This policy sets out privacy terms that apply to all apps published by Anspear Ltd. It sets out what data the apps collect, how the data is stored, what the data is used for and the commitments we make to you as a user of our apps.
If you have any questions about this policy, please contact us via firstname.lastname@example.org.
Our apps fall into two categories, "Publication apps" and "Library apps". Note that Publication apps do not collect any personal or usage data at all, so if you are using Publication apps only, the parts of this policy that relate to data collection, storage and use (ie the majority of this policy) will not apply to you. An exception is the paragraph headed 'Links to other sites'.
"Publication apps" are apps produced by Anspear that include a single, fixed publication. The content used by the app is provided to the user at the same time the app is downloaded, stored on the user's device and can't be added to or changed except when the app itself is updated.
"Library apps" are apps produced by Anspear that are able to download and display a range of different publications. These apps are free to download and do not contain any content when you download them. Instead they allow users to download a selection of publications, which can then be accessed online. Library apps include the Unitas Academy, the library app for your multi-academy trust or training provider, the nimbl app and the Anspear app.
If you are in any doubt as to which type of app you are using, note that Library apps require you to log in the first time you open the app, whereas Publication apps never ask you to log in.
Library apps require you to log in with a user account. Depending on which app you are using, this may be given to you by your school, multi-academy trust, training provider or other organisation, or you may be asked to register an account yourself using an email address. (Note that where an email address is matched to an account, this is only ever used to manage that account and we will never use it to contact you for marketing or any other purpose.)
Personal data linked to a username typically includes a user's name and the school, college or other organisation that they are associated with. The apps do not gather any other personal details. This data is visible to Anspear staff and to administrators at the relevant school, college or organisation, so that they can track and report on learners' use of publications.
In cases where users are considered to be in a particularly sensitive group, such as looked after children, usernames may be linked to ID numbers rather than names so that Anspear staff cannot identify any individuals. The users' school, college or other organisation will be able to match the ID numbers to individual learners so that they can monitor progress and use of the app without personal data being available to those outside their organisation.
As you use a Library app, it may collect usage data such as the amount of a publication you have read, activities you have completed and self-evaluation scores. When you go online, this usage data is then shared with your administrator at your providing organisation so that they can track your use of the publication in question. Anspear staff can also access this usage data. No data is collected via the app apart from this usage data.
Publications used within Library apps allow you to add notes to particular pages and many also include written activities that you can complete. Notes and activity answers are stored on our servers so that they can be synced when you use the same publication on another platform or device. Anspear stores this data securely and does not routinely access it or share it with any other person or organisation. However, you are advised not to enter sensitive or personal information into notes or activities in publications.
When users of library apps connect to the internet, we may log technical data such as their IP address, device model/OS and web browser. These are only referred to when necessary to provide technical support.
Usage data collected via, or relating to, Library apps is used only for the following purposes:
Data is stored securely on servers in the United Kingdom. We understand the importance of data security and take all reasonable steps to maintain the security of personal data, including (and especially) that relating to our app users. The hosting provider for our data services is ISO 27001 certified.
We do not retain personal data any longer than we need to for the purposes set out above, after which point it is deleted.
The only circumstances under which we transfer personal data relating to our apps to other parties are:
Library apps are typically used to provide publications for the purpose of education, training or professional development on behalf of a school, college or other organisation. Under GDPR, the school, college or other organisation is the data controller and Anspear acts as a data processor. Therefore, the legal basis for processing data is the ultimate responsibility of the school, college or other organisation that is providing the publications. Depending on the type of organisation, the legal basis is likely to be Public task, Contract or Consent. To be sure, you should contact the school, college or other organisation that is providing your publications.
Anspear complies with all relevant data protection law, including the right to request any personal data that we hold about you and for that data to be deleted. You can contact us via email@example.com.
Content accessed through both Publication apps and Library apps may contain links to websites that are not under the control of Anspear. We make every effort to ensure that we only link to reputable websites, but users are advised to check the privacy policies of the sites in question, particularly if asked to submit any personal data.
All our apps are completely free of advertising in any form.
We review this policy periodically and it may change from time to time. You are advised to check this page periodically for changes that may be relevant to you.
If you have any queries about this policy, please contact us via firstname.lastname@example.org.