The Brainery Privacy Policy (the “Policy”)

This Policy sets out what personal data The Brainery Limited (“the Brainery”) collects online and how we use it. Please review it closely.

The Brainery is committed to being transparent about how it collects and uses the personal data of its clients (and others) and to meeting its data protection obligations. This policy sets out the organisation’s commitment to data protection, and individual rights and obligations in relation to personal data. 

By using our website - www.thebrainery.co.uk -  (the “Site”) you consent to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy please do not use the Site.

The Brainery is a data controller (i.e. the entity responsible for the processing of your personal information) in respect of all of the information which we collect and receives about you when visit our Site.

The Brainery is bound by, and uses your personal information in accordance with the General Data Protection Regulation 2016 (“GDPR“).

1. How we collect your information

We collect your information directly from you through our website, i.e. the “chat with us” form, through email communications, through job applications submitted on third party websites (IE, Indeed.co.uk( and through non-electronic transmission methods. 

2. Information we may hold about you and uses of your information

The Brainery collects two types of information from you: (I) personal information, and (II)

non-personal information:

I. Personal information is information that identifies you or can be used to identify you personally such as your name or your email address.

II. Non-personal information is information that does not identify you and can’t be used to identify you personally.

As a tuition provider, The Brainery is responsible for the personal information it handles in order to deliver our service. This information is only used for delivering tuition and for safeguarding purposes.

The kind of information we hold varies, depending upon whether you, and your child, are clients of The Brainery, or whether you are just visiting the site or whether you are prospective tutor wishing to join the brainery. More detailed information on this is below. 

When your child becomes a student at The Brainery, we will collect and process the following data from you:

• Parents/Guardians’ names, email addresses and contact phone numbers

• Emergency contact’s names and phone numbers

• Child/ren’s name, age, date of birth and school

• Information about any medical conditions, allergies or Special Educational Needs of child/ren

3. How we will use your information

We need the above categories of information primarily to allow us to perform our contract with you and to enable us to comply with contractual obligations towards you. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. In rare cases, we may also use your information in order to comply with any legal requirements The Brainery must meet. 

The situations in which we will process your personal information include:

• For the purpose of delivering tuition and for improving that tuition service;

• For the purposes of considering your suitability to work as a tutor for the Brainery;

• To safeguard students’ health and welfare and provide appropriate pastoral care;

• For the purposes of management planning; and 

• On rare occasions, to escalate and investigate safeguarding concerns.

You have the option of allowing us to use your child’s photo for the purpose of promoting The Brainery. Explicit consent will be sought from you before doing so and may be withdrawn at any time. 

4. Legal bases for holding information

We will use your personal information in accordance with the consent you have provided to us, or on the following bases:

● Legitimate business interest - We will process your personal data to pursue our legitimate interests in a way which you would reasonably expect and without any material impact on your freedom and rights.

● Legal compliance – We will process and store your personal data when we are required to do so by law.

● Contract– We will process and store your personal data when doing so is necessary in order to fulfil our contractual obligations either with you or third parties.

Unless you withdraw your consent (see point 5), we will keep your information for as long as is necessary for the purpose for which it is collected or used. The actual time will depend on the type of relationship you have with us, the nature of the data and the purpose for which it is used. 

However, we will periodically review all data to ensure our records are accurate and up-to-date and delete any data no longer required for our legitimate interests or any other purpose (such as for legal compliance) after 7 years. Please also keep us informed if your information is no longer accurate or up-to-date.

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.

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. You have certain choices about how we use your information

In line with the GDPR, when the Brainery processes your personal data you have the right to request:

- Access, deletion of or correction of your personal information

- Your personal information be transferred to another person

If you wish to exercise these rights or have any questions or complaints about this Policy or any privacy concerns, please contact jason@thebrainery.co.uk. Please do not include your credit card number or other financial or sensitive information in your email.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

If you wish to withdraw any consent you have provided to us, to amend any information we hold about you or to request copies of the information we hold about you please write to us at jason@thebrainery.co.uk

In addition to the above rights, you have the right to make a complaint to us about the use of your personal information if you feel we have been intrusive to your privacy or misused your data or complain to the regulator (see https://ico.org.uk/make-a-complaint/).

6. We may share your information with the following third parties

In line with the GDPR, we may share your information (see 2 (ii) above) with the following third parties in line with our legal and contractual obligations:

○ To contracted tutors the Brainery uses to deliver lessons;

○ To anyone you request us to disclose information to (IE school teachers)

In the event that we are required to share any sensitive information with those parties, we will ensure that you are informed in advance.

The Site is hosted by SquareSpace. Any personal information published on our website is transferred to SquareSpace.

7. We use standard security measures

In accordance with GDPR (art. 32) we have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk. That is, the standard security measures we use will depend on the type of information collected. However, the Internet is not 100% secure. We cannot promise that your use of our sites will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords.

8. We may (although rare do) link to third party sites or services we don't control

If you click on one of those links, you will be taken to websites we do not control which may allow third parties to collect or share data about you. This Policy does not apply to the privacy practices of those websites. Read the privacy policy of other websites carefully. We are not responsible for these third party sites.

9. Cookies

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 this website may become inaccessible or not function properly.

Date: 28 August 2023