DATA CONTROLLER:
KCO Commercial Limited trading as King’s College Online, 
Address: Sixth Floor, 3 Burlington Gardens, London, W1S 3EP, United Kingdom
Company number: 12923482
King’s College Online is part of Inspired Education Holdings Ltd., which is a company registered in United kingdom with number 09268120 and registered address at Sixth Floor, 3 Burlington Gardens, London, W1S 3EP. Inspired operates numerous affiliated schools globally via its regional offices in Europe, Africa, Middle East, Asia-Pacific and Latin America.

1.    INTRODUCTION
This privacy policy is drafted in accordance with the terms of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Individuals with regard to the Processing of Personal Data (GDPR) and the Data Protection Act 2018.
King’s College Online provides information about how we are processing the personal data that you provide to us. 
Our Data Protection Officer can be contacted by email at the address dpo@inspirededu.com if you have any queries regarding the processing of your personal data.

2.    TYPES OF PERSONAL DATA WE PROCESS
We process personal data from our students and their families and / or legal representatives and also from our employees, candidates, suppliers, contractors, prospective customers and third parties interested in finding out more about King’s College Online within the systems controlled by the school as Data Controller. 
The personal data processed is mainly the following:
•    Register your interest / Contact Us: 
-    Name
-    Email address 
-    Phone number
-     Interested party
-    Age of student
-    Country of residence

•    Application form: 
-    Student details: Forename, surname, gender, date of birth, address, nationality, postcode, home phone number, mobile phone number
-    Parent contact details: First and last name, phone, email address, nationality, native language, address 

In these forms, information related to the level and desired year of entry, how did you hear about us and information provided in the section “Message” (your comments and / or questions) are even collected.

We also automatically collect data about your visit to our website, as described in the cookie policy.

3.   HOW WE COLLECT AND PROCESS PERSONAL DATA
King’s College Online collects information through our website forms “Application Form” and “Contact Us/ Register your interest”. 

4. LEGITIMATION FOR THE PROCESSING OF YOUR DATA
The legal basis for the processing of your data is to comply with the purpose of attending your application and queries.  
5.    PURPOSES FOR WHICH WE PROCESS PERSONAL DATA 
King’s College Online processes personal data to lawfully and legitimately carry out the school’s educational activity. The school collects and keeps students and parents’ information when necessary:
•    Recommend to the user the most appropriate educational service.
•    To ensure that the student meets the school’s admission criteria;
•    To provide educational services including the support of pupil learning, monitor, evaluation and report on pupil progress;
•    To provide to the students welfare and pastoral care services;
•    To meet the educational, social, physical and emotional requirements of the student;
•    To comply with the law regarding sharing information;
•    To comply with legislative or administrative requirements;
•    To administer the school’s governing body;
•    To enable parents/guardians to be contacted in the case of emergency or in the case of school closure, or to inform parents of their child’s educational progress or about school events, etc.
•    To inform users about everything related to the training offer published on http://www.kingscollegeonline.com/. 
•    Sending promotional electronic communications that include the most relevant news, updates and information on the website and the school educational activity if previously consented by you.
You will be able to unsubscribe from the receipt of commercial communications by clicking in the “unsubscribe” section found in all these kind of e-mails sent by the school.

Your personal data may only be communicated to other schools within the Inspired group to provide services strictly necessary for the development of its activity and with the same legitimate purposes mentioned herein.

6.  WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
King’s College Online may be required to share personal information with relevant authorities or third parties as permitted on statutory grounds, to comply with legal obligations or on the basis of a specific consent given by the individual concerned. 
We will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your personal data when disclosing your personal data to a third party. 
The parties to whom we may disclose your personal data as above referred may be located in countries outside the European Economic Area (EEA), including countries which may offer a lower level of data protection than in the EEA. In such cases, we will implement appropriate measures to ensure adequate protection of your personal data in accordance with applicable data protection legislation. 
Your personal data shall be neither rented nor sold to third parties.

7.    CONSERVATION OF DATA
The personal data provided by you will be kept as long as the relationship with King’s College Online is maintained and its deletion is not requested. Your data will be kept in accordance with the legal terms and King’s College Online internal policies. 

8. YOUR RIGHTS
Under the GDPR and Data Protection Act 2018, you have rights regarding the processing of your personal data. These rights are, however, subject to certain exemptions and limitations.
You have the right to:
•    Be informed, at the time when personal data is collected, about the data processing. 
•    Access the information we process and how we process it as well as to obtain a copy of the personal data considering the legal limitations and exceptions;
•    Ask for the erasing of the personal data we hold about you without undue delay considering the legal limitations and exceptions; 
•    Obtain the rectification of your personal data providing a supplementary statement;
•    Obtain restriction of processing of your personal data when it is inaccurate, illegal, unnecessary or not verified, considering the legal  limitations and exceptions;
•    Obtain data portability of your personal information in a structured, commonly used and machine-readable format. This allows the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided; 
•    Object to processing for direct marketing purposes;
•    Withdraw consent at any time and freely to the processing of your personal data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Therefore, data subjects will be able to exercise their rights through the procedure Subject Access Request (SAR) by sending a written specific request, and clearly indicating their petition, along with a copy of their ID card, to the DPO’s email address dpo@inspirededu.com.   
 
-    SUBJECT ACCESS REQUESTS (SAR)
According to the previous paragraph, the Subject Access Request (SAR) procedure regulates the right of the subjects to access their personal data verbally or in writing and at no charge. We have processes in place to ensure that we respond to a subject access request without undue delay and within one month of receipt although we can extend the time limit to respond to a request if necessary. We are aware of the information we must provide in response to a subject access request and the need to provide it in clear and plain language.
Any data access request is subject to certain exemptions, limitations or contractual obligations. Data belonging to or identifying other individuals is exempt from right of access and will be subject to legal privilege. We cannot disclose any confidential information related to the purpose of providing education within our group of schools, examinations or supplying examination scripts to external bodies. We cannot disclose confidential information on any of our staff.

9.    ACCEPTANCE AND CONSENT 
By providing your data to us, you declare to have been informed about the conditions on protection of personal data, accepting and consenting to their processing by King’s College Online in the manner and for the purposes indicated in this privacy policy.
You have the right to withdraw your consent at any time without prejudice of the legality of processing according to the consent given before withdrawal.


10. ACCURACY AND VERACITY OF THE DATA
As a user, you are solely responsible for the veracity and correctness of the data you send to http://www.kingscollegeonline.com/ , exonerating King’s College Online of any responsibility in this regard. Users guarantee and respond, in any case, to the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated. The user agrees to provide complete and correct information in the contact or subscription form.

11. MINORS
Students over at least thirteen (13) years of age may register at http://www.kingscollegeonline.com/  as users without the prior consent of their parents or legal guardians and without prejudice of their supervision.
In the case of minors under thirteen (13) years of age, the consent of the parents or legal guardians is required for the processing of their personal data on their behalf.
In no case will data related to the professional, economic situation or the privacy of the other members of the family be collected from the minor, without their consent.
If you are under legal age and have accessed this website without notifying your parents or legal guardians, you should not register as a user. 

12. STORING AND SECURING INFORMATION
King’s College Online shall use the appropriate technical and organisational measures to ensure the security, confidentiality, integrity and privacy of the personal data, preventing from unauthorised access or unlawful processing as well as accidental loss, destruction or damage of the files.
King’s College Online cannot guarantee the absolute impregnability of the Internet network and therefore, the violation of data through fraudulent access to them by third parties. 

13. NAVIGATION DATA
When browsing this website, non-identifiable data can be collected, which may include IP addresses, geographical location (approximately), a record of how services and sites are used, and other data that cannot be used to identify the user. Non-identifying data also includes those related to your browsing habits through third-party services. This website uses Google Analytics.
We use this information to analyse trends, administer the site, track user movements around the site, and to gather demographic information about our user base as a whole.

14.    COMPLAINTS
If you are not satisfied with our response to the exercise of your rights, you would like to discuss anything regarding this privacy notice, or you believe we are processing your personal data disregarding the data protection regulations in force, any claim can be sent to our DPO dpo@inspirededu.com or to the Information Commissioner’s Office, (ICO) at https://ico.org.uk/make-a-complaint/. 

15.     PRIVACY NOTICE UPDATES
King’s College Online may need to update this privacy notice periodically so we recommend that you review this information from time to time. 
This version was last updated on November 2020.