Last Updated: 3rd September 2021

Please read this policy carefully. This policy contains important information on who manages the Code for Life portal, how and why we collect information about you (for example, your name and email address), how we use your information, and with which persons we share your information. We also explain what rights you have in relation to your personal information, for example, the right to say no to the use of your information in certain cases, and how to contact us if you want to find out more about your rights or if you have other questions about this policy.

  1. Our commitment

  2. Who we are

  3. Types of information we hold about you

  4. How we will use information about you

  5. Change of purpose

  6. Cookies

  7. Sharing your personal information with other persons

  8. How long will we keep your personal information?

  9. Your rights

  10. Keeping your personal information secure

  11. How to complain

  12. Changes to this Privacy Policy

  13. How to contact us

  14. Do you need extra help?


1. Our commitment

We are deeply committed to creating a safe and secure online learning environment for all students, teachers, parents and guardians who use the Code for Life portal.

  1. We strive to give you control over the personal information that you give us, and we take the protection of your information very seriously.

  2. We take extra precautions for the safety and privacy of our younger learners. Where personal information could be entered, for example when a student names a level, the teacher is notified via email and the teacher has the ability to delete the level if its name is rude or compromising.

  3. Our portal only relates to Code for Life and we do not show advertisements on our website or within our lessons.


2. Who we are

We are a company called “Ocado Innovation Limited” or “Ocado Technology”, and we own the Code for Life learning portal. In this policy, we also use the name “Ocado” when we refer to us. Our office is at Buildings 1 & 2 Trident Place, Hatfield Business Park, Mosquito Way, Hatfield, AL10 9UL.

We are responsible for the personal information we collect about you on the Code for Life portal.


3. Types of information we hold about you

Your personal data, or personal information, is any information relating to you. It does not include anonymous information, which cannot be traced back to you or another person (anonymous data).

When you use the Code for Life portal and our services we collect the following personal information:

If you are a Student, we collect:

  • Your name, password and class code: we collect this information when your teacher creates an account.

  • Your school / club / teaching or education institution and your class code and class name, if you are a school Student: your Teacher provides this information to us.

  • Performance information about your performance and progress (for example, what levels you have completed and what levels you create), and

  • The coding you create (including any avatars you may create): we collect this information when you use the Code for Life portal.

  • Your messages and queries you may send us: when you use the “Contact Us” form or email.

  • When your account was created and when you last logged into your account: this information is generated at the time your account is created or you log in.

  • Technical information, such as the IP address and other information about the device you use to access the Code for Life portal, and technical information about how you use these (for example, which pages on our portal you visit, for how long you stay on each page, etc.): when you navigate the portal and allow the use of non-essential cookies.

  • Data from Code for Life surveys you may take part in.

If you are a Independent Student, we collect:

  • Your name, email address, username and password: we collect this information when you create an account.

  • Performance information about your performance and progress (for example, what levels you have completed and what levels you create), and

  • The coding you create (including any avatars you may create): we collect this information when you use the Code for Life portal.

  • Your messages and queries you may send us: when you use the “Contact Us” form or email.

  • When you created an account and when you last logged in to your account: this information is generated at the time you create your account or log in.

  • Technical information, such as the IP address and other information about the device you use to access the Code for Life portal, and technical information about how you use these (for example, which pages on our portal you visit, for how long you stay on each page, etc.): when you navigate the portal and allow the use of non-essential cookies.

  • Data from Code for Life surveys you may take part in.

  • Your marketing preferences, if you select to sign up to our newsletter.

  • If you are under 13 years old, we will collect the data of your parent or guardian as you will need to ask them to register on your behalf.

If you are a Teacher, we collect:

  • Your first and last names, email address and password: we collect this information when you create an account.

  • Your school / club / teaching or educational institution, the classes you create, the students you register in each class, and the teachers you invite; also, any material you create: when you use the portal.

  • Your messages and queries you may send us: when you use the “Contact Us” form or email.

  • When you created an account and when you last logged in to your account: this information is generated at the time you create your account or log in.

  • Technical information, such as the IP address and other information about the device you use to access the Code for Life portal, and technical information about how you use these (for example, which pages on our portal you visit, for how long you stay on each page, etc.): when you navigate the portal and allow the use of non-essential cookies.

  • Data from Code for Life surveys you may take part in.

  • Your marketing preferences, if you select to sign up to our newsletter.

If you are a Website visitor, we collect:

  • Technical information, such as the IP address and other information about the device you use to access the Code for Life portal, and technical information about how you use these (for example, which pages on our portal you visit, for how long you stay on each page, etc.): when you navigate the portal and allow the use of non-essential cookies.

  • Your email address and marketing preferences, if you select to sign up to our newsletter.


4. How we will use information about you

We need all the categories of information that we describe above, so that we can:

  • perform our agreement with you and provide you with our services. For example, to enable you to create an account and to access the portal and our learning materials. Having an account gives teachers access to course material, class and individual student management features, and also it gives students access to the portal in order to learn how to code within a supported environment (classroom), or independently (at home).

  • fulfil our legitimate interests, such as our interests to:
    • improve our services.

    • ensure that our portal is secure and is used in accordance with our Terms. For example, we may use account information to limit a user temporarily or permanently from the Code for Life portal if that user engages in inappropriate use of the site (e.g. giving other people access to their user account, malicious misuse of the portal, including spam).

    • send you important information: for example, we use your email address to send you account verification emails, emails to notify you about changes to our Terms, or about any maintenance impacting your access to the portal. Sometimes, we may be required by law to send you this information.

    • provide customer support and respond to your queries, for example, when you use the Contact Us form. We strongly advise you not to disclose personal information (other than name and email address) when contacting us – messages you exchange on the portal and any forms you submit to us will be recorded. The Contact Us form is strictly for the purpose of user support. User-initiated communication concerning topics other than those relating directly to the Code for Life portal, including resources or user experience, may not be answered. Please be aware that we will never ask for personal information other than what is required to identify your account and respond to your queries, and we will never ask for your password.

    • protect our legal rights, for example, if we need to defend ourselves in court.

  • with your permission (or if you are under 13, the permission of the person who looks after you) to send you marketing communications (for example, our newsletter or communications about our portal features or upcoming events). You have the right to change your mind at any time (see the “Your Rights” section below for more information).

  • with your permission (or if you are under 13, the permission of the person who looks after you), use cookies to collect information about how you use our portal, in order to analyse and improve user experience. This information is usually anonymised and used at an aggregate level. Please see section “Cookies” below for more information on what information we collect and how we use cookies.

We summarise below the purposes for which we use your personal data and the lawful basis on which we rely.

Purpose Legal basis

To allow you to create an account and provide our services to you through our portal, such as providing course material and resources

Contractual necessity: the information is necessary to fulfil our contract with you.

To manage our relationship with you, including to allow you to manage your account, provide customer support, to handle your requests and queries, to provide you with information about our services that you use, or information about changes in our Terms or this Policy

  • Contractual necessity: to the extent the information is necessary to fulfil our contract with you (e.g. to ensure that we provide to you the services that you have requested).

  • Legitimate interests: to the extent the information is necessary to process queries and effectively manage our relationship with you as user of our services.

  • Compliance with a legal obligation: to the extent we are required by law to contact you in order to provide certain information (for example, to notify you of changes to our Terms)

To send you our newsletters and other promotional material about Code for Life

  • Your consent, where this is required by law.

  • Otherwise, when consent is not required, we will rely on our legitimate interest to keep you informed of our services, to the extent this is permitted by law.

To carry out analysis and compile statistics about the use of our portal, and the use of our services, in order to enable us to provide a better service, feature and functionality

  • Your consent: where we obtain this information by using cookies.

  • Our legitimate interest to ensure the smooth and effective functioning of our portal and services, to make sound business decisions about our services and to design, inform and deploy our business strategies.

To authenticate your account and to ensure the security of our portal, information systems and assets, to monitor compliance with our Terms, to prevent illegal activities in relation to our services.

Our legitimate interest to protect our business assets against illegal or inappropriate activities or security threats and your legitimate interest to protect the security of your account and information.

To protect our legal rights and to establish, exercise or defend legal claims relating to our services.

Our legitimate interest to protect our legal rights.

For accounting, record keeping and audit purposes

Our legitimate interest to effectively manage our business, audit our business processes and make informed business decisions.

When we rely on legitimate interests to process personal data, we consider and balance those interests against any potential impact on you (both positive and negative) and your rights and interests. If we consider that our interests are overridden by the impact on you, we will not use your personal data in this way (unless the law gives us another valid ground to do so). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.


5. Change of purpose

We will only use your personal information for the purposes for which we collected it or for other compatible purposes. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the basis on which we do so. Please note that we do not always need to rely on your consent to collect and process your personal information, and we will not seek your consent unless this is required by law.


6. Cookies
6.1 What are Cookies?

Cookies are tiny files that have information (data) in them. When you visit our portal, a cookie is placed on the device you use. Cookies allow us to remember when you visit our portal, or when you open an email. They help us understand how you are using the Code for Life portal, as well as which parts of our portal are popular and which ones we need to make better.

We also use other forms of technology (such as web beacons or pixels) which are similar to cookies and which allow us to monitor and improve our website. When we talk about cookies in this policy, we also refer to these technologies.

6.2 Types of cookies used

We use the following types of cookies on our portal for the following purposes:

Types of cookies Purpose For how many months does the cookie stay on your browser?

Strictly necessary cookies

These cookies do what you have asked for: for example, they allow the website to load on your browser, they keep you logged in when you use our portal, and keep our portal safe. If you turn off these cookies via your browser settings certain parts of the website will not function for you.

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Functional cookies

These cookies enable the website to provide enhanced functionality and personalisation. If you do not allow these cookies then some services may not function very smoothly. These kinds of cookies remember things like your sound settings.

Session

Analytics/Performance cookies

These cookies help us understand how you use our portal and improve or optimise the experience we provide. This can be anything like which pages you go to most often, and if you get error messages from web pages. They allow us to measure how visitors interact with the portal (for example which parts of the website are clicked on and the length of time between clicks).

We use third-party web analytics software on our portal (Google Analytics and Mouseflow). We provide further information about these partners below.

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6.3 Third party cookies

We do not allow third party advertising, or affiliation on our portal.

As we explain above, we work with other companies to use analytics cookies on our portal: these are Google, who provide Google Analytics cookies, and Mouseflow. We explain in more detail below what information they collect and how it is used.

Google Analytics. Our portal uses Google Analytics, which is provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyse how users use our portal. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By accepting analytics / performance cookies on our portal, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Mouseflow. We also use Mouseflow on our portal; this provider offers a website analytics tool that helps us understand how our portal is used, and which areas are mostly used (e.g. by using heatmaps or by replaying your journey on our portal). Mouseflow uses cookies to record information such as when you click on or move your mouse, when you scroll, or press a key, what pages you visit on our website, how much time you spend on each page, and also information about the device you use (operating system, device type (desktop/tablet/phone), screen resolution, location (city/country), language, and similar metadata). Mouseflow does not collect any information on pages where it is not installed, nor does it track or collect information outside your web browser.

6.4 Managing and disabling cookies

We make available a cookie management platform on our portal (provided by OneTrust), through which you can turn off non-essential cookies at any time. Please note, strictly necessary cookies will always be set as they are essential for our website to operate.

You can change your cookie preferences or withdraw consent by clicking on the following button:


7. Sharing your personal information with other persons
  • We share your personal information with our employees, to the extent this is necessary for them to perform their tasks, and with members of our group of companies, for the purposes set out in this Policy.

  • We also share some limited information with third party service providers (as explained below) – these are companies that help us provide the portal to you, and they also help us to do all the actions that we describe in this Policy. When we trust our service providers with your information, we require them 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 information for specified purposes and in accordance with our instructions. We use the following types of service providers:

IT, email and web service providers

We share your personal information with our IT, email and web service providers, in order to enable them to provide us with their services. For example, we share your name and email address details with DotDigital, a service provider used for the purposes of sending emails to our users (such as newsletters, collecting feedback, or any important service related emails). This data sharing enables us to send you emails, view when they are opened and view which links are clicked.

Surveys, support and feedback providers

Freshdesk is our third party customer support tool that enables customers to contact us through a ticketing system on the website.

For more information on Freshdesk’s Privacy Notice, visit https://www.freshworks.com/privacy/.

For more information on Freshdesk and GDPR, visit https://freshdesk.com/gdpr.

We will occasionally ask for feedback on our portal. We will usually do this via an email which will direct you to our survey provider, UsabilityHub. It will only record; time spent, country, device type, device platform, unless specifically asked within the questions themselves for example, the survey may ask your age. You can find out more about UsabilityHub here.

  • If our business or part of our business is sold to another company, typically customer information would be transferred to that company. However, that company would still need to comply with this Privacy Policy and treat personal information as described in this Privacy Policy.

  • Where necessary, we share personal information with our business advisors, such as legal advisors, consultants, accountants or auditors, for the purposes outlined in this Policy.

  • In the event of a legal dispute, a court order or a legitimate request from a law enforcement agency or other public authority, we will share your personal information with our legal advisors, courts or such public authority, as necessary.


8. How long will we keep your personal information?

We will only retain your personal information for as long as you have an active account, unless we need to retain this information for longer, after your account is deactivated, in order to protect our legal interests and establish, exercise or defend a legal claim. If you deactivate your account, we may anonymise your information and use it for a period of time in an anonymous format for research and other business purposes, such as business analytics.

For users that have registered but whose accounts are inactive, we will delete your personal information after 3 years of inactivity.


9. Your rights

Under data protection laws, you have certain rights in relation to your personal information, which you can exercise free of charge. In summary, those include the right to:

  • request a copy of your personal information and to certain other extra information that this Privacy Policy is already designed to address;

  • require us to correct any mistakes in your information which we hold;

  • require the erasure of personal information concerning you in certain situations;

  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format (e.g. in pdf or .csv format) and have the right to transmit those data to a third party in certain situations;

  • object (say no) at any time to processing of personal information concerning you for direct marketing;

  • object (say no) in certain other situations to our continued processing of your personal information;

  • otherwise require us to only store but not use your personal information in certain circumstances;

  • where you have given your permission for us to use your information, to change your mind at any time.

Please note these rights may be limited, for example if fulfilling your request would reveal personal data about another person or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of the relevant exemptions upon which we rely when responding to any request you make.

If you would like to exercise any of those rights, please:

  • email our Data Protection Officer at privacy@ocado.com;

  • let us have enough information to identify you (e.g. username, full name and email address); and

  • let us know (if possible) the information to which your request relates.

If you would like to unsubscribe from any email newsletter or other promotional emails, you can click on the unsubscribe link which you can find at the bottom of our emails, in order to be removed from our mailing list. It could take up to 72 hours to process the update through our systems.


10. Keeping your personal information secure

We have security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those persons who have a genuine business need to know it and we require them to keep it confidential.

We enable Teachers to use two-factor authentication to further reinforce the security of their accounts and we encourage them to do that. You can find more details here.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.


11. How to complain

We hope that we or our Data Protection Officer can resolve any query or concern you raise about this Privacy Policy or how we use your information.

Alternatively, you also have the right to lodge a complaint with a data protection authority, in particular in the UK and/or the and/or the European Union (or European Economic Area) country where you work, normally live or where any alleged infringement of data protection laws occurred. The data protection authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: +44 303 123 1113.


12. Changes to this Privacy Policy

This Privacy Policy was last updated on 3rd September 2021.

We may change this Privacy Policy from time to time and you should check it regularly. If we make any material changes to this notice we will inform via appropriate means (e.g. email).


13. How to contact us

Please contact our Data Protection Officer or us at privacy@ocado.com if you have any questions about this Privacy Policy or the information we hold about you.


14. Do you need extra help?

If you would like this Policy in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).