Privacy Policy

Introduction

This Privacy Policy details how we, Homegrown Learning Limited of The Workbox Penzance, Wharf Rd, Penzance TR18 4FG, collect, use, and process personal data provided to us. If you have any questions on this Privacy Policy or otherwise relating to how we process your personal data, you can contact us at hello@collageapp.co.uk.

This Privacy Policy affects your legal rights and obligations, so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide any personal data to us.

We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any changes to it.

We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.

Non-Disclosure to Government Entities

At Homegrown Learning Limited, we prioritize the privacy and security of your personal data and the personal data of your children. We want to reassure you that all media you upload (such as photos, videos, etc.) is stored securely with encryption, ensuring it is accessible only to you. It will never be shared with or reported to any government agency or similar entity by Collage App or Homegrown Learning Limited.

Additionally, all media that you upload (such as photos, videos, etc.) is stored securely in servers that cannot be accessed by us or anyone else. It is encrypted, meaning all media is only viewable in your account by you. No one from Collage App can view, edit, or download your media at any time.

Our commitment to your privacy means:

• We do not disclose your personal data, or your children's personal data, to any government bodies or law enforcement agencies, unless compelled by a legal obligation.
• All user-uploaded media is encrypted and stored securely, ensuring it is accessible only to you.
• Any request for data sharing with government entities will be communicated to you, and your consent will be sought where applicable.

We understand the importance of maintaining the confidentiality of your homeschooling information and are dedicated to protecting it. If you have any concerns about your privacy, please contact us at hello@collageapp.co.uk.

Whose Personal Data Do We Collect?

By personal data, we mean identifiable information about you, such as your name, email address, gender, age, mobile and home telephone number, and your IP address.

Information You Provide to Us

From time to time you may provide to us with personal data. This may be because you wish to:

• Use any of our websites;
• Register an account on our Collage App platform, and subsequently upload personal data within your account, including personal data about children identified within your Account;
• Register to receive marketing information from us;
• Provide services to us;
• Otherwise contact us including with queries, comments, or complaints.

You may provide personal data to us directly, or to us through our social media platforms.

We shall process all such personal data in accordance with this Privacy Policy. Certain personal data is mandatory to be provided to us in order that we can fulfill your request, for example, to register an account on our Collage App platform, and we shall make this clear to you at the point of collection of the personal data.

If you have an account on our Collage App platform, you may provide to us personal data about children, that is, individuals under the age of 18. If you do not have parental responsibility for those children, you must have written permission from an individual who does have parental responsibility to provide us with personal data. You must provide us with a copy of that written permission on our request.

All personal data that you provide to us must be true, complete, and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this, and we may also report this to the appropriate authorities.

At our request, you shall promptly provide evidence of your identity.

When you contact us by email or post, we may keep a record of the correspondence, and we may also record any telephone call we have with you.

Information We Automatically Collect About You

When you use our website, we automatically collect and store information about your device and your activities. This information could include:

• Technical information about your device, such as type of device, web browser, or operating system;
• Your preferences and settings such as time zone and language;
• How long you used the website and which services and features you used.

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy available on the website you visit.

Information We Receive from Others

If you have an account on our Collage App platform, we may receive personal data about you from our security service partners and our payment providers if they choose to provide it to us for any reason.

If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, confirming or otherwise, your identity.

Lawful Use of Your Personal Data

We will only use your personal data where we have a lawful basis to do so. The lawful purposes that we rely on under this Privacy Policy are:

• Consent (where you choose to provide it);
• Performance of our contract with you;
• Compliance with legal requirements; and
• Legitimate interests. When we refer to legitimate interests, we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom, or interests.

If you wish to access and use our Collage App platform, we shall use your personal data and the personal data of any children identified on your account to register and manage your account in accordance with our Terms of Use.

We may from time to time need to use your personal data to comply with any legal obligations, demands, or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety.

In certain circumstances, we may be required by law to disclose your personal information to third parties such as government bodies, law enforcement agencies, and data protection regulators.

However, please note that all media you upload (such as photos, videos, etc.) is stored securely in servers that cannot be accessed by us or anyone else. It will never be shared with or reported to any government agency or similar entity by Collage App or Homegrown Learning Limited. It will be exclusively your decision whether or not to share your personal data with them from your account.

Who Do We Share Your Data With?

For our legitimate interests, we may share your personal data with our service providers, sub-contractors, and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers or payment providers.

Where We Hold and Process Your Personal Data

Some or all of your personal data may be stored or transferred outside of the UK or the European Economic Area (the EEA) for any reason, including, for example, if our email server is located in a country outside the UK or EEA or if any of our service providers are based outside of the UK or EEA.

Where your personal data is transferred outside the UK or EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data – for example, by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).

Security

We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and strong encryption electronic measures within our electronic data management systems.

However, unfortunately, because of the nature of electronic storage, we cannot promise that your personal data or any other data you provide to us will always remain secure. If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimize the loss of any data.

Marketing

You may consent to receive marketing email messages from us about the services we offer and our Collage App platform. To be clear, though, we will not knowingly send marketing email messages to a child.

You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.

If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send you marketing information. We will still contact you as necessary about your account on our Collage App platform, if you have one.

Your Rights

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here.

• Right of Access: You have the right to obtain from us a copy of the personal data that we hold for you.
• Right to Rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete, or out of date.
• Right to Portability: You can request that we transfer your personal data to another service provider.
• Right to Restriction of Processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information.
• Right to Be Forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws, although if you are a child we will always delete your personal data following a request to do so.
• Right to Stop Receiving Marketing Information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to your account on our Collage App platform.

We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You can also contact the Information Commissioner, see www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local regulatory authority.

Retention of Personal Data

Subject to the provisions of this Privacy Policy, we will retain personal data in accordance with applicable laws, and in any event for the duration of your account with us.

However, we may also be required to retain personal data for a particular period of time to comply with legal, audit, or statutory requirements, including requirements of HMRC in respect of financial documents.

Data Minimization

We ensure that we only collect and process the personal data that is necessary for the purposes for which it is collected. We regularly review our data collection practices to ensure that we adhere to this principle of data minimization.

User Support

If you need any assistance with your account or have any concerns about how we handle your personal data, you can contact our support team at hello@collageapp.co.uk. Our team is available to help with any issues related to your account and data privacy.

Updates to T&C

We reserve the right to update these Terms and Conditions (T&C) from time to time to reflect changes in our services, legal requirements, or other operational needs. If we make significant changes to the T&C, we will provide you with at least 14 days' notice before the new terms take effect. We will notify you via email and by posting a notice on our website. Continued use of our services after the changes have taken effect will constitute your acceptance of the new terms.

Updated Feb 2025