From the School Gates

This privacy notice will let you know what From The School Gates (“FTSG”), ‘we’, ‘our’, ‘us’, does with your personal data. We will tell you:

• what information we need and why
• what we do with your information
• who we share your information with
• how long we keep your information
• the lawful basis we process your information under
• the rights you have

Some activities, services and websites will have additional privacy notices or transparency statements providing more detail on how your information is used.

We are registered with the Information Commissioner’s Office with the registration number ________. FTSG is the data controller for the personal information we process, unless otherwise stated.

Your data protection rights

Data protection legislation gives you eight rights over your personal information. Whether a particular right applies depends on why information is being processed. Below we have outlined each of the rights and specified where a right would always apply.  You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe we have not handled your personal data in accordance with applicable data protection laws.

The right of access

You have the right to ask for copies of the personal data that we hold on you. This right always applies. However, there are exemptions which mean you may not get all the information you have requested.

The right to rectification

You have the right to ask for any inaccurate or incomplete information to be updated. This right always applies.

The right to erasure

In some circumstances you have the right to ask for information to be erased.

The right to restrict processing

In some circumstances you have the right to ask us to restrict the way we use your personal data.

The right to object to processing

In some circumstances you have the right to object to the ways in which we are using your personal data.

The right to be informed

You have the right to be told how your personal information will be used before it is collected from you. This privacy notice is key part of how we are fulfilling this right, additional privacy notices and transparency statements may also be provided.

The right to data portability

In some circumstances you have the right to request a copy of your personal data in a structured, commonly used and machine-readable format, or have it sent to another organisation. Due to the way we collect and use information this right is unlikely to apply.

Rights related to automated decision-making including profiling

You have the right to not be subject to automated decision making, if this results in legal or other significant effects on you.

When you contact us to exercise any of your rights, we will:

• acknowledge that your request has been received
• inform you if your request is not applicable, and give the reasons why
• endeavour to act on your request within the statutory time period, usually 1 calendar month
• let you know if more time is needed to respond to your request
• explain any exemptions we have applied

More information on your rights and how and when they apply can be found on the Information Commissioner’s ‘Your data matters’ page.

Our data protection policy

We are committed to fostering a culture of transparency and accountability by demonstrating compliance with the principles set out in data protection legislation.

This privacy notice outlines how we use personal data, including data we collect from or about you.

To keep you informed about how we use personal information some of our activities, services and websites may also provide additional privacy notices or transparency information.

What Information We Collect

We collect information from you personally, from the devices you use, and from third parties.

Information You Provide

• Profile Information. We collect information that you provide when you set up an account, such as your username, email address and/or telephone number, and password. You can add other information to your profile, such as a bio or other details.
• User Content. We collect the content you create or publish through the Platform, such as reviews, posts, photographs, videos, audio recordings, comments, hashtags, feedback, reviews, and the associated metadata (such as when, where, and by whom the content was created). Even if you are not a user, information about you may appear in content created or published by users on the Platform.
• Purchase Information. When you make a purchase or payment on or through the Platform, including when you buy a subscription, we collect information about the purchase or payment transaction, such as payment card information, billing, delivery, and contact information, and items you purchased.
• Surveys, Research, and Promotions. We collect information if you choose to participate in a survey, research, promotion, marketing campaign, or event conducted or sponsored by us.
• Information When You Contact Us. When you contact us, we collect the information you send us, such as proof of identity or age, feedback or inquiries about your use of the Platform or information about possible violations of our Terms of Service or Community Guidelines.

Automatically Collected Information

• Technical Information. We collect certain device and network connection information when you access the Platform. This information includes your device model, operating system, IP address, and system language. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs. We automatically assign you a device ID and user ID. Where you log-in from multiple devices, we use information such as your device ID and user ID to identify your activity across devices to give you a seamless log-in experience and for security purposes.
• Usage Information. We collect information about how you engage with the Platform, including information about the content you view, the duration and frequency of your use, your engagement with other users, your search history and your settings.
• Inferred Information. We infer your attributes (such as age-range and gender) and interests based on the information we have about you. We use inferences, for example, to keep the Platform safe, for content moderation and, where permitted, to serve you personalised ads based on your interests.
• Cookies. We use cookies and similar tracking technologies to operate and provide the Platform. For example, we use cookies to remember your language preferences, make sure text remains in a draft if you happen to refresh the page, and for security purposes. We also use these technologies for marketing purposes. We will obtain your consent to our use of cookies where required by law.

Information From Other Sources

• Merchants, Payment and Transaction Fulfilment Providers. We receive information about you from merchants as well as payment and transaction fulfilment providers, such as payment confirmation details, and information about the delivery of products you have purchased through our shopping features.
• Third Party Platforms and Partners. Third party platforms provide us with information (such as your email address, user ID, and public profile) when you choose to sign up for or log in to the Platform using sign-in features provided by those third parties (for instance, if you create an account tied to your Google email address). We may also receive contact information that you hold or is held about you when contact information is synced with our Platform by you or another user.
• Additional Sources. We may collect or receive information about you from organisations, businesses, people, and others, including, for example, publicly available sources, government authorities, professional organisations, and charity groups. We also collect information about you where you are included or mentioned in User Content, Direct Messages, in a complaint, appeal, request or feedback submitted by a user or third party, or if your contact information is provided to us by a user.

How We Use Your Information

We use your information to operate, provide, develop, and improve the Platform, including for the following purposes.

• Provide and administer the Platform, such as enabling you to create, share, and consume content, to interact with other users and their content, and provide user support.
• Personalise and customise certain features and content on the Platform, such as providing content that you might find relevant.
• Enforce our Terms, Guidelines, and other policies that apply to you. We review content and other information through a mix of technology (including through automated means) and human moderation to protect the safety and well-being of our community.
• Provide and improve our advertising services, including to serve ads (including personalised ads, where permitted) and to measure and understand the effectiveness of the ads and other content.
• Maintain and enhance the safety, security, and stability of the Platform by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).
• Review, improve, and develop the Platform, including by monitoring interactions and usage across your devices, analysing how people are using it, and by training, testing, and improving our technology, such as our machine learning models and algorithms.
• Facilitate research conducted internally and by independent researchers that meets certain criteria.
• Comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.

How We Share Your Information

Service Providers

We engage service providers that help us provide, support, and develop the Platform and understand how it is used. They provide services such as: cloud hosting, content delivery, customer and technical support, content moderation, marketing, analytics, and online payments.

Partners

Third Party Platforms and Partners. We share limited information with third party platforms and partners whose platform or services are integrated with the Platform. We do this to give you a seamless experience, allow your content to be shared on other platforms, and/or enable third party platforms and partners to better authenticate users. Some examples include if you:

• log-in to a third party platform using your account, we will share your basic account information,
• sign-up or log-in to the Platform using your account details from a third party platform (such as Google), we will share certain Technical Information to facilitate this.

Merchants, Payment and Transaction Fulfilment Providers, and Other Service Providers. When you purchase a subscription through the features on our Platform, we share purchase information related to the transaction with the merchant, payment and transaction fulfilment providers, and other service providers.

Others

We share your information in other limited scenarios as follows:

Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control, or acquisition of all or a portion of our business.

Legal Obligations and Rights. We may access, preserve, and share the information with law enforcement agencies, public authorities, researchers, copyright holders, or other third parties if we have good faith belief that it is necessary to:

• comply with applicable law, legal process or government requests, as consistent with internationally recognised standards,
• protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk,
• investigate potential violations of and enforce our Terms, Guidelines, or any other applicable terms, policies, or standards, or
• detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.

Our Legal Bases and How We Process Your Information

We may only use your information when we have a legal basis to do so. We use different legal bases depending on why we use your information (in other words, the “purpose” of our processing). These legal bases are contractual necessity, legitimate interests (ours, yours or those of another party), consent, compliance with a legal obligation, performing a task in the public interest, and protection of vital interests.

Here we explain the legal bases we rely on when we process your information. This section also describes why we use your information, how this information is processed, the categories of information involved, and the associated rights (which always includes the right to access your information). For more information on how to exercise any of your rights, please check out the “Your Rights and Choices” section in the Privacy Policy.

Contractual Necessity

If you have the legal capacity to enter into an enforceable contract, we your information where it is necessary to perform the contract you enter into (our Terms) when you register for, access, or use the Platform. This means we use your information to:

• Provide you with the Platform. We use your information to allow you to access and use the Platform, including allowing you to create and consume content, interact with others, and utilise social features.
• Enforce our Terms, Guidelines, or policies. We use your information to enforce our Terms, Guidelines, and policies (including through automated means and human moderation). This may include age restricting mature content, maintaining our For You feed eligibility standards, removing content or suspending or banning your account if we determine that you are violating our Terms or Guidelines.
• Administer the Platform. We also use the information we have to administer the Platform, such as to communicate with you on service related matters, provide you with updates and support regarding any purchase you make on or through the Platform, and respond to and process your queries, claims or disputes (including when you tell us about a problem, or ask for a copy of your information).

Your Consent

We ask for your consent to access or use your information for specific purposes. If we do, you’ll always be able to revoke your consent through your device permissions or in-app settings.

Your rights: Whenever we use your information based on your consent, you can withdraw your consent at any time. However, your withdrawal of consent will not affect the lawfulness of processing your information based on your consent prior to your withdrawal of consent.

You also have the right to port information you have provided to us that we use based on your consent.

Compliance with a legal obligation

We may use your information where it is necessary to comply with a legal obligation. This includes situations where we have obligations to take measures to ensure the safety of our users, or comply with a valid legal request such as an order or disclosure request from regulators, law enforcement agencies or courts.

To perform a task in the public interest

We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding children and promoting public safety, security, and integrity as laid down by applicable law.

Your rights: When we use your information on the basis that it is necessary for a task carried out in the public interest, you have the right to object to, and seek restriction of, our usage.

To protect someone’s vital interests

We may use your information where it is necessary to protect your or someone else’s life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life.