VUWBO (We) are committed to protecting and respecting your privacy.

SCOPE OF POLICY

This policy together with our end-user licence agreement as set out at www.vuwbo.com (EULA) applies to your use of:

• the VUWBO application software version 1.0, as well as of the data supplied with that software (App) available on our site (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device); and
• Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites).

This policy sets out the basis on which any personal data We collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the avoidance of doubt, this policy relates to the personal data We collect about you, rather than the data We collect from you about others.  Please refer to the EULA for more information on data protection issues arising in respect of such third party personal data.

For the purpose of the Data Protection Act 1998, the data controller is VUWBO of 39 Apperley Road, Stocksfield, Northumberland, NE43 7PQ, United Kingdom

INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:

• Submitted Information: information that you provide by filling in forms on the App Site and the Services Sites (together Our Sites), including the Device’s telephone number.  This includes information provided at the time of registering to use the App or any of the Services, subscribing to any of the Services, posting material or requesting further services.  We may also ask you for information when you report a problem with any of Our Sites.
• Additional information:
• if you contact us, We may keep a record of that correspondence;
• We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them;
• details of transactions you carry out through any of Our Sites;
• details of your visits to any of Our Sites and the resources that you access.
• Device information: We may collect information about the Device or any computer you may use to download or stream a copy of the App onto your Device, including, where available, the Device’s or computer’s unique Device identifiers, operating system, browser type and mobile network information as well as the Device’s telephone number, for system administration and to report aggregate information to our advertisers.  We may associate Device information with Submitted Information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
• Location information: when you use one of our location-enabled Services, We may collect and process information about your actual location.  Some of these Services require your personal data for the feature to work.  If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by noptifying us in writing at info@VUWBO.co.uk.
• Log information: when you use the Services or view content on Our Sites, We may automatically collect and store certain information in server logs, including but not limited to internet protocol (IP) addresses, internet service provider (ISP), clickstream data, browser type and language, viewed and exit pages and date or time stamps.
• Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

COOKIES
Our Sites may from time to time use cookies to distinguish you from other users of Our Sites.  This may help us to provide you with a good experience when you use the App or browse Our Sites and also allows us to improve the App and Our Sites.  For detailed information on the cookies We use and the purposes for which We use them, see the cookie policy on our website: www.VUWBO.co.uk.

WHERE WE STORE YOUR PERSONAL DATA
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA).  It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.  These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services.  By submitting your personal data, you agree to this transfer, storing or processing.  We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where We have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential.  We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure.  Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk.  Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

USES MADE OF THE INFORMATION
We use information held about you in the following ways:

• Submitted Information: The information gathered on lesson observation will automatically be sent to VUWBO.  When you purchase the App without also purchasing a full subscription to the VUWBO online service (Subscription) this information will be anonymised but will be attributable to your organisation.  When you purchase the App and also purchase a Subscription, this information will not be anonymised as well as being attributable to your organisation.  The information will be used to research trends in teaching and learning across all users.  Furthermore the identification of your organisation, should you purchase a Subscription, will allow you to produce reports using information collected on multiple Devices. Submitted Information will also be used to improve the service we provide to our users.
• Additional information: Contact information which you provide will be used to inform you of related products and services we consider useful to you.
• Device information:  This will be gathered so that subscribers using multiple devices can analyse all data collected relating to their organisation. We may also use this information to provide targeted information to our advertisers.
• Location information:  This will be used to examine geographical trends in quality of teaching and learning.
• Log information: This will be used to inform multi-platform development and use.
• Unique application numbers: to monitor use of this App.

We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services that may be of interest to you. We or they may contact you about these by post or telephone.

If you are an existing customer, We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those that were the subject of a previous sale to you.

If you are a new customer, and where We permit selected third parties to use your data, We (or they) will contact you by electronic means only if you have consented to this.

If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which We collect your data.

DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may disclose your personal information to third parties:

• In the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets.
• If We are acquired by a third party, in which case personal data held by VUWBO about its customers will be one of the transferred assets.
• If We are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
• In order to:
• enforce or apply the EULA or to investigate potential breaches; or
• protect the rights, property or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes.  We will usually inform you (before collecting your data) if We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes.  You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your data.  You can also exercise the right at any time by contacting us at www.vuwbo.com.

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised).  If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

ACCESS TO INFORMATION
The Data Protection Act 1998 gives you the right to access information held about you.  Your right of access can be exercised in accordance with that Act.  Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information We hold about you.

CHANGES TO PRIVACY POLICY
Any changes We may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or by notifying you of a change when you next start the App or log onto one of the Services Sites.  The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to www.vuwbo.com