Introduction

This privacy notice for Limejar Ltd (doing business as BOOP) ('BOOP', 'we', 'us', or 'our',), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:

• Visit our website at https://www.boop.co.uk, or any website of ours that links to this privacy notice


• Download and use our mobile application (BOOP), or any other application of ours that links to this privacy notice


• Engage with us in other related ways, including any sales, marketing, or events

What information do we collect?

Personal information you disclose to us

We collect the personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on BOOP app or website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

When you create an account on BOOP you may be asked for some basic information such as name, email address, password and possible profile picture. We do not collect student email addresses unless they have their own login account. Teachers,parents or guardians will create student accounts on their behalf and provide basic information to do this. Students are not permitted to create an account by themselves, but must be invited or added by their school administrator or parent.

We collect minimal personally identifiable information that is necessary to create an account on BOOP.

• Names
• Email Addresses
• Passwords
• Profile Picture (optional)
• Billing Address (if applicable)
• Contact Preferences

Student Diary Content / Student data / Sharing content

Users are able to add content to BOOP through adding information to student profiles, posts to diaries, reports, activities and schedules.

In order to provide the service as intended BOOP processes and stores the content that has been added, by the students, teachers or parents, to a students personal account, diary or schedule. This content could be text, photo’s, videos, documents, notes, class, year group, comments under posts and voice recordings. Content on a students personal profile is private by default and only visible by the student themselves, their teachers, parents or other users specifically invited to have access to the student account.

Sensitive Data

BOOP does not ask for, collect or require sensitive data as part of account creation.

However, as mentioned above, Teachers and Schools are able to add content to a student personal profile at their own discretion. Where this information includes very specific groups, this may include areas that is sensitive information (like racial or ethnic origin, or health data). This may also include other information that you wish to treat as sensitive data (like Looked-After Child status, free school meals or other funded groups). Where you share sensitive information or we process the information, then it will be allowed based on how you, as an organisation, have agreed to it. We will process this information on the understanding that you have a Lawful Basis for collecting and processing it.

Class Diary Posts / School Noticeboards

BOOP collects and processes content added to to wider school community through the class and school noticeboards. Teachers may post content to a class diary or the school noticeboard (if permissions allow) and this content is visible to all parents and students linked to the specific class or school. Content can include text, photos, videos, documents, comments, voice recordings and author of post.

Messages

BOOP collects messages that are sent and received within BOOP.

Content Library - Resources and Activities

Teachers can create learning content and resources for their students. BOOP will collect and store this content. Once published and assigned to a student or class this content is visible to the students and parents

Application Data

When you use BOOP app or website we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.


• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

Information automatically collected

Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

How does BOOP use your information?

Basically, we process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes but only with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

What legal bases does BOOP rely on to process your information?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

BOOP and GDPR

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. The purposes for which BOOP collects your information, the categories and specific types of information, and our practices and policies regarding the processing of your information are described in our Privacy Policy. We may rely on the following legal bases to process your personal information:

• General Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose.


• Performace of a Contract.  We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.


• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:


• Analyse how our services are used so we can improve them to engage and retain users


• Legal Obligations.  We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.


• Vital Interests.  We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

Your GDPR Responsibilities as a School or Teacher

It is important for school to determine the appropriate basis for collecting student data under the GDPR law.

• Parental Consent - Because we don't always have a direct relationship with parents and guardians, we ask that teachers and schools administrators acquire parental consent before adding a student to BOOP.


• Legitimate Interests. Your Data Protection Officer may determine that legitimate interest is the legal basis that permits you to collect and transfer student data to BOOP to process and provide the service.

BOOP acts as the Data Processor of student data and therefore cannot do anything with this data unless they have been instructed to do so by the Data Controller - The school/organisation/individual user are the Data Controller .

When and with whom do we share your information?

We never share your personal information unless completely neccessary in limited circumstances and in order to provide our service. We may share information in specific situations described in this section and/or with the following third parties.

Sub Processors

These companies help us do things like manage our data centres to make sure BOOP is reliable and fast or provide analytics. We currently use the following sub-processors:

• AWS (Amazon Web Services)
  At AWS their highest priority is securing their customers’ data, and implementing rigorous contractual, technical and organisational measures to protect its confidentiality, integrity, and availability regardless of which AWS Region a customer has selected.
  
  AWS complies with ISO 27018, a code of practice that focuses on protection of personal data in the cloud. It extends ISO information security standard 27001 to cover the regulatory requirements for the protection of personally identifiable information (PII) or personal data for the public cloud computing environment and specifies implementation guidance based on ISO 27002 controls that is applicable to PII processed by public cloud service providers.

Our sub processors have signed a Data Protection Agreement with us, which stipulates that any data we share with them will be used exclusively to provide services to us and not for any other purposes.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.


• Other Users Please note when you share personal information (for example, by posting comments under someones post, making contributions, or other content to the BOOP app or website) or otherwise interact with broadcasted areas of the Services (posting/commenting to the Class Diary, Creating activities in the Content/Resources Library or posting/commenting School Noticeboard) such personal information may be viewed by others users and may be more widely made available to users with access to these areas. Similarly, other users will be able to view your activity in these instances, communicate with you within BOOP, and view your basic profile info which includes personally identifiable information (Mainly your name and profile picture).

How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy and for as long as a user account is active, unless a longer retention period is required or permitted by law. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information.

After an account has been deleted or terminated, we will hold the associated data for a period of 3 months in case of accidental deletion by a User.

How do we keep your information safe?

We aim to protect your personal information through a system of organisational and technical security measures.

BOOP takes the security and privacy of personal Information extremely seriously. We maintain safeguards designed to protect against unauthorised use, disclosure of, or access to personal information. 

• When you enter any information anywhere on the Service, we encrypt the transmission of that information using secure socket layer technology (SSL/TLS). BOOP uses TLS 1.2 and above security at the network level to ensure account information and journal content is transmitted securely


• All your personally identifiable information is encrypted at rest, which converts all personal information stored in the database to an unintelligible form.


• We ensure passwords are stored and transferred securely using encryption and salted hashing


• BOOP is hosted using trusted service provider AWS, with whom we have a contract providing for enhanced security measures. AWS Servers are equipped with industry-standard firewalls. In addition, the hosting facility provides a 24x7 security system, video surveillance, intrusion detection systems, and locked cage areas.


• AWS undergoes strict ongoing security assessments from external audit firms to ensure compliance with security standards including ISO 27001 , ISO 27018, ISO 27017, ISO 27701 and ISO 9001. As well as Cyber Essentials plus certification.


• All employees of BOOP are subject to strict confidentiality agreements which they must sign and agree to before working on the platform.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.

If you believe you have found a security vulnerability on BOOP, please let us know right away. By emailing info@limejar.co.uk. We will investigate all reports and do our best to quickly fix valid issues.

What are your privacy rights?

You have the right to access, correct, delete or download for transport to a similar service any of your Personal Information collected by BOOP, where permitted under applicable law.

If you are an administrator, teacher, or family member you can update the information associated with your BOOP account directly the Account Settings tab on your profile. If you are a parent or guardian and want to correct, edit, download, or update information about your child, please work directly with your child's teacher or school, or you can contact us at info@limejar.co.uk

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at info@limejar.co.uk.

Updates to this notice

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

How to contact us regarding this privacy policy

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), by email at info@limejar.co.uk, or by post to:

Limejar Ltd
DPO Officer
53 Andersonstown Road
Belfast, Antrim BT11 9AG
United Kingdom