Privacy Policy

Updated 29-Jan-21

It is important that you read this Policy, together with any other privacy notice we may provide when we are collecting or using personal information about you or provided by you, so that you are aware of how we are using such information, and your rights.

About this document

At Persona Education we take our users’ and customers’ privacy very seriously.

In this document, “our”, “us”, “we” and “Persona” mean Persona Education Ltd, UK registered company number 12370902.

Persona is registered with the UK Information Commissioner’s Office (ICO) and is fully compliant with the EU General Data Protection Regulation (GDPR). We are also fully compliant with the UK Data Protection Act 2018.

This Privacy Policy tells you about personal information we collect, and how we use it. It forms part of the Persona Life Skills Terms of Use.

By submitting data via our website, you acknowledge that you have read and agreed to this Privacy Policy. By registering to use or actually using any of the Persona web or mobile applications (“the App”), you acknowledge that you have read and agreed to this Privacy Policy and our Terms of Use.

We are a Data Controller under GDPR definitions. This means that we determine the purposes for which, and the way in which, your personal data are processed. Our Data Processor partner is Solirius Ltd, UK registered company number 06279757. This means that Solirius Ltd processes personal data on our behalf.

All Persona employees and our Data Processor partner’s employees are Disclosure & Barring Service (DBS) checked. Our Data Processor partner’s employees are also Baseline Personnel Security Standard (BPSS) checked.

Data protection principles

We comply with data protection law and principles, which means that any personal information we collect about you is:

  • Used lawfully, fairly and transparently
  • Used only for valid purposes that we have notified you about
  • Relevant to the purposes that we have notified you about
  • Accurate and kept up to date
  • Kept only as long as necessary for the purposes that we have notified you about
  • Kept securely

Keeping your data safe

Your personal information is stored in the UK, on the Google Cloud Platform (GCP). GCP is compliant with information security international standards ISO/IEC27001, ISO/IEC27017 and ISO/IEC27018, among others. More information on GCP’s approach to security is available here.

Data stored on GCP are ‘encrypted at rest’ meaning your information is always encrypted by default, even when not being accessed. More information on GCP’s approach to encryption at rest is available here.

We encrypt your information using Transport Layer Security (TLS) – the more secure successor to SSL – when it is being transferred to/from your computer, tablet or phone and the GCP cloud server. More information on GCP’s approach to encryption in transit is available here.

We and our Data Processing partner have established procedures for accessing personal information and logging any such access, so there is always a record of which data have been accessed, how and when.

Any updates to our software requiring manual access are always carried out by two software engineers working together, to ensure any data access is witnessed and logged.

In addition to managing data access by our own and our Data Processing partner’s staff, GCP uses a combination of strong identities for individuals and service accounts, access-control list (ACL) systems, and an internal control similar to Binary Authorization to ensure that access to data is valid. 

Information we hold about you

In connection with your use of the App, we may collect, store, and use the following personal information:

  • Contact Data: Email address(es).
  • Identity Data: First name, last name, email address(es), date of birth, your school/college, school/college year or grade, gender, and country of residence.
  • Personality Insights Data: Responses to personality insights questions about yourself (Self Insights questions), and responses to personality insights questions about other people (Friends Insights questions) (together, “PIQ”).
  • Participation Data: Other information you provide when using the App, including PIQ invitations sent to/received from other users, responses to questions in learning modules, selections made in activities (eg. drag-and-drop, rankings), notes made at the end of learning modules, and learning outcomes self-reporting. You should not input any sensitive personal information or offensive information in the App.
  • Survey Data: Responses to survey questions we may ask from time to time via the App and/or via email. You should not input any sensitive personal information or offensive information in response to survey questions.
  • Settings Data: The information you provide when you create or update your settings, including a photo or other image uploaded by you, description, tagline, status, and your preferences.
  • Technical Data: Internet protocol (IP) address, your login data, device type and screen size, browser type and version, time zone setting and location, browser plug-in types and versions, and the operating system on the device(s) you use to access the App.
  • Usage Data: Information about how you use the App, for example time logged in, modules started and completed, etc..

In addition, we may collect, store, and use the following personal information only about Teacher and Admin users:

  • Contact Data: Phone number, school/college address.

If you have contacted us via our website form, we may store and use the following personal information about you:

  • Contact Data: First name, last name, email address, phone number, school/college name.

Access to information

You have the right to request access to your personal information and receive a copy of the data we hold about you.

No-one at Persona or its partners, or any App user (including Students, Teachers and Admins), has access to your password, which is always stored and transmitted in an encrypted form.

Identity Data, Participation Data and Usage Data information relating to your school or college account may be accessed by Teacher users and Admin users linked to your school or college.

Aggregated Personality Insights Data relating to your school or college account may be accessed by Teacher users and Admin users linked to your school or college. Your responses to individual PIQs may not be accessed by any App user other than yourself.

Aggregated Personality Insights Data relating to your school or college account, specifically averaged responses to Friends Insights questions about you from other users, may be accessed by other Student users linked to your school or college.

Aggregated and anonymised Personality Insights Data and aggregated and anonymised Survey Data may be accessed by our Marketing Data partners (eg. companies which use our data to help understand attitudes and behaviour among young people, for market research purposes).

Identity Data, aggregated Personality Insights Data and Survey Data may be accessed by our API Licensing partners (eg. a social media platform or careers platform with which you hold an account), only with your prior consent which will be requested for each partner separately.

How we use the data

We use personal information based upon consent and/or Legitimate Interest. Consent means obtaining your permission – by using the App you are giving consent for us to use your personal information as described in this document. Legitimate Interest means where using your information will help us serve a particular, valid purpose such as improving the App or making it available to as many young people as possible, to help them develop life skills and improve their wellbeing and employability.

We use each type of personal information in the following ways:

Contact Data:

  • To send messages that help you use the App, eg. password reset, reminders or feedback requests.
  • To send survey questions from time to time.
  • To inform you about you about our products and company news, if you have submitted contact data via our website.

Identity Data:

  • To verify you are old enough to use the App.
  • To enable you to sign in to the App.
  • To link your account with your school/college and group(s) within it, eg. school year and class.
  • To provide input for our data analytics, so we can show useful information in your dashboard and your school/college Teachers’ and Admins’ dashboards, and continuously improve the App.
  • To facilitate a link to your account with one of our API Licensing partners, where you have requested it. 

Personality Insights Data:

  • To provide you with useful information about your own and other people’s mix of personality and communication styles, using the Persona algorithm.
  • To provide you with guidance on how you could adapt your thinking, communication and behaviour in different situations in order to achieve positive outcomes.
  • To provide input for our data analytics, so we can show useful information in your dashboard and your school/college Teachers’ and Admins’ dashboards, and continuously improve the App.
  • To contribute to aggregated and anonymised data sets for our Marketing Data partner(s) to use for market research purposes.
  • To facilitate a link to your account with one of our API Licensing partners, where you have requested it. 

Participation Data:

  • To inform you when other users have invited you to answer PIQs about them.
  • To allow a Teacher user or Admin user linked to your group or school/college to review your responses to questions in learning modules, selections made in activities, notes made at the end of learning modules, and learning outcomes self-reporting.
  • To provide input for our data analytics, so we can show useful information in your dashboard and your school/college Teachers’ and Admins’ dashboards, and continuously improve the App.

Survey Data:

  • To provide input for our ongoing research about personality and communications styles, life skills, wellbeing and employability.
  • To contribute to aggregated and anonymised data sets for our Marketing Data partner(s) to use for market research purposes.
  • To facilitate a link to your account with one of our API Licensing partners, where you have requested it. 

Settings Data:

  • To enable you to customise your account in the App.
  • To record your preferences on how you use the App.

Technical Data:

  • To help us ensure the App performs properly on different technology platforms.
  • To provide input for our data analytics, so we can continuously improve the App.

Usage Data:

  • To provide input for our data analytics, so we can show useful information in your dashboard and your school/college Teachers’ and Admins’ dashboards, and continuously improve the App.

Your personal information rights

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (known as making a ‘data subject access request’). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request your personal information to be erased. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest and there is a specific reason why you want to object.
  • Request restricted processing of your personal information. This enables you to ask us to suspend processing your personal information, for example if you want us to establish its accuracy.
  • Request the transfer of your personal information to another party.

Contacting us

  • Contact form: www.persona-life.com
  • Email: privacy@persona-life.com
  • Phone: +44 (0)117 313 2897
  • Address: 18 Berkeley Square, Bristol BS8 1HB, United Kingdom

If you would like to contact us about data privacy, please get in touch with our designated Data Protection Officer using one of the communication channels above.

You also have the right to make a complaint to the UK Information Commissioner's Office (ICO).