Privacy Policy

Introduction to Privacy Policy

This Privacy Policy is effective from September 6, 2022. By continuing to use The Polaris School from September 6, 2022, you understand and agree to this Privacy Policy. The Polaris School reserves the right to ammend or replace this privacy policy at any time without notice, however if you at any time no longer agree to the Privacy Policy, you can request for your account to be deleted here and your account with The Polaris School (and any personal data, as well as purchased content) will cease in accordance with our Privacy Policy and GDPR (UK), GDPR (EU) and CCPA (California) Policies for data protection. “The Polaris School”, “We”, “Our” and “Us” refers to The Polaris School platform and its associated entities - including the site administrators, contractors and respective owners. “You”, “Your” and “Yourself” refers to you, the site visitor (at any capacity, depending on context). “Platform”, “Website”, “Site”, “Service”, “Services” and “Polaris” refers to The Polaris School website accessible at https://thepolaris.school. “User”, “Users’, “Customers”, “Students”, “Parents”, “Account holder”, “Account holders” and “Licensees” refers to the site visitor with or without a respective The Polaris School account(depending on context). “Administrators”, “Staff”, “Owners” and “Teachers” refers to the owners, staff or contractors of The Polaris School. “Subscription” refers to a paid ongoing contract with The Polaris School, which provides access to “content”. “Content”, “Materials”, “Lessons”, “Blocks” and “Purchases” refers to digital materials made available to a user with or without a purchase (depending on context). “Personal data”, “Data”, “Personal information” and “Account data” refers to personal information belonging to a user made available to, or collected by, the Polaris School “Enrolled” and “Enrolling” refers to a student with, or in the process of obtaining, an active The Polaris School account. This Privacy Policy is in place in line, dictated by, and in compliance with local laws. In the event that information made available on this page is not in compliance or is not compatible with the laws of a user’s relevant jurisdiction, the law overrides the policy outlined on this page.

1a) Personal Information that we collect in order to provide access to our Services

The Polaris School collects the following personal identifiable information about every student (or parent, for email addresses) enrolled in The Polaris School in order to provide access to our Services:
- Full Name
- Nationality
- Language
- Email Address
- Date/Time of Last Login
- Active Subscriptions

We additionally collect the following (only) for analytical purposes and users can choose to delete this personal data through a request form here:
- Date of Birth

This personal information is collected i) in order to provide our Services; ii) to prevent fraud and criminality; iii) to provide the correct language (in the event that the Service or Content is available in multiple languages in future; iv) to provide communication with parents and/or students; v) to facilitate access to the Service. The personal information is collected at the time of sign up for a new The Polaris School account, and users can request for adjustments to be made at any time by contacting us here. Users can additionally at any time request for their personal information and account to be deleted here.

1b) Storage of Personal Information that we collect

The Polaris School protects personal information collected on users with strong security and is accessed only for work purposes that aid the ongoing process of providing the Service to the user. Student personal information is stored on Outseta’s secure platform with strong security and with periodic reviews of data storage. You can read Outseta’s privacy policy here. Administrators and staff may only access personal information manually for i) communication with students or parents, ii) billing or providing access to the Services for students or parents, iii) prevention of fraud or criminality.

In the event that personal information has to be migrated from Outseta to another platform, you will be notified in writing prior to, and/or after, the migration has taken place. For the duration of, and strictly limited to, the migration process, personal information may be downloaded in plain text to be transferred over to the new data storage platform. Every care will be taken during the migration process to protect users’ personal information. Immediately after completion of migration, any and all downloaded copies of personal information will be securely destroyed.

1c) Deletion of Personal Information that we collect

In accordance with our GDPR (UK) Compliance Policy, GDPR (EU) Compliance Policy and CCPA (California) Compliance Policy (depending on user jurisdiction), The Polaris School respects and complies with all data protection rights for users in the United Kingdom, European Union, State of California, United States and worldwide. In the event of a request for deletion of personal information, we will endeavour to delete all personal information linked to the user at the earliest opportunity including any external documents, email servers and storage providers, except where we are legally required to hold it (in the event of criminality) and in the event of abuse of the platform. Users can request the information we hold about them at any time by contacting us regarding a personal data inquiry, however a request for full deletion of a user's account prior to the inquiry for personal data will nullify any later request for personal information. We comply with any and all requests by law enforcement in the event that suspected criminality has occurred by a user through the use of, or aided by the use of, The Polaris School platform. Information requested by law enforcement may be held, even if a user requests deletion of their personal data, providing it is held in compliance with local laws. The Polaris School is not liable for any losses incurred as a result of accidental account deletion requests on a user’s part. In the rare event that a user’s account data is deleted by The Polaris School mistakenly (without a request), the user agrees that The Polaris School will provide access to materials made inaccessible as a result of the mistake and attempt to restore the user’s account and deleted personal data as soon as possible, once The Polaris School becomes aware of the issue. If lost materials are no longer available, an alternative equivalent to that of the prior purchased materials’ value will be made available to the affected account.

1c) i) Rights Under GDPR (For Users in the United Kingdom)

In accordance with our Privacy Policy and our GDPR Compliance Policy, The Polaris School respects and complies with additional data protection rights for users in the United Kingdom (only) under the General Data Protection Regulation (GDPR) as part of The Data Protection Act 2018. Users in the United Kingdom (only) have special rights for data deletion, and data requests. The data deletion process may be expedited for users in the United Kingdom in order to comply with this law. You can read our GDPR Compliance Policy here for more information.

1c) ii) Rights Under GDPR (For Users in the European Union)

In accordance with our Privacy Policy and our GDPR Compliance Policy, The Polaris School respects and complies with additional data protection rights for users in the European Union (only) under the General Data Protection Regulation (GDPR) as part of country specific laws. Users in the European Union (only) have special rights for data deletion, and data requests. The data deletion process may be expedited for users in the European Union in order to comply with this law. You can read our GDPR Compliance Policy here for more information.

1c) iii) Rights Under California Consumer Privacy Act (CCPA) (For Users in the State of California, United States)

In accordance with our Privacy Policy and our CCPA Compliance Policy, The Polaris School respects and complies with additional data protection rights for users in the State of California (only) under the California Consumer Privacy Act (CCPA) as part of United States state-specific laws. Users in the State of California (only) have special rights for data deletion, and data requests. The data deletion process may be expedited for users in the State of California in order to comply with this law. You can read our CCPA Compliance Policy here for more information.

1c) iv) Rights For Users Internationally (Excluding United Kingdom, European Union and State of California, United States)

In accordance with our Privacy Policy, The Polaris School respects and complies with worldwide data protection laws. Users outside of the United Kingdom, European Union and State of California do not have special rights for data deletion, or data requests.

1c) v) Changes to Rights If Users Move Abroad

In accordance with our Privacy Policy, GDPR Compliance Policy and CCPA Compliance Policy, The Polaris School respects and complies with worldwide data protection laws and additional country-specific and state-specific laws. Rights apply to citizens of the relevant applicable jurisdiction (EU, UK, State of California, or elsewhere), and so rights change if users move abroad. When notified in writing by the user, The Polaris School will adjust handling of personal data in order to comply with the user’s new local laws as soon as possible. A user typically holds one set of rights - either the rights under GDPR for United Kingdom users, GDPR for European Union users, CCPA for State of California, United States, users, or local laws for users internationally. In the event a user is a citizen in multiple regions, The Polaris School will attempt to store personal information in compliance with the rights based on the user’s sign up location (specified upon first sign up) or the latest known location (whichever is most recent). If a user is unhappy with the rights based on their sign up location (for example, a user is a citizen of both the United Kingdom and the State of California, United States), the user may request for personal information to be stored in compliance with a different jurisdiction’s rights if they are a lawful resident of that country or state.

1d) Handling cyberattacks, system failures, leaks and breaches of security

The Polaris School only utilises external platforms with the strongest security measures for data storage and handling of personal information. The platform itself stores no personally identifiable or anonymised data about users - with all user information securely stored on Outseta’s servers and passed through to the platform when a user signs up or logs in. The Polaris School protects access to external platforms with extreme attention to security and with regular reviews of security to ensure no personal information is made public.

In the event of a cyberattack, system failure, leak or breach of security, once identified and verified, The Polaris School will immediately report the event to relevant authorities and/or platform providers (Outseta, Webflow and others) to ensure access is locked down and users’ data is immediately inaccessible to bad actors or any unauthorised users. The Polaris School will immediately contact affected users, detailing the information that may have been leaked with information on the date and time of the event. Account passwords are stored differently, but also protected by our external platform provider Outseta and encrypted to prevent misuse. The Polaris School does not have access to, and cannot access under any circumstances, a user’s password. In the event of a password breach, users will be immediately contacted and encouraged to update their password.

1e) Storage of Billing Information

The Polaris School platform stores no billing information for users. All billing information is stored on Outseta’s servers in accordance with their respective privacy policy, which you can view here. We cannot access users’ billing information in plain text and have strong regularly updated security in place to prevent potential breaches, in accordance with subsection 1d.

1f) Storage of Personally Unidentifable Data

In addition to the identifiable data we collect as outlined in subsection 1a, we also collect and handle unidentifiable random data that cannot be tied to a specific user, and is used more broadly to track overall site statistics. We track the following information with no identifiers and with no way of associating the data with a user:

- Site Views
- Active Users Count

These categories of data are tracked via Outseta and used to provide anonymous statistics.