Your information is important to us and we aim to look after your information carefully in line with the latest data protection and privacy laws.
Please do read this policy so you know what we are doing with your information.
The rights of individuals are protected by the General Data Protection Regulation (Regulation EU) 2016/679) (the “GDPR”) and any amendments to it. These impose restrictions and controls over the way that Zero Gravity collects and uses personal data.
For the purpose of this Policy and the applicable data protection legislation, the data controller of your personal information is Zero Gravity Tech Ltd (company number: 12091675), a private limited company incorporated in England with its registered office: First Floor, 70 Wilson St, London, England, EC2A 2DB.
2. Who we are, our aims and objectives
Zero Gravity Tech Limited (“Zero Gravity”) is a certified social enterprise (company number: 12091675) that provides free-to-use digital mentoring services to young people from low-income backgrounds.
Our mission is to transform access to higher education so that the brightest minds can reach the best universities and careers, whatever their background.
We provide these services free to our users because we believe that cost should never be a barrier to our community. Our ongoing commitment to our social mission means that we only share your personal data with third parties when required to deliver the Services (as defined below) and when compelled to do so by law.
For the purposes of this Policy, the term “Zero Gravity” refers to both Zero Gravity Tech Ltd and the Zero Gravity Fund, charity number 1188177.
3. What is personal data?
“Personal data” is information relating to a living individual where the individual can be identified from the data, or the individual can be identified from that data combined with other information held by us (or likely to come into our possession). This might include a name, address, telephone number, email address or photograph. It could also include identifiers such as an identification number or a pseudonym. It does not include anonymised data, where the identity has been permanently removed and cannot be matched back to an individual through other data held so that it is no longer possible to identify an individual.
4. What are special categories of data?
“Special categories of personal data” is data that includes more sensitive or personal information about an individual. This might include information relating to an individual’s racial or ethnic origin, physical or mental health, religion, or criminal offences.
5. What services does this policy cover?
Our services include (without limitation) mentoring services, provision of information about Zero Gravity, connecting members with universities, employers and employment-based opportunities, provision of audiovisual content, text, photographs, advertising and other services which we may offer at or via the Platform (the “Services”). This policy covers all of the Services and any reference to “you” or “your”, means you as a user of our Services. This policy applies to the collection and use of your information by us and parties that we use to deliver the Services (such as our suppliers and sub-contractors).
6. What information does Zero Gravity collect?
What information we collect about you depends on which of our Services you are using or providing. The information that we may collect includes:
- your full name, address, postcode, email address, telephone number, profile picture, schools(s) attended, examination grades, work experience, extra-curricular activities, date of birth, gender and/or ethnicity;
- information about your socio-economic background, e.g. whether you have lived in care, have been a young carer, have refugee/asylum seeker status, would be or are the first in your family to go to university and/or have received free school meals;
- information about your use of or delivery of Services, including details of the content you viewed on our Platform, how long you stayed and on which pages, and your engagement with features on the Platform;
- automatically tracked information, which includes your IP address, cookie information, the type of device used to access the Platform, dates and times of your interactions with the Platform and Platform correspondence;
- feedback from your Zero Gravity mentor/mentee, reviewing your session together, collected by surveys after each mentoring session;
- in the event of a safeguarding issue, recordings of video mentoring sessions between relevant users;
- other data to ensure and check compliance with the Terms & Conditions and/or otherwise as required by law.
The GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with those acts. Any access request is free of charge.
7. When and how do Zero Gravity collect information?
We (or our authorised third parties) may collect information about you:
- when you register to receive Services or to deliver Services as a mentor, when you complete a written form stating that you would like further information about Services, when you register on our Platform and/or when you request support from a mentor or deliver support as a mentor via our Platform;
- when you contact us with an enquiry or other feedback;
- in monitoring your use of the Services including (without limitation) communications sent by you via the Services;
- when we are checking compliance with the Terms & Conditions and/or otherwise as required by law;
- through the use of “cookies” and/or other devices. For full details, see the section entitled “Cookies and similar devices” below;
- when you disclose your personal information to us or otherwise through the Services at any other point;
- from third party suppliers who have confirmed to us that they are authorised to pass your information to us in accordance with your legal rights.
8. How will Zero Gravity use my information?
Your information may be used by us and our authorised third parties to:
- assist in and administer the provision of Services to you;
- monitor, develop and improve the Services and/or your experience;
- in the case of mentees referred to Zero Gravity by a school, sixth form college or an institutional partner, including Local Authorities and other public bodies, confirmation that you have applied for our Services and your level of engagement;
- process and deal with any complaints or enquiries made by or about you;
- investigate any suspected breach of the Terms & Conditions;
- contact you with further information about our Services (if you have requested to receive this).
9. Do we disclose your personal data to third parties?
We may disclose your personal data to third parties:
- authorised by us and acting on our behalf, such as our employees, contractors, suppliers and/or agents, including without limitation our customer care teams to administer the Services provided to you by us now or in the future;
- where we have your consent to do so, for marketing communications, such as potential careers opportunities;
- as part of general, statistical information about the Services’ user base, traffic volumes and related matters. These details will not include information personally identifying you;
- as part of general, statistical information about those that access our Services. These details will not include information personally identifying you; and
- to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence, unlawful activity or suspected breach of the Terms & Conditions and/or Safeguarding Policy or otherwise where required by law or where we suspect harm or potential harm to others. We will co-operate with any law enforcement authorities or court order requesting or directing us to disclose the identity or location of or any other information about anyone breaching the Terms & Conditions and/or Safeguarding Policy or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders. We shall not be obliged to give you any further notice of this.
Please note this policy does not cover companies, services or applications that we do not own or control, or people that we do not employ or manage, including (without limitation) platforms, websites or applications/widgets provided by third parties.
10. What are Zero Gravity’s legal grounds for processing my information?
We will only process your personal information where we have legal grounds to do so. Generally, we will only process it on the following grounds:
- you have given consent for the processing. When we rely on consent to process your personal information, you will always have the right to withdraw this consent either by clicking the ‘unsubscribe’ button if there is one or by emailing us at email@example.com;
- to comply with a legal obligation;
- the processing is necessary for the purposes of the legitimate interests pursued by Zero Gravity or an authorised third party. An example of this is when we provide updates to third parties who have introduced a mentee to Zero Gravity.
11. Will I be sent marketing messages?
We will only send you information about our Services if you indicate that you wish to receive such messages (e.g. by “opting-in” by ticking a tick box). Where we have your consent or are otherwise permitted to do so, we may send you information by email, telephone (including SMS and MMS), mail or other methods of communication.
To stop receiving marketing communications from us, you can use the ‘unsubscribe’, ‘stop’ or similar facility contained in any such communication or you can email us at firstname.lastname@example.org stating that you do not wish to receive further communications from us.
12. How long will Zero Gravity store my personal data?
Unless you request that we delete your information:
- subject to safeguarding obligations, we will keep your information until you no longer require access to or provide the Services; and
- if you have consented to Zero Gravity sending you direct marketing communications, we will retain your information for a period of 6 years, to cover the period we expect that you may be in higher education and entering work, after which we will delete it unless you consent to us holding it.
13. Cookies & similar devices
In addition, in common with many other online services, we and our authorised third parties may use “cookies” and/or other tools to store and sometimes track information about you in accordance with sections 15 to 19 inclusive below.
14. What are cookies?
Cookies are small files of letters or numbers. These files are stored in the memory of your computer (or relevant device) or are placed on the hard drive of your device. Those stored on your device are generally known as session cookies. Those stored on your hard drive are generally known as persistent cookies.
You can find out more about cookies, including how to disable/enable and delete them, at the following website: www.allaboutcookies.org.
We use two types of cookies on our Platform:
- Analytics cookies – these provide us with analytical information about the use of our services; and
- Authentication cookies – these are used for registration and log in authentication.
We use these cookies to help provide and review our services, for example to:
- allow you to access your stored information you have registered with us;
- monitor and count the number of visitors to our Platform; and
- see how you and other users move around our Platform.
You can block the cookies that we use by activating the settings on your browser that allow you to refuse the setting of all or some cookies. However, if you block all cookies (including essential cookies) you may not be able to access parts of our services, or you may experience reduced functionality when accessing certain services.
17. When do my cookies expire?
Most cookies will expire at the end of your current session on our Platform, but some have an extended lifespan.
18. How can I turn cookies off?
You can block most cookies by activating the setting in your browser that allows you to refuse the setting of all or some cookies.
19. Are my details safe?
We endeavour to take all reasonable steps to protect your personal information. We are careful to choose storage facilities that we have had assessed and which we are confident are suitably secure to store your information.
Please always think carefully before disclosing information to other users of the Platform or otherwise making your information publicly available. It is important that you are aware that any information you disclose to another user of the Platform may then be disclosed by that user. We have no responsibility or control over the contents of communications made between users of our Services.
20. What are my rights?
Any personal information you supply will be treated in accordance with the GDPR.
We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. These are:
- the right to request a copy of the personal information we hold about you. To do this, please contact us at email@example.com making clear that you are requesting a copy of your personal data and including full details of what you require. You may also be required to submit proof of your identity;
- the right to object to your personal information being used for direct marketing. We will give you the ability to object to this, and where required, we will ensure we obtain your consent before undertaking marketing;
- the right to object to your personal data being processed where the legal basis for the processing is our own legitimate interests as a business (see the ‘legal basis for processing’ section above). We will comply with such a request unless there is a lawful reason for not doing so, such as, when we need to continue to process your data to defend a legal claim or comply with safeguarding rules, regulations and legislation;
- the right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal data;
- the right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal data is essential;
- the right of erasure. You may request that we erase your personal data and we will comply unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your personal data, such as, a legal obligation that we have to comply with, including but not limited to safeguarding mentees;
- the right to data portability. In certain circumstances, you may request that we provide your personal data to you in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services to us. Where this right is applicable, we will comply with such transfer as far as it is technically feasible; and
- the right to lodge a complaint with the supervisory authority. We suggest that you contact us with any questions or if you have a complaint in relation to how we process your personal data. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.
21. How do I lodge a complaint?
If you are concerned about our use of your personal data, please contact us at firstname.lastname@example.org and we will be happy to provide explanations or information as needed.
If you find our response unsatisfactory, or you do not believe we are processing your personal data in accordance with the law, you can make a complaint directly to the Information Commissioner’s Office. The Information Commissioner's Office can be contacted in writing at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Zero Gravity’s registration number with the Information Commissioner’s Office is ZB000749.
22. How can I change my details?
Where you register your details for certain Services and open a user account with us, you can then use that to access and log on to use those Services. You may change or update some of your details at any time via your account. If you are not registered for these Services but wish to update your details then please contact us at email@example.com. You should please make sure that you update your details as soon as possible with all relevant changes.
Contact Zero Gravity
If you would like to discuss any aspect of this policy or the way Zero Gravity processes your information please contact firstname.lastname@example.org.
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