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Last Updated: {{ last_updated }}

Please read this notice carefully. This notice contains important information on who manages the Code for Life portal, how and why we collect information about you (for example, your name and email address), how we use your information, and with which persons we share your information. We also explain what rights you have in relation to your personal information, for example, the right to say no to the use of your information in certain cases, and how to contact us if you want to find out more about your rights or if you have other questions about this notice.

  1. Our commitment

  2. Who we are

  3. Types of information we hold about you

  4. How we will use information about you

  5. Change of purpose

  6. Cookies

  7. Sharing your personal information with other persons

  8. How long will we keep your personal information?

  9. Your rights

  10. Keeping your personal information secure

  11. How to complain

  12. Changes to this Privacy Notice

  13. How to contact us

  14. Do you need extra help?


1. Our commitment

We are deeply committed to creating a safe and secure online learning environment for all students, teachers, parents and guardians who use the Code for Life portal.

  1. We strive to give you control over the personal information that you give us, and we take the protection of your information very seriously.

  2. We take extra precautions for the safety and privacy of our younger learners. Where personal information could be entered, for example when a student names a level, the teacher is notified via email and the teacher has the ability to delete the level if its name is rude or compromising.

  3. Our portal only relates to Code for Life and we do not show advertisements on our website or within our lessons.


2. Who we are

We are a company called “Ocado Innovation Limited” or “Ocado Technology”, and we own the Code for Life learning portal. In this notice, we also use the name “Ocado” when we refer to us. Our office is at Buildings 1 & 2 Trident Place, Hatfield Business Park, Mosquito Way, Hatfield, AL10 9UL.

We are responsible for the personal information we collect about you on the Code for Life portal.


3. Types of information we hold about you

Your personal data, or personal information, is any information relating to you. It does not include anonymous information, which cannot be traced back to you or another person (anonymous data).

When you use the Code for Life portal and our services we collect the following personal information:

If you are a Student, we collect:

If you are a Independent Student, we collect:

If you are a Teacher, we collect:

If you are a Website visitor, we collect:


4. How we will use information about you

We need all the categories of information that we describe above, so that we can:

We summarise below the purposes for which we use your personal data and the lawful basis on which we rely.

Purpose Legal basis

To allow you to create an account and provide our services to you through our portal, such as providing course material and resources

Contractual necessity: the information is necessary to fulfil our contract with you.

To manage our relationship with you, including to allow you to manage your account, provide customer support, to handle your requests and queries, to provide you with information about our services that you use, or information about changes in our Terms or this Notice

  • Contractual necessity: to the extent the information is necessary to fulfil our contract with you (e.g. to ensure that we provide to you the services that you have requested).

  • Legitimate interests: to the extent the information is necessary to process queries and effectively manage our relationship with you as user of our services.

  • Compliance with a legal obligation: to the extent we are required by law to contact you in order to provide certain information (for example, to notify you of changes to our Terms)

To send you our newsletters and other promotional material about Code for Life

  • Your consent, where this is required by law.

  • Otherwise, when consent is not required, we will rely on our legitimate interest to keep you informed of our services, to the extent this is permitted by law.

To carry out analysis and compile statistics about the use of our portal, and the use of our services, in order to enable us to provide a better service, feature and functionality

  • Your consent: where we obtain this information by using cookies.

  • Our legitimate interest to ensure the smooth and effective functioning of our portal and services, to make sound business decisions about our services and to design, inform and deploy our business strategies.

To authenticate your account and to ensure the security of our portal, information systems and assets, to monitor compliance with our Terms, to prevent illegal activities in relation to our services.

Our legitimate interest to protect our business assets against illegal or inappropriate activities or security threats and your legitimate interest to protect the security of your account and information.

To protect our legal rights and to establish, exercise or defend legal claims relating to our services.

Our legitimate interest to protect our legal rights.

For accounting, record keeping and audit purposes

Our legitimate interest to effectively manage our business, audit our business processes and make informed business decisions.

When we rely on legitimate interests to process personal data, we consider and balance those interests against any potential impact on you (both positive and negative) and your rights and interests. If we consider that our interests are overridden by the impact on you, we will not use your personal data in this way (unless the law gives us another valid ground to do so). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.


5. Change of purpose

We will only use your personal information for the purposes for which we collected it or for other compatible purposes. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the basis on which we do so. Please note that we do not always need to rely on your consent to collect and process your personal information, and we will not seek your consent unless this is required by law.


6. Cookies
6.1 What are Cookies?

Cookies are tiny files that have information (data) in them. When you visit our portal, a cookie is placed on the device you use. Cookies allow us to remember when you visit our portal, or when you open an email. They help us understand how you are using the Code for Life portal, as well as which parts of our portal are popular and which ones we need to make better.

We also use other forms of technology (such as web beacons or pixels) which are similar to cookies and which allow us to monitor and improve our website. When we talk about cookies in this notice, we also refer to these technologies.

6.2 Types of cookies used

We use the following types of cookies on our portal for the following purposes:

Types of cookies Purpose For how many months does the cookie stay on your browser?

Strictly necessary cookies

These cookies do what you have asked for: for example, they allow the website to load on your browser, they keep you logged in when you use our portal, and keep our portal safe. If you turn off these cookies via your browser settings certain parts of the website will not function for you.

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Functional cookies

These cookies enable the website to provide enhanced functionality and personalisation. If you do not allow these cookies then some services may not function very smoothly. These kinds of cookies remember things like your sound settings.

Session

Analytics/Performance cookies

These cookies help us understand how you use our portal and improve or optimise the experience we provide. This can be anything like which pages you go to most often, and if you get error messages from web pages. They allow us to measure how visitors interact with the portal (for example which parts of the website are clicked on and the length of time between clicks).

We use third-party web analytics software on our portal (Google Analytics and Mouseflow). We provide further information about these partners below.

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6.3 Third party cookies

We do not allow third party advertising, or affiliation on our portal.

As we explain above, we work with other companies to use analytics cookies on our portal: these are Google, who provide Google Analytics cookies, and Mouseflow. We explain in more detail below what information they collect and how it is used.

Google Analytics. Our portal uses Google Analytics, which is provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyse how users use our portal. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By accepting analytics / performance cookies on our portal, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Mouseflow. We also use Mouseflow on our portal; this provider offers a website analytics tool that helps us understand how our portal is used, and which areas are mostly used (e.g. by using heatmaps or by replaying your journey on our portal). Mouseflow uses cookies to record information such as when you click on or move your mouse, when you scroll, or press a key, what pages you visit on our website, how much time you spend on each page, and also information about the device you use (operating system, device type (desktop/tablet/phone), screen resolution, location (city/country), language, and similar metadata). Mouseflow does not collect any information on pages where it is not installed, nor does it track or collect information outside your web browser.

6.4 Managing and disabling cookies

We make available a cookie management platform on our portal (provided by OneTrust), through which you can turn off non-essential cookies at any time. Please note, strictly necessary cookies will always be set as they are essential for our website to operate.

You can change your cookie preferences or withdraw consent by clicking on the following button:


7. Sharing your personal information with other persons
IT, email and web service providers

We share your personal information with our IT, email and web service providers, in order to enable them to provide us with their services. For example, we share your name and email address details with DotDigital, a service provider used for the purposes of sending emails to our users (such as newsletters, collecting feedback, or any important service related emails). This data sharing enables us to send you emails, view when they are opened and view which links are clicked.

Surveys, support and feedback providers

Freshdesk is our third party customer support tool that enables customers to contact us through a ticketing system on the website.

For more information on Freshdesk’s Privacy Notice, visit https://www.freshworks.com/privacy/.

For more information on Freshdesk and GDPR, visit https://freshdesk.com/gdpr.

We will occasionally ask for feedback on our portal. We will usually do this via an email which will direct you to our survey provider, UsabilityHub. It will only record; time spent, country, device type, device platform, unless specifically asked within the questions themselves for example, the survey may ask your age. You can find out more about UsabilityHub here.


8. How long will we keep your personal information?

We will only retain your personal information for as long as you have an active account, unless we need to retain this information for longer, after your account is deactivated, in order to protect our legal interests and establish, exercise or defend a legal claim. If you deactivate your account, we may anonymise your information and use it for a period of time in an anonymous format for research and other business purposes, such as business analytics.

For users that have registered but whose accounts are inactive, we will delete your personal information after 3 years of inactivity.


9. Your rights

Under data protection laws, you have certain rights in relation to your personal information, which you can exercise free of charge. In summary, those include the right to:

Please note these rights may be limited, for example if fulfilling your request would reveal personal data about another person or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of the relevant exemptions upon which we rely when responding to any request you make.

If you would like to exercise any of those rights, please:

If you would like to unsubscribe from any email newsletter or other promotional emails, you can click on the unsubscribe link which you can find at the bottom of our emails, in order to be removed from our mailing list. It could take up to 72 hours to process the update through our systems.


10. Keeping your personal information secure

We have security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those persons who have a genuine business need to know it and we require them to keep it confidential.

We enable Teachers to use two-factor authentication to further reinforce the security of their accounts and we encourage them to do that. You can find more details here.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.


11. How to complain

We hope that we or our Data Protection Officer can resolve any query or concern you raise about this Privacy Notice or how we use your information.

Alternatively, you also have the right to lodge a complaint with a data protection authority, in particular in the UK and/or the and/or the European Union (or European Economic Area) country where you work, normally live or where any alleged infringement of data protection laws occurred. The data protection authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: +44 303 123 1113.


12. Changes to this Privacy Notice

This Privacy Notice was last updated on {{ last_updated }}.

We may change this Privacy Notice from time to time and you should check it regularly. If we make any material changes to this notice we will inform via appropriate means (e.g. email).


13. How to contact us

Please contact our Data Protection Officer or us at individualrights@ocado.com if you have any questions about this Privacy Notice or the information we hold about you.


14. Do you need extra help?

If you would like this Notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

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This Privacy Notice will tell you what information we collect about you, how we use it, who we share it with, how long we keep it and how you can ask us about it.

This is the version of the Privacy Notice without all the legal jargon (we understand how overly complicated some privacy policies can be!) A full version of the Privacy Notice can be found by clicking here.

What we mean by ‘personal information’ is any information that can be used to identify you, such as your name and email address.


1. Who we are

We are a company called “Ocado Innovation Limited” or “Ocado Technology”, and we run the Code for Life learning website. From now on in the Privacy Notice, we’ll just use the name “Ocado” to mean us. Our office is at Buildings 1 & 2 Trident Place, Hatfield Business Park, Mosquito Way, Hatfield, AL10 9UL, United Kingdom.


2. Personal information we collect about you

When you are signed up to a class by a teacher on our Code for Life website, we will collect the following personal information about you:

If you sign up as an independent student for our Code for Life website, then we will also collect the following information about you:

If you are under 13 years old, you will need to ask a parent or guardian to register for you and we will collect personal information about them.


3. How we will use the information

The UK’s Data Protection rules say that we have to have a lawful reason to process your personal information (“lawful” meaning that the law allows us to use your information in that way).

Below we’ve listed the lawful reasons which allow us to process your information for the Code of Life Website:

Contract: We have to collect some personal information about you so we can provide you with the services we offer on the Code for Life website. For example, we need your name and a password so you can create an account and access our website and learning materials. This means you can access the portal and learn how to code with the support of your teacher and classmates, or work on your own/with a guardian if you are an independent student.

Legitimate Interests: We collect personal information to:


4. Change of purpose

We will only use your personal information for the reasons we collected it or for other similar reasons. If we need to use your personal information for a different reason, we will tell you. We do not always need your consent to use your personal information, and we will not ask for your consent unless the law says we need it.


5. Cookies & Similar technologies

When you visit our website, it will leave small data files called Cookies (not the edible kind) on your computer. Some of these are needed for the site to work (e.g. to help to keep it secure). Others are there to remember your settings (like how you’ve set up the sound) for when you next visit. We also use cookies that collect information about how you use our website (e.g. what pages you visit and how long you spend on the site). This is so we can see which parts of our site are popular and which we can improve in future.

Please see the “What are cookies” (not the edible kind!) section below for more information on what information we collect and how we use cookies.

What are cookies?

Cookies are tiny files that have information (data) in them. When you visit our site, we may put some cookies on the device you use. Cookies allow us to remember things like when you visit our site. They help us understand how you are using the Code for Life portal, as well as which parts of our portal are popular and which ones we need to make better.

We also make use of things called “web beacons” or “pixels.” These are similar to cookies and allow us to keep an eye on how well our website is working and look for ways to improve it. To keep things simple, when we talk about cookies in this Privacy Notice, we also mean web beacons and pixels.

Types of cookies used

You can see all the different cookies we use and what we use them for below.

Types of cookies Purpose How long does it stay on the browser?

Strictly necessary cookies

These cookies do what you have asked for: for example, they allow the website to load on your device, they keep you logged in when you use our site and help keep our site safe. If you turn off these cookies using your browser settings, then it could stop some parts of the site from working.

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Functional cookies

These cookies allow the website to remember your settings each time you revisit the site (for example how you have your sound set up). If you do not allow these cookies, then some services may not work as smoothly.

For as long as you are on the site

Analytics/Performance cookies

These cookies help us understand how you use our site, so we can improve the service we provide. This can be anything like which pages you go to most often and if you get error messages from web pages. They allow us to measure how visitors use the portal (for example which parts of the website are clicked on and the length of time between clicks).

We use other companies called (Google Analytics and Mouseflow) to help us collect information from these cookies (see the “Third-party cookies” section below).

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Third party cookies

We work with other companies to run the analytics cookies on our portal, including Google, who provides our Google Analytics cookie, and Mouseflow. They might also collect information from websites that are not ours. We explain in more detail below what information they collect and how it is used. We do not let other companies show ads on our portal.

Google Analytics. We use Google Analytics (which is run by Google) to help us understand how you use our site. The information it collects about your use of the website (including your IP address) will be stored by Google in the United States. Google may pass this information to other organisations who help them to interpret this information. They may also pass the information to other organisations if the law says they have to do so. If you choose to allow analytics / performance cookies on our site, you are consenting to Google using your data for the reasons above.

Mouseflow. We also use Mouseflow to help us understand how our site is used and which areas are mostly used. It uses cookies to record information such as when you click on or move your mouse, when you scroll or press a key, what pages you visit on our website, how much time you spend on each page, and also information about the device you use (like the device type (desktop/tablet/phone), location (city/country) and language). Mouseflow does not collect any information on pages where it is not installed and does not track or collect information outside your web browser.

Managing and disabling cookies

You can switch the functional and analytics cookies on and off at any time by clicking this button below.

You cannot switch strictly necessary cookies off as our website won’t work properly without them.


6. Who might we share your personal information with?

Your personal information will be shared with the Code for Life Team in Ocado, so they can set up and run your account.

We may also share a small amount of information with organisations that provide email services to help us run the Code for Life website.

For example, we share your name and email address details with DotDigital, a company that sends emails to users on our behalf (such as when we want to collect your feedback or need to give you important email updates about our service). This data sharing also allows us to view when your emails have been opened.

Another company we share personal data with is Freshdesk. They help us keep track of the questions users send using the Contact Us form, so we can reply to them more quickly.

We also use a survey company called UsabilityHub to help us carry out surveys. UsabilityHub records time spent on the site, country, device type, device platform alongside any questions that we may ask you in our surveys (for example, the survey may ask your age). You can find out more about UsabilityHub here.

We’ll only share your personal information with organisations mentioned in this Privacy Notice. They all sign an agreement to say that they will keep your personal information as safe and secure as we do, and that they will strictly follow our instructions on how your data can be used.

Finally, we may need to share your information for legal reasons, such as if we sold our business to another company, if our business advisors needed the information to help us achieve the purposes in this Privacy Notice, or to respond to law enforcement or court requests if there is a legal problem.


7. How long will we keep your personal data?

We’ll only retain your personal information for as long as you have an active account on Code for Life, unless we need to keep it for longer than this to help us defend a legal claim.

Once you deactivate your account, we might keep an anonymous version of your information to help us with research and other business reasons like assessing how the business is performing and planning for the future.

For users that have registered but whose accounts are inactive, we’ll delete your personal information after 3 years of inactivity.


8. Your rights

Depending on where you live, you may have the rights to:

If you would like to use any of these rights listed above, please email our Data Protection Officer at individualrights@ocado.com. Depending on where you live, you may need help from a parent or guardian to use your rights.


9. Keeping your information secure

Everyone at Ocado understands the need to keep your personal information safe so we’ve put steps in place to help prevent it from being accidentally lost or used in ways you wouldn’t expect.

Only those people in Ocado who have a business need to know your personal information are allowed to have access to it, and they have to keep it confidential.


10. How to complain

If you have a complaint about how we’ve used your personal information, you can write to our Data Protection Officer at individualrights@ocado.com.

You also have the right to complain to the Information Commissioner’s Office (the ICO). The ICO’s role is to make sure organisations like Ocado use your personal information fairly and keep it safe. You may contact the ICO by telephoning them on the number below or by visiting their website.

Telephone: 0303 123 1113

Website: https://ico.org.uk/concerns


11. Changes to the Privacy Notice

We may need to make changes to this Privacy Notice from time to time, so it’s a good idea to check it regularly. If we do ever change anything then we'll be sure to let you know (e.g. by sending you an email or posting an update on the Code for Life website).


12. How to contact us

Please contact our Data Protection Officer at individualrights@ocado.com if you have any questions about this Privacy Notice or the information we hold about you.


13. Do you need extra help?

If you would like this Privacy Notice in another format (for example, audio, large print, braille), please contact us (see the “How to contact us” section above).

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