Privacy

MY REPTON PRIVACY POLICY
‘My Repton’ includes anyone whose life has an association with Repton Schools: students, Old Reptonians, parents (past and present), staff (past and present), wider family, neighbours, suppliers and friends of Repton Schools. The Schools, The Repton Foundation and The Old Reptonian Society have a shared interest in and co-ordinated approach to our former pupils and supporters and want to stay in touch and this statement summarises how we handle and use the data it collects. We will use the contact details of parents, alumni and other members of the My Repton to keep them updated about the activities of Repton Schools, including by sending updates and newsletters, by email, by post and SMS. Central to this is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.
Off-Line Transparency – your data will be used by My Repton to organise events and services as well as for fundraising purposes. These include production and distribution of publications and appeal information, and the marketing of events and dinners. Communications may be sent by post, telephone or increasingly, by electronic means. Most records contain education, contact details, and career information. Contact with The Schools and donations are also recorded. In some cases other data may include information about partners, financial and other data you have disclosed to us or which we have derived from publicly available sources in order to maximise the Repton’s fundraising potential.
On-line Transparency - My Repton is a social network and online platform for professionals, specifically Old Reptonians, their extended family, Repton Staff and other Friends and associates of Repton Schools. Our Privacy Policy applies to any Member or Visitor.
Our registered on-line users (“Members”) share their identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and find business, social and career opportunities. Content and data on some of our Services is viewable to non-members (“Visitors”).
Services - This Privacy Policy, including our Cookie Policy applies to your use of our Services. This Privacy Policy applies to MyRepton.org.uk, MyRepton.net, MyRepton.com, the MyRepton app, communications and services (“Services”), including off-site Services, such as event payment processing, and our off-line communications.
Data Controllers and Contracting Parties - We store and backup your data on servers in the EU and only share data for the purpose of mailings and analytics. We are based in the UK and defer to the regulations of this country.
As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.
Change - Changes to the Privacy Policy apply to your use of our Services after the “effective date.”
My Repton (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.
You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.
DATA WE COLLECT
Off-Line -
We collect personal information from you in various ways, for example:
·         When you join the OR Society as a life member;
·         When you enrol as a parent;
·         When you sign up as a Friend of Repton;
·         When you supply personal details in the course of registering for an event;
·         When you sign-up to receive newsletters or email notifications from us;
·         If you order any merchandise; and/or
·         If you raise a question or issue with us.
On-Line - To create an account you need to provide data including your name, email address and/or mobile number, and a password. If you register for an event you will need to provide payment (e.g., credit card) and billing information.
You create your My Repton profile (a complete profile helps you get the most from our Services) which can be drawn from other platforms, for example LinkedIn.
Photos - 
We have made the best effort to adhere to all known copyright and usage rights, but due to the age of some of the records and photographs we hold it has not always been possible to establish rights owners or permissions to share. Requests for removal of digital records from this website and school social media feeds should be sent to admin@myrepton.org.uk with details of the item and an explanation of why it should be removed. We commit to reviewing any such requests within two working days.

Profile - You have choices about the information on your profile, such as your education, work experience, skills, photo, city or area and endorsements. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping recruiters and business opportunities find you. It’s your choice whether to include sensitive information. We do not require Members to include sensitive data (e.g., race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual orientation or criminal record) in their My Repton profile. If you choose to post any such data, it is visible to others like the rest of the profile information you provide. On your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
You may give other data to us, such as by syncing your address book or calendar.
Posting and Uploading - We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, respond to a survey, or submit a CV. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).
If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about them, e.g. times, places, attendees and contacts.
You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.
Data From Others - Content and News - You and other Members may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. Unless you opt-out, we collect public information about you, such as professional-related news and accomplishments (e.g., patents granted, professional recognition, conference speakers, projects, etc.) and make it available as part of our Services (e.g. suggestions for your profile, or notifications of mentions in the news).
Related Companies and Other Services - We receive data about you when you use some of the other services including, for example, LinkedIn and Microsoft. For example, you may choose to send information about your contacts in Microsoft apps and services, such as Outlook, to us for improved professional networking activities on our Services.
Service Use - We log your visits and use of our Services, including mobile apps.
We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps or share articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
Cookies, Web Beacons and Other Similar Technologies - We collect data through cookies and similar technologies. The Cookie Policy describes the use of cookies and similar technologies. We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. We also allow some others to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools.
Your Device and Location - We receive data from your devices and networks, including location data. When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or to identify your precise location.
Sites and Services of Others - We get data when interact with sites that, for example ‘share’ or ‘like’ content from My Repton.
Other - We are improving our Services, which means we get new data and create new ways to use data.
Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.
HOW WE USE YOUR DATA
Our Services help you connect with others, find and be found for work and business opportunities, stay informed, get training and be more productive. We use your data to authorize access to our Services.

Stay Connected - Our Services allow you to stay in touch and up to date with colleagues, friends, and other professional contacts in order to exchange professional and social opportunities.
We will use data about you (such as your profile, profiles you have viewed or data provided through address book uploads or partner integrations) to help others find your profile, suggest connections for you and others (e.g. Members who share your contacts or job experiences) and enable you to invite others to become a Member. We are working on a way for you to opt-in to allow us to use your precise location or proximity to others for certain tasks (e.g. to suggest other nearby Members for you to connect with, or notify your connections that you are at a professional event).
Stay Informed - Our Services allow you to stay informed about news, events and ideas regarding professional topics, social events and news of Repton Developments. Our Services also allow you to improve your professional skills, or learn new ones. We may use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant content and conversations on our Services, suggest skills you may have to add to your profile and skills that you might need to pursue your next opportunity. We use your content, activity and other data, including your name and picture, to provide notices to your network and others that, for example, you are attending an event.
Career - Our Services allow you to explore careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. We will use your data to recommend jobs or mentees, show you and others who work at a company, in an industry, function or location or have certain skills and connections. You can signal that you are interested in changing jobs and share information with job recruiters. We will use your data to recommend jobs to you and you to recruiters. We may use automated systems to profile and provide recommendations to help make our Services more relevant to our Members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.
Productivity - Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to do business with. Our Services allow you to communicate with other Members and schedule and prepare meetings with them..
Communications - We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.
We will contact you through email, mobile phone, notices posted on our websites or apps, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.
We also enable communications between you and others through our Services, including for example invitations, groups and messages between connections.
Marketing  - We promote our Services to you and others. We use data and content about Members for invitations and communications, promoting network growth, engagement and careers.
Service Development - We use data to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.
We seek to create economic opportunity for Members of globally, and to help them be more productive and successful.
Surveys - Polls and surveys are conducted by us through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.
Support - We use data to help you and fix problems. We use cookie data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).
Aggregate Insights - We use data to generate aggregate insights.
We use your data to produce and share aggregated insights that do not identify you. For example we may use your data including inferences drawn from data about you such as your age or gender to generate statistics about our members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics and insights. We may anonymously share this information with our provider to benchmark these statistics with organizations similar to ours.
HOW WE SHARE INFORMATION
Any data that you include on your profile and any content you post or social action (e.g. likes, follows, comments, shares) you take on our Services will be seen by others.

Profile - Your profile is fully visible to all Members. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines).
·         Our Services allow viewing and sharing information including through posts, likes, follows and comments.
·         When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
·         In a group, posts are visible to others in the group. Your membership in groups is public and part of your profile, but you can change visibility in your settings.
Any information you share through Careers pages on our Services will be viewable by it and others who visit those pages.

·         When you like or re-share or comment on another’s content other Members will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).
OTHERS’ SERVICES
You may link your account with others’ services so that they can look up your contacts’ profiles, post your shares on such platforms, or start conversations with your connections on such platforms. Excerpts from your profile will also appear on the services of others.

Subject to your settings, other services may look-up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter or WeChat account to share content or your email provider may give you the option to upload your contacts into its own service. You may revoke the link with such accounts. Subject to your settings, excerpts from your profile will appear on the services of others (e.g., search engine results)
Service Providers - We may use others to help us with our Services. We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
Legal Disclosures - We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.
It is possible that we will need to disclose information about you when required by law, if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of My Repton, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
YOUR CHOICES & OBLIGATIONS
Data Retention - We keep most of your personal data for as long as your account is open. We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services every few years, we will retain your information and keep your profile open until you decide to close your account. In some cases we choose to retain certain information in a depersonalized or aggregated form. If you decide to close your account, we will keep basic records of your association with the school as a matter of historical reference and to ensure that your details aren’t re-added from archive data eg Blue Books, at some point in the future. You can opt for us to hold you data entirely off-line and continue to receive communications from us by post and SMS and email.
Rights to Access and Control Your Personal Data - You can access or delete your personal data. You have many choices about how your data is collected, used and shared. We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to opt-outs opt-ins and communications.
The personal data that we have about you:
·         Delete Data: You can ask us to erase or delete all or some of your personal data (e.g. If you are an OR we will hold the minimum amount as your historical record with the school).
·         Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
·         Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
·         Right to Access and/or Take Your Data: You can ask How to do this: Members may make requests to us for a copy of your personal data. You may also contact us using the contact information below, and we will process this request in accordance with UK law.
On-line Account Closure - We keep some of your data even after you close your account.
If you choose to close your My Repton account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.
If a Member is an OR we will retain the minimum of data as a matter of historical association with Repton Schools and so that we have traceability to your opt-out.
Other Important Information
We will retain certain Personal Data in respect of financial transactions for as long as the law requires us to for tax or accounting purposes (which in the UK may be up to 6 years after a particular transaction). This could be for charitable gifts or for event bookings and other services eg the shop.
LEGAL OBLIGATIONS
We collect and process your Personal Data in observance of applicable laws that regulate data protection and privacy. This includes, but is not limited to, the EU General Data Protection Regulation 2018 (2016/679) and other UK privacy legislation. 
The type of personal information we collect includes your name, email address, home (or work) address, phone number and other personal details which you may choose to provide or of which we may otherwise become aware by virtue of it being publicly available.

SECURITY
Security and data-sharing with partners – all information is held and transmitted securely and (in addition to disclosure as permitted or required by law) may be disclosed on a considered and confidential basis to officers, Governors, employees and/or staff of Repton Schools, The Old Reptonian Society. Data may also be transmitted to selected third parties who may provide services (such as printers, mailing houses, wealth screening services and fundraising consultants) to ‘My Repton’. They are required to delete or destroy all such information once they have completed the agreed activities carried out on our behalf.  We also facilitate communication between former pupils but will not release personal contact details without your permission.
We will not sell or share your information with any third parties for their own use, or for them to market to you.
Lawful Bases for Processing
Off- Line. Your pre-existing relationship with The Schools establishes a legitimate interest in our sharing with you news of developments at Repton, our fundraising programme generally, and in the social and networking opportunities that we offer to our community. It is on this basis that we hold the information that you or others have supplied to us, and use it in the manner set out in this document. You will receive our general news, and information about our events and our development programme, unless you have asked us not to contact you about certain subjects, or using certain methods (see below). There is a balanced and legitimate interest in our contacting members of our community to establish whether or not they would like to commence or to renew financial support for the School through My Repton. This serves to maximise our ability to carry out our objectives in this regard, but also to ensure that we respect community members’ wishes in respect of fundraising approaches.
At any time, you can withdraw consent you have provided by emailing myrepton@myrepton.org.uk or by post at My Repton, Repton School, Willington Road, Derbyshire, DE65 6FH
On-Line. Signing up to My Repton for an online profile establishes a legitimate interest in your data being used and shared as part of this Service. At any time, you can withdraw consent you have provided by going to settings or by emailing myrepton@myrepton.org.uk or by post at My Repton, Repton School, Willington Road, Derbyshire, DE65 6FH
Where we process data based on consent, we will ask for your explicit consent. You may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our myrepton@myrepton.org.uk.
Governing Law - This Privacy Policy is subject to English law. To the maximum extent legally permitted, you agree that any dispute relating to use of your Personal Data as referred to under this Privacy Policy is subject to the exclusive jurisdiction of the courts of England and Wales.
Contact Information - If you have further queries or requests relating to how we use Personal Data please contact our My Repton, Willington Road, Repton, Derbyshire, DE65 6FH. If, following our response, you are still not satisfied or believe we are processing your Personal Data not in accordance with applicable law you can raise your concern or complaint with the UK Information Commissioner's Office – for more information on this, see https://ico.org.uk/concerns/
A link to our offline policy is DATA AND PRIVACY POLICY
 

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