App Privacy Policy

Privacy Policy for WesteringsPLUS Mobile Application

This Privacy Policy explains how LIFT Westerings (referred to as "the school", "the Trust," "we," "us," or "our") collects, uses, maintains, and discloses information collected from users (referred to as "you" or "users") of the WesteringsPLUS mobile application (the "App"). This policy aligns with our Trust's commitment to data protection and adheres to Apple's and Google Play's Developer Policy Center requirements, particularly concerning user data and children's privacy.

1. Introduction and Data Controller

The School and The Trust are committed to protecting the privacy and security of your personal information. This Privacy Policy sets out how we handle your data when you use our App.

For the purposes of the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, the data controller is LIFT Schools Trust, with address: 3rd Floor, 1EdCity Walk, EdCity, London W12 7TF. We are registered with the Office of the Information Commissioner under registration number Z1457960.

2. Information We Collect

We collect information to provide and improve our services to you through the App. The types of information we may collect, depending on the App's functionality and your interaction with it, include:

Contact Details: Such as names, email addresses, and phone numbers, primarily for communication purposes (e.g., sending notifications, responding to inquiries).
Demographic Information: Such as preferences, and interests, if collected via in-app surveys or engagement features.
App Usage Data: Anonymous traffic log statistics and analytics to understand how the App is used, which features are popular, and to identify areas for improvement. This data is aggregated and does not personally identify you.
Information relevant to surveys and/or stakeholder engagement: If the App includes features for feedback or participation in school-related initiatives.
Information required for processing purchases/bookings (via Wix payments platform).
User-generated content: Any information you voluntarily submit within the app, such as messages, feedback, or entries to school-related activities.

We adhere to the principle of data minimisation: We only collect information that is necessary for the stated purposes of the App's functionality and to provide the services you expect.

3. How We Use Your Information

The information we collect is used for the following purposes:

To provide App functionality: To enable the features and services offered by the App.
To improve our services to you: By analysing anonymous usage data, we can enhance the App's performance, user experience, and content.
To undertake stakeholder engagement: If the App facilitates communication for school-related projects or feedback.
To send information that you have requested: For example, notifications about school events, news, or updates, if you have opted in to receive them.
To communicate matters relating to the Trust/School to you: For official announcements or important information.
To safeguard you, our pupils, and other individuals: Where necessary and legally permissible.
To respond to your inquiries and provide support: If you contact us through the App or related channels.

We will not contact you through the App unless you have specifically requested that we do so or it is necessary for the core functionality of the App (e.g., essential school updates).

4. How We Share Your Information

We are committed to not selling, distributing, or leasing your personal information to third parties. We will only share information about you in the following circumstances:

With your explicit consent: Where you have given us permission to do so.
Where required by law: If we are legally obliged to disclose information (e.g., to law enforcement agencies or regulatory bodies).
Where our internal policies allow us to do so: This may include sharing with other entities within the LIFT Schools Trust for legitimate educational or administrative purposes, always in compliance with data protection laws.
With service providers: We may use third-party service providers such as Wix (e.g., for analytics, push notifications) to help us operate our business and the App or administer activities on our behalf. These providers are contractually bound to protect your data and use it only for the purposes for which we disclose it to them, and in compliance with Apple/Google Play Developer Policies. We ensure any third-party SDKs integrated into the App comply with all applicable policies, especially for child-directed services.

5. Data Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, our provider (Wix) have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect through the App. All personal and sensitive user data collected by the App is transmitted using modern cryptography (e.g., over HTTPS) to ensure secure handling.

6. Data Retention

We retain collected information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Once data is no longer required, it will be disposed of securely.

7. Your Rights

Under the GDPR, you have certain rights regarding your personal data. These include:

Right to Access: You may request details of personal information which we hold about you.
Right to Rectification: If you believe that any information we are holding on you is incorrect or incomplete, please contact us as soon as possible. We will promptly correct any information found to be incorrect.
Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your personal data.
Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data.
Right to Data Portability: You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format.
Right to Object: You have the right to object to our processing of your personal data in certain circumstances.

Account Deletion: If the App allows for user accounts, we provide an in-app option for you to request the deletion of your account and associated data. A dedicated web link for account deletion will also be available [Insert Link to Web Account Deletion Page if applicable, otherwise state 'upon request via contact details below']. When you request account deletion, we will delete your personal data associated with that account, unless we need to retain certain data for legitimate reasons such as security, fraud prevention, or regulatory compliance. We will clearly inform you about any such data retention practices.

8. Children's Privacy

Our App is primarily directed at families of Westerings and is intended for use by students, parents, and staff of Westerings. We are committed to complying with all applicable laws and regulations regarding children's online privacy, including the GDPR.

We do not knowingly collect personal information from children under the age of 13 without parental consent, unless permitted by law.
If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will take steps to delete that information as quickly as possible.
We ensure that any third-party SDKs or services used within the App are approved for use in child-directed services.

9. Third-Party Links and SDKs

Our App may contain links to other websites or services of interest. However, once you have used these links to leave our App, you should note that we do not have any control over that other website or service. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website or service in question.

We integrate third-party code (SDKs) only if they comply with Apple/Google Play Developer Programme Policies and our own privacy standards. We ensure transparency regarding any data collected by these SDKs.

10. In-App Disclosure and Consent

In compliance with Apple/Google Play policies, where the App accesses or collects personal and sensitive user data, we will provide an in-app disclosure. This disclosure will:

Be visible in the App itself, not only in the App description or on a website.
Be displayed in the normal usage of the App and not require you to navigate into a menu or settings.
Clearly describe the data being accessed or collected.
Explain how the data will be used and/or shared.

Any requests for in-app user consent and runtime permission requests will be immediately preceded by such an in-app disclosure. Consent will be obtained through a clear and unambiguous dialogue requiring affirmative user action (e.g., tapping "Accept" or ticking a checkbox) and will not be inferred from navigation away from the disclosure.

11. Data Safety Section (Google Play Console)

We will complete a clear and accurate Data Safety section for this App in the Google Play Console, detailing our collection, use, and sharing of user data. This section will reflect the information provided in this Privacy Policy and will be kept up to date.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new Privacy Policy within the App or on our website. You are advised to review this Privacy Policy periodically for any changes.

13. Contact Us

If you have any questions about this Privacy Policy, our data practices, or your rights, please contact us:

Email: contactus@liftschools.org

Address: 3rd Floor, 1EdCity Walk, EdCity, London W12 7TF

Phone: 020 3947 5700

This policy is subject to regular review by the school.