Introduction

This privacy policy (the “Policy”) will inform you as to how we look after your personal data when you visit our websites www.epraise.co.uk, www.epraise.com.au, and/or www.epraise.us (collectively, the “Website”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Policy also applies to personal data that is automatically collected about your mobile device (“Device”) when you download the Epraise mobile application software (the “Apps”) hosted, respectively, on the iOS App Store or the Google Play App Store (the “App Site”). 

Because we offer our services on a global basis, we have chosen to use the UK and European Union (GDPR) model, often considered the strictest model for user transparency, as the format for this Policy. Consequently, based on the privacy and data protection laws that apply in the location from which you access our Website or download our Apps, you may not necessarily understand the meaning of some of the terms used in this Policy, we refer you to our Glossary of terms at the end of this Policy to help you make better sense of this document.

This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary at the end of this document to understand the meaning of some of the terms used in this privacy policy.

1. Important Information and Who We Are
2. The Data We Collect About You
3. How is Your Personal Data Collected?
4. How We Use Your Personal Data
5. Disclosures of Your Personal Data
6. International Transfers
7. Data Security
8. Data Retention
9. Your Legal Rights
10. Glossary

1. Important Information and Who We Are

Purpose of this Policy

This Policy aims to give you information on how Epraise collects and processes your personal data through your access and use of this Website or when you download our Apps, including any data you may provide through the Website when you write to us to book a demo or order our services, when you call us for support, send us an email or fill out our contact form to receive more information about our services.

This Policy does not apply to any personal data processed in connection with the services that we provide through our platform and Apps (collectively, our “Services”) to our clients, educational or other institutions (our “Customers”). To understand how we look after your personal data when providing you with our Services through our platform and Apps, please consult our Epraise Product Privacy Policy. 

In our processing of personal data in connection with Services we provide to our Customers, we act as a data processor under applicable data privacy laws, and in that context our Customers act as data controllers on behalf of which we process data for purposes of the Services. When we act as data processor, our processing of data on behalf of our Customers isn’t governed by this Policy but by our Data Processing Agreement or other data processing terms in place between Epraise and each Customer. For more information on our processing as a data processor, please contact the educational or other institution that collected your personal data in connection with the Services.

By accessing and using our Website or downloading our Apps, you agree that you have read and understand this Policy and you consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Policy. Please read carefully this Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you understand how we collect, share, and protect your information. This Policy supplements other notices and privacy policies and is not intended to override them.

Controller

Epraise Limited is the controller and responsible for your personal data (collectively referred to as “Epraise”, “we”, “us” or “our” in this Policy).

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our DPO using the details set out below:

c/o Firefly Learning Ltd
167-169 Great Portland Street, 5th Floor
London, United Kingdom, W1W 5PF
Email: privacy@epraise.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). 

If you are based in Australia, you may contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au).

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Children

Our Website is not intended for children, and we do not knowingly collect data relating to children. 

Changes to the Policy and Your Duty to Inform Us of Changes

We keep our Policy under regular review. This version was last updated on December 6, 2024. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

Our Website may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every other website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

1. Identity Data includes first name, last name, username or similar identifier.
2. Contact Data includes email address and telephone numbers.
3. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the devices you use to access this website, error reports, and performance statistics.
4. Device Data includes the type of device you use, a unique device identifier, network information, your operating system, the type of mobile browser you use, your device configuration, and other similar information.
5. Profile Data includes your interests, preferences, feedback and survey responses.
6. Usage Data includes information about how you use our website, products and services.
7. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
8. Employment and Education Data includes job and education history, degrees obtained, resumes and/or CVs, and related information.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, consider your application for a position with our company).

3. How is Your Personal Data Collected?

We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your Identity and Contact Data by visiting the Website or by corresponding with us by post, phone, email or otherwise. This also includes personal data you provide when you:

• Download or install one of our Apps
• Request marketing to be sent to you
• Sign up for our Services
• Enter a competition, promotion or survey
• Give us feedback or contact us
• Apply for a job with Epraise

Automated technologies or interactions. As you interact with our Website or download our Apps, we will automatically collect Device and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookies section for further details.

Third parties. We will receive personal data about you from various third parties as set out below:

• Technical Data from analytics providers, such as Google based outside the UK
• Device Data from App Site providers, such as Apple and Google based outside the UK
• Identity and Contact Data from our affiliated companies within the Veracross Group based in the UK, Australia, and the U.S.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to comply with a legal obligation

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. For more information about the legal bases we rely on to process data under the GDPR, please see our Glossary below.

Purposes for Which We Will Use Your Personal Data

We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified, for our users in the UK and the EU, what our legitimate interests are where appropriate.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers from Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any external third parties for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a Service experience or other transactions.

Cookies

We use cookies and other tracking technologies to distinguish you from other users of the Website, Apps, App Site, or the distribution platform (Appstore). This helps us to provide you with a good experience when you use the Website or download our Apps, and it also allows us to improve our Website and Apps.

We also use cookies or similar technologies to analyse trends, administer the Services, Apps, and Website, track our users’ movements around the Services, Apps, and Website, and to gather demographic information about our Services, App and Website userbase as a whole.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. 

For more information about the cookies we use, please see our list of cookies here.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data  above.

• Internal Third Parties: other companies in the Veracross Group acting as joint controllers and who are based in the UK, Australia, and in the U.S. and provide IT and system administration services, sales and marketing services, technical services, and undertake leadership reporting.

• External Third Parties, as follows:

  • Service providers. We or our affiliates of the Veracross Group may share your personal data with the following service providers:
  • Amazon Web Services (AWS), based in the EU and acting as processors which provide hosting, infrastructure, and storage services using your personal data
  • Apple and Google, based in the United States and acting as processors, which provide apps and analytics services using your personal data
  • Mailgun, based in the United States with data stored in the US and EU, and acting as processors, which provides email and analytics services using your personal data
  • Zendesk, Marketo, Survey Monkey, and Salesforce, based in the United States, and acting as processors, which provide communications and analytics services using your personal data
  • Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the UK and in the United States, who provide consultancy, banking, legal, insurance and accounting services
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets

6. International Transfers

We share your personal data within the Veracross Group. This will involve transferring your data outside the U.K., Switzerland, and the European Economic Area (EEA)

Many of our external third parties are based outside the UK, Switzerland, and the EEA so their processing of your personal data will also involve a transfer of data outside the UK, Switzerland, and the EEA.

Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK, Switzerland, and the EEA which give personal data the same protection it has in the UK, Switzerland, and the EEA.  For further details, see UK International data transfer agreement and guidance

Please also note that our U.S. parent company, Veracross LLC, and its U.S. subsidiaries Magnus Health, LLC and Digistorm, LLC participate in and have certified their compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as administered by the U.S. Department of Commerce, with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Veracross LLC and its U.S. subsidiaries have also certified to the U.S. Department of Commerce that they adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view the Veracross certification, please visit https://www.dataprivacyframework.gov/

Veracross LLC, Magnus Health, LLC, and Digistorm, LLC are responsible for the processing of personal data they receive, under the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, and subsequently transfer such personal data to a third party acting as an agent on their behalf. Veracross LLC and its U.S. subsidiaries comply with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, the UK, and Switzerland, respectively, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over Veracross LLC’s, Magnus Health, LLC’s and Digistorm, LLC’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, Veracross LLC, Magnus Health, LLC, and Digistorm, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Veracross LLC, Magnus Health, LLC, and Digistorm, LLC commit to resolve DPF Principles-related complaints about their collection and use of your personal data. EU and UK individuals and Swiss individuals with inquiries complaints regarding our U.S. affiliates’ handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact us at privacy@epraise.co.uk. 

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Veracross LLC, Magnus Health, LLC, and Digistorm, LLC commit to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our U.S. affiliates’ handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

For complaints regarding EU-U.S. DPF, Swiss-U.S. DPF, and UK Data Bridge compliance not resolved by the EU, Swiss, or UK IRM panel, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.

Canadian Residents

Please note that we may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

Australian Residents

Please note that we may disclose your personal information to recipients which are located outside Australia. Those recipients are likely to be located in the UK and the United States.

7. Data Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. 

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Our website may occasionally contain links to other websites. Please note that these websites are outside our control, and we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites.

For the most up-to-date Epraise data security measures, see our Trust Centre.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

You can find more information about our data retention policies by emailing privacy@epraise.co.uk.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

U.S. Residents: Your State Privacy Rights

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:
  • targeted advertising (excluding Iowa);
  • sales; or 
  • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal information. 

The exact scope of these rights may vary by state. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit Website Privacy Policy for California Residents.

To appeal a decision regarding a request to exercise your rights with respect to your personal data please send an email to privacy@epraise.co.uk, specifying the nature of your rights affected by the decision and your arguments in support of the appeal, and include a copy of the decision, along with any supporting documentation, and the best phone number and email address to reach you back on. We’ll review your appeal and revert to you with our decision as soon as possible.

Canadian Residents

Rights of users located in Canada are governed by the Personal Information Protection and Electronic Documents Act , S.C. 2000, c. 5, the Personal Information Protection Act , R.S.A. 2003, c. P-6.5, the Personal Information Protection Act , R.S.B.C. 2003, c. 63 and an Act respecting the protection of personal information in the private sector , CQLR, c. P-39.1, as amended by Law 25, An Act to modernize legislative provisions as regards the protection of personal information (as applicable based on the location of the user in Canada).

Since the adoption of Law 25, Quebec residents have enhanced rights with respect to their personal information, including: 

• Access Rights: the right to receive confirmation of the processing of their personal information, of the nature of the information being processed, and to receive a copy of it.  
• Data Portability Right: the right, subject to certain exceptions, to ask that the processing organization communicate to them computerized personal information in a written, intelligible transcript, and any collected personal information in a structured, commonly used, technological format.
• Rectification Right: subject to certain requirements and exceptions, the right to ask to correct the information in the processing organization’s possession t is inaccurate, incomplete, or ambiguous, or if collecting, communicating, or keeping it is not authorized by law. 
• De-indexation Right or "Right to be Forgotten": the right to ask organizations to stop disseminating their personal information or to de-index any hyperlink attached to their name giving access to information if this dissemination causes them harm or contravenes the law or a court order.
• Automated Decision Making: the right to be informed when they are the subject of a decision based exclusively on automated processing of their personal information. Organizations must also, on request, inform them about the personal information used to make the decision, the reasons and main factors leading to the decision, and the right to request correction of the personal information used to make the decision. They must also be given the opportunity to present their observations to a member of their staff for review of this decision. 

Exercising Your Data Subject Rights

The following section only applies to you if we collect and process your personal data directly and for our own purposes, not on behalf of our Customers for purposes of the Services we provide to you on their behalf. If we collect and/or otherwise process your information this section does not apply to you and we ask that you please direct any request to exercise your data subject rights to the Customer on behalf of which we process your personal data for purposes of our Service. 

You may exercise your data subject rights by contacting us at privacy@epraise.co.uk. 

Individuals who submit requests to exercise data subject rights will be required to verify their identity by answering certain questions. We cannot process data subject rights requests until your identity is verified. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you are making a request for access, we may not be able to provide specific pieces of personal data if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your personal data, your account with us, or our systems or networks.

If you are making a request for erasure of personal data, we will ask that you confirm that you would like us to delete the personal data again before your request is processed.

You may designate an authorised agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.

Agents who make requests on behalf of individuals will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorisation is verified.

If you are seeking to access, correct, or delete information on our Services, we may refer your request to the Customer on whose behalf we process your personal data for purposes of our Services.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Legal Bases

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 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.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your Personal Information where it is necessary for compliance with a legal obligation that we are subject to.

Consent means any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of Personal Information relating to you.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object, where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.