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Document 05

Privacy notice

What we do with your own details as a customer.

  1. 01

    Who this notice is for

    This notice is for tutors and practices who use Lucy Learn, and for anyone who signs up or writes to us. It explains what we do with your own personal data as our customer.

    If you are a parent or carer, your practice holds your family’s information and decides what happens to it; we look after it for them. The privacy notice that applies to you is your practice’s, and you should ask them about it.

  2. 02

    Who we are

    Smithies Studio LLP trades as Lucy Learn and is the controller of the personal data this notice describes. We are a limited liability partnership registered in England and Wales with number OC460734, at 27 Finches Close, Chepstow, NP16 5UX, and registered with the Information Commissioner’s Office under number C2029774. Write to us about anything in this notice at [email protected].

  3. 03

    What we hold, why, and on what basis

    • Your email address and password (stored only as a one-way hash), your authenticator app’s secret and your recovery codes

      Why
      To create your account and keep it secure
      Lawful basis
      Our contract with you
    • Your practice’s details: its name, your name, contact details, town and outward postcode, VAT details and safeguarding lead

      Why
      To run the service and put your name on what your practice sends
      Lawful basis
      Our contract with you
    • Your plan, trial, subscription and payment history. Your card is held by Stripe; we see only its brand, last four digits and expiry

      Why
      To bill you and keep the records the law requires
      Lawful basis
      Our contract, then legal obligation
    • Which version of our terms and agreement you accepted, when, and from which IP address

      Why
      To show what we agreed
      Lawful basis
      Legitimate interests: being able to prove our contract
    • A record of significant actions on your account, with the IP address they came from, and of sign-up attempts, kept only as a one-way hash

      Why
      To keep the service and your account secure and stop abuse
      Lawful basis
      Legitimate interests: security and preventing fraud
    • How much email your practice sends, and how much bounces or is marked as spam

      Why
      To keep every practice’s email deliverable, as our Acceptable use policy describes
      Lawful basis
      Legitimate interests: protecting the service and every practice using it
    • What you write to us, and our replies

      Why
      To help you
      Lawful basis
      Legitimate interests: supporting our customers
  4. 04

    Email we send you

    We email you about your account: sign-in and sign-up links, receipts, failed payments, changes to our terms, our sub-processors or our prices, and anything else you need to know to use the service. These are part of the service and you cannot opt out of them while you have an account. We do not send marketing email.

  5. 05

    Who we share it with

    We do not sell your data or share it for anyone else’s marketing. We share it only with:

    • the services listed on our Sub-processors page, which host the service, store files and send email;
    • Stripe, which takes your subscription payments and holds your card;
    • Google, which hosts our own email inbox, for anything you write to us;
    • our accountants and professional advisers, under a duty of confidentiality; and
    • HM Revenue & Customs, the police, a court or a regulator, where the law requires it.
  6. 06

    Outside the UK

    Our database is in the Netherlands, which the UK recognises as protecting data adequately. Stripe, Resend and Google may process your data in the United States; each transfer is covered by the UK Extension to the EU–US Data Privacy Framework, or by the UK International Data Transfer Addendum where that does not apply.

  7. 07

    How long we keep it

    • Your account and your practice’s details

      How long
      While you are a customer, then 90 days, which is when your practice is deleted
    • Subscription, invoice and payment records

      How long
      Six years from the end of the financial year they belong to, because HMRC requires it
    • Which terms you accepted, when and from where

      How long
      Six years after our contract ends, the time within which either of us could bring a claim
    • Security and activity records

      How long
      Six years from when each was made
    • A sign-up that was never finished

      How long
      Deleted once the link we sent has expired unused
    • A record of the emails we send you: who to, which email and whether it arrived

      How long
      Twelve months
    • What you write to us

      How long
      Two years after we last wrote to each other
  8. 08

    Automatic decisions

    One decision is made automatically: if a subscription payment fails and has not been made seven days later, your practice is locked until it is paid. Paying unlocks it at once, and you can write to us if you think it has happened in error. Nothing else about you is decided automatically, and we do not profile you.

  9. 09

    Cookies

    Our website and the service use only the cookies needed to keep you signed in and protect your forms. We use no advertising or tracking cookies and no third-party analytics, so we do not ask for consent to cookies.

  10. 10

    Your rights

    You have the right to see the personal data we hold about you, to have it corrected, to have it erased, to restrict or object to how we use it, and to receive it in a portable format. Some rights depend on the lawful basis: we cannot erase records the law requires us to keep, and we will tell you when that applies. Ask at the address above; we reply within a month.

    If you are unhappy with how we have handled your data, please tell us first. You also have the right to complain to the Information Commissioner’s Office, at ico.org.uk or on 0303 123 1113.

  11. 11

    Changes to this notice

    If we change this notice in a way that matters, we will email you before the change takes effect. The date it last changed is shown on this page.

Questions about any of these go to Smithies Studio LLP, which trades as Lucy Learn, at [email protected].