Privacy Policy
Juniper Education Group (“Juniper“) takes your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
This privacy policy aims to give you information on how Juniper collects and processes your personal data, including any data you may provide through this website, by telephone, by email or by post when you enquire or purchase a product or service or use our applications.
If you are or have been a Juniper employee, contractor or have carried out work experience with Juniper please refer to the internal privacy policy for more information on how we use your data.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. It supplements other notices and documents and is not intended to override them.
We keep our privacy policy under regular review. This version was last updated on 6 June 2024.
1. WHO WE ARE
Juniper Education Group Limited is a private limited company registered in the UK.
When we talk about “Juniper” unless otherwise stated, we mean Juniper Education Group Limited and all its subsidiaries.
As our head office is in the United Kingdom, Juniper is regulated principally by the United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 and overseen by the UK Supervisory Authority, the Information Commissioner’s Office (ICO). Other UK laws inter-relate with the Act and the UK GDPR including but not limited to the Privacy and Electronic Communications Regulations (2003) (PECR) and the Freedom of Information Act (2000).
Juniper is also established in the European Economic Area (EEA) and is further regulated by the European General Data Protection Regulation (EU GDPR) and the Protection of Personal Data Act 2002 and overseen by the Bulgarian Supervisory Authority, the Commission for Personal Data Protection (CPDP).
Juniper is responsible as both a Data Controller and a Data Processor under the relevant data protection legislation.
Juniper as a Data Controller
Juniper is a Data Controller in relation to our employees’ personal data (including applicants, contractors, work experience and former employees), leads, prospects and customers, and in any other situation where we make decisions on processing personal data.
Juniper as a Data Processor
Juniper processes personal data to provide products and/or services under contract to customers (clients). In this situation, the customer is the Data Controller as they make the decisions on how the data will be processed, Juniper is the Data Processor.
2. WHAT PERSONAL DATA WE COLLECT ABOUT YOU
Personal Data is any piece of information or item that can be used to identify a living person.
We collect, use, store and transfer (“process”) many types of personal data which we have grouped together as follows:
- Identity Data may include first name, maiden name, last name, username or similar identifier, marital status, title, passport number, ID numbers/codes, date of birth and gender.
- Contact Data may include home address, billing address, delivery address, email address, telephone numbers.
- Financial Data may include bank account and payment card details.
- Transaction Data may include details about payments to and from you and details of products and services you have purchased from us, consents for trips and photos.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website and applications.
- Profile Data includes your username and password, pupil type, registration groups, year groups, class names, group names and IDs, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. If you have opted into receiving marketing communications from Juniper, you can unsubscribe at any time in the link provided in any email from us.
- Special category personal data includes racial or ethnic origin, safeguarding concerns, data regarding children, special educational needs, eligibility for free school meals, FSM Ever 6, political opinions, religious beliefs, philosophical beliefs or trade union membership, Genetic data, Biometric data (where used for identification purposes), data concerning health (including dietary needs and medical conditions), sex life or sexual orientation.
This data is required to enable us to carry out our duties as a Controller or provide products and services to you as a Processor. If we do not have all the personal data required, it may delay or prevent us from providing some services to you.
Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific service or website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data and process it in accordance with relevant laws and this privacy policy.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
- Direct interactions - You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email or face to face. This includes personal data you provide when you:
- apply for our services;
- create an account on our website;
- subscribe to our services or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions - As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
- Technical Data:
- analytics providers such as Google;
- advertising networks; and
- search engine/information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity, Contact and Transaction Data from local authorities, Consultants, trade unions, professional bodies or pension administrators and other professionals we may engage in relation to your matter.
- Identity and Contact Data from third parties or publicly available sources such as the Electoral Register or Department of Education databases based inside the UK.
- Identity and Contact Data from online marketing campaigns run on social media platforms such as LinkedIn.
4. WHAT WE USE YOUR PERSONAL DATA FOR
Our use of your personal data is subject to your and the Data Controller’s instructions, relevant data protection legislation and our professional duty of confidentiality.
We will only process your personal data if we have a proper and lawful reason for doing so for example:
- to comply with our legal and regulatory obligations;
- for the performance of a contract
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use personal data, so long as this is not overridden by your own rights, freedoms and interests.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to receiving marketing communications at any time by contacting us or clicking on the unsubscribe link in our marketing emails.
Purposes for which we will use your personal data
We have set out below a description of the ways we may use your personal data, and which of the legal bases we rely on to do so. We have identified what our legitimate interests are where applicable. Please note, we may process your personal data under more than one lawful basis.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer. | (a) Identity (b) Contact |
Performance of a Contract and Legitimate Interests:
|
| To process and deliver a service including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us. |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
Performance of a Contract and Legitimate Interests:
|
| To provide the necessary deliverables for a Service (Juniper product/software/ service) to you. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Special Category Data |
Performance of a Contract and Legitimate Interests:
|
|
To manage our relationship with you which will include: (b) Asking you to leave a review or take a survey. |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
Performance of a contract, comply with a Legal Obligation and Legitimate Interests;
|
| To enable you to partake in a prize draw, competition or complete a survey. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
Performance of a contract and Legitimate Interests
|
| To develop, administer and protect our business applications and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | (a) Identity (b) Contact (c) Technical |
Legitimate interests;
and in the context of a business reorganisation or group restructuring exercise necessary to comply with a Legal Obligation. |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Legitimate Interests:
|
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. | (a) Technical (b) Usage |
Legitimate Interests:
|
| To make suggestions and recommendations to you about goods or services that may be of interest to you. | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Legitimate Interests:
|
How and why we use special category personal data
Under data protection law, we will only process special category personal data where we have a lawful basis for doing so and at least one of the 10 conditions for processing special category applies.
We mainly process special category personal data under the condition “employment, social security or social protection”. Where “explicit consent” is used, the Data Controller will ensure they retain a record of consent.
There may be times where the condition “legal claims or judicial acts” applies for example in
- actual or prospective court proceedings;
- obtaining legal advice; or
- establishing, exercising or defending legal rights in any other way.
5. HOW LONG WE KEEP YOUR PERSONAL DATA
We only keep your data for as long as is necessary to carry out the original purpose we obtained it for.
If you’re a pupil, student, teacher, member of school/Trust staff or parent, this will usually be for the period we are providing products or services under contract to your school/MAT.
We are legally bound to hold onto some data for a defined period for example to comply with tax rules and other legal purposes.
6. WHO WE SHARE YOUR PERSONAL DATA WITH
We may share your personal data with the subsidiaries in the Juniper group and external third parties, including
- Service providers acting as processors for Juniper based in the UK/EU e.g. companies who provide IT and system administration services.
- Professional advisers including consultants, agents, lawyers, bankers, auditors and insurers based in the UK/EU who provide consultancy to Juniper.
- HM Revenue & Customs (UK), regulators and other authorities who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy and any contracts you have with Juniper.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. TRANSFERS
We mainly process data within the UK. If we require to transfer your data between the UK and EEA, the UK GDPR, EU GDPR, UK Addendum and the European Commission’s (EC) adequacy decisions apply.
Should the EC’s adequacy decisions be revised or withdrawn, or we wish to transfer personal data internationally, we would do so on a third-country basis using one of the following safeguards.
- International Data Transfer Agreement (IDTA)/IDTA Addendum;
- Binding Corporate Rules;
- Standard Contractual Clauses;
- Certification and Codes of Conduct.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to process it. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify Data Controllers, Data Subjects and any applicable regulator of a breach where we are legally required to do so.
Third-party links
Our website and applications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
9. YOUR LEGAL RIGHTS
You have the following rights, which you can exercise free of charge.
Please note that if your data is being processed by Juniper in our capacity as a Data Processor, e.g. you are a pupil, student, parent, member of school/MAT staff, etc. then we cannot action your request. You will need to contact the relevant Data Controller, i.e. school/MAT as it is the Data Controller’s responsibility to action rights’ requests. Juniper will assist Controllers with requests if they ask us to do so.
| Access | Request access to your personal data (commonly known as a “subject access request (SAR)”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. |
| Withdraw consent | Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. |
| Rectification | The right to require us to correct any mistakes in your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. |
| To be forgotten | The right to require us to delete your personal data in certain situations. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. |
| Restriction of processing |
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
|
| Data portability | Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. |
| To object | Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes without consent. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. |
If you wish to exercise any of the rights set out above, please contact DPO@junipereducation.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure you have a right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. COOKIE POLICY
What are cookies?
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. When you visit our website, we may collect information from you automatically through cookies or similar technology like ‘pixels’. Pixels are small blocks of code installed on (or triggered) on a web page or advertisement which can retrieve certain information about your device and browser, as well as advertisement identifiers.
How do we use cookies?
Our website uses cookies to distinguish you from other users of our website. This helps us to:
- provide you with a good experience when you browse our website and also allows us to improve our site.
- tailor our content.
- remarket relevant information and resources to website visitors.
11: GOVERNANCE & COMPLAINTS
If you have any questions or complaints about this Privacy Policy, the processing of personal data by Juniper or any other data protection matter involving Juniper, please contact
Gayle Richardson, Data Protection Officer in one of the following ways:
Email address: dpo@junipereducation.org
Postal address: Boundary House, 4 County Place, Chelmsford, CM2 0RE
Telephone number: 0345 200 8600
You can direct complaints to The Information Commissioners Office (ICO), which is Juniper’s Lead Supervisory Authority due to it being the supervisory authority of our main establishment in the UK. Additional relevant supervisory authorities will be contacted in relation to specific matters where required by law.
SUBSIDIARIES
Juniper Education Group Limited (UK) subsidiaries:
Juniper Education Newco Limited
Juniper Education Holdco Limited
Juniper Education Midco Limited
Juniper Education Holdings Limited
Financial Services 4 Schools Limited
Jane IT Systems Limited
Juniper Education Limited
Juniper Education Services Limited
Klik Limited
Pupilasset Ltd
Maze Education Limited
Optimum Reports Ltd
Primarysite Limited
Prime Principle Limited
Sisra Limited
Target Tracker Limited
The Concentric Curriculum Limited
E4Education Holdings Limited
E4Education Limited
Marvellousme Limited
all registered at Boundary House, County Place, Chelmsford, Essex CM2, and
Shkolo EOOD registered at 15 Lyubata Str. Lozenets Distr. Sofia-grad 1407 Sofia, Bulgaria.
Should any additional entities become part of Juniper Education Group Limited, they will be required to process data in the ways outlined in this Privacy Policy.
