of any such external website or application before submitting any personal data, as we cannot accept any responsibility or liability in relation to such websites or applications.

13.2 We reserve the right to change this Policy at any time. These changes will take immediate effect unless you are notified otherwise. For this reason, we recommend that you refer to this Policy on an ongoing basis so that you understand our current practice at the time you use our service.

13.3 If you have a concern about this Policy or would like to know more about how your personal data is collected, processed, stored or disclosed, please contact us.

13.4 If you wish to contact us with a complaint regarding the processing of your personal data, please ensure you include your full name, contact information and a detailed description of your complaint.

13.5 If you are not satisfied with our response to any of your data subject rights or a complaint that you have made, you may also contact your local data protection authority to lodge a complaint.

14.Contact information:

14.1 If you have any questions regarding this Policy or want to exercise any of your data subject rights, please email us at info@thepehub.co.uk.

14.2 As outlined in the above section, should you not be satisfied with the process, conduct or response to a request you have made, you have the right to complain to the ICO. The contact information for the ICO can be found here: (https://ico.org.uk/make-a-complaint/).