Myley Privacy Policy

About this policy Personal data we collect about you How is your personal data collected? Our purpose for using your personal data Sharing your personal data International transfers Data Security Data Retention Your legal rights Changes to the privacy policy and your duty to inform us of changes How to contact us

About this policy

Myley respects your privacy and is committed to protecting your personal data. This privacy policy (“policy”) describes how we process your personal data.

Purpose of this privacy policy 

This privacy policy aims to give you information on how we collect, use, share, retain and transfer information. We also let you know your legal rights and how the law protects you. This policy describes the information that we, Myley Education Ltd., process to provide you with the Boost app, Boost management dashboard and Boost website which we will refer to as “Products”. These are not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This privacy policy is issued on behalf of Myley Education Ltd. When we mention, "we", "us" or "our" in this privacy policy, we are referring to Myley Education Ltd.

Personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which are grouped together as follows:

  • User Data includes first name, last name, username or similar identifier, email address.
  • Contact Data includes business address, email address and telephone numbers. 
  • Technical Data includes internet protocol (IP) address, your login data, browser and device type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access the products. 
  • Payment data includes your payment method and bank or credit card details
  • Profile Data includes your username and password, interests inferred from user activity, preferences, assigned content, feedback and survey responses. 
  • Usage Data includes information about how you use our products and services. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific product feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services; 
  • create an account within our products; 
  • subscribe to our service or publications; 
  • request marketing to be sent to you; 
  • enter a competition, promotion or survey; or 
  • give us feedback or contact us. 

Automated technologies or interactions. As you interact with our products, we will automatically collect Technical Data about your equipment, actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Provided by your Employer. To provide you with access to and features of the products, your employer will provide us with information that we will use to set up and manage your account. Only personal data required for the functioning of the products will be requested and stored.

Our purpose for using your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you / your employer. 
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 
  • Where we need to comply with a legal obligation. 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Below is a general explanation of each 'legal basis' to help you understand the table below which describes all the ways we plan to use your personal data, and which legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 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.

Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Consent means when you have provided consent to process your personal data for one or more specific purposes. You are free to withdraw your consent by contacting us using the details below.

Compliance with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer/user within our product/s
  • User data
  • Payment data

Performance of a contract

To diagnose, troubleshoot, and fix issues with our product/s
  • User data
  • Usage data
                    

 

Performance of a contract

To manage and maintain our relationship with you which will include:

                    
  1.      Notifying you about changes to our terms or privacy policy
  2.      Asking you to leave a review or take a survey
  • User data
  • Contact data
  • Usage data

Performance of a contract and legitimate interest

To use data analytics to evaluate, improve, develop new features/technologies to the products, marketing, customer relationships and experiences.
  • User data
  • Usage data
  • Profile data
  • Marketing and communications data
  • Technical data

Legitimate interest for us to develop and improve products, features and services for our users

For marketing or advertising where the law requires us to collect your consent.

                    

 

                    

For example, when we use cookies to understand your interests, or the law requires consent for email marketing.
  • User data
  • Usage data
  • Marketing and communications data
  • Profile data
                    

 

                    

 

Consent

To comply with a legal obligation that we are subject to or a request from law enforcement, courts, or other authority
  • User data
  • Contact data
  • Usage data
  • Payment data
  • Profile data

Compliance with legal obligations

To tailor content to you and others based on analytical data
  • Usage data
  • Contact data
  • Technical data
  • Marketing and communications
  • Profile data
                    

 

Legitimate interest

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out 

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at hello@boostcare.org.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of actual transactions with, or services provided to you by, us.

Cookies 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which would be compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sharing your personal data

We may share your personal data with the parties set out below for the purposes set out in the table under Our purpose for using your personal data.

Category of recipient

Type of data

Reason for sharing

Service providers
  • User data
  • Usage data
  • Payment data
  • Contact data
  • Technical data
  • Marketing data

This is so they can provide admin, product or sales support, technical, IT or marketing services for our products.

                    

 

Payment partners
  • User data
  • Payment data

For payment processing

Marketing and Advertising partners
  • User data
  • Usage data
  • Marketing data
                    

 

To support with providing relevant marketing and advertising as well as measure the effectiveness

Professional advisers including lawyers, bankers, auditors and insurers
  • User data
  • Usage data
  • Payment data
  • Contact data
  • Technical data

To provide consultancy, banking, legal, insurance and accounting services.

Academic or industry researchers
  • User data
  • Usage data

For activities such as statistical analysis and academic study, but only in a pseudonymised format.

Law enforcement and other authorities
  • User data
  • Usage data

When it’s necessary for us to do so we may need to provide information to comply with a legal obligation, respond to a legal process, or for a third-party's justifiable interest.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
  • User data
  • Usage data
  • Payment data
  • Contact data
  • Technical data

If we were to sell or negotiate to sell our business to a buyer we may share your personal data to a successor or affiliate as part of that transaction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions to provide our products and services to you.

International transfers

Personal and company data is stored within the European Economic Area (EEA), and is not accessed outside of the EEA except by Myley Education Ltd. staff and subcontractors in order to provide the products listed in this Policy. Only data that complies with the EU Laws is transferred internationally. This excludes all medical records from international transfer.

We require all staff and subcontractors who are accessing data outside of the EEA to protect your data and to provide you with EU-level rights and protections.

Data Security

We have put in place appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

We have put in place safeguards to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed in our systems. These include pseudonymisation, encryption, access, and retention policies where appropriate.

To protect your user account with our products, we encourage you to:

  • use a strong password which you only use for your Boost account 
  • never share your password with anyone 
  • limit access to your device 
  • log out once you have finished using the app or dashboard on a shared device

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data according to our instructions and are subject to a confidentiality duty.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We keep your personal data only as long as necessary to provide you with the products and/or services and for Myley Education Ltd’s legitimate and essential business purposes, such as:

  • Enabling the full functionality of the products
  • making data-driven business decisions about new features and offerings
  • complying with our legal obligations
  • resolving disputes

Categories of our retention periods:

Data retained until your remove it

It's your right to request that we delete certain parts of your personal data.  Only data that can be removed without impacting the functioning of the products can be requested to be deleted.

Data retained until your account is deleted

Account data is retained for the duration of the account’s life. Thereafter, it is removed unless it is required for other purposes as stated below.

Data retained for extended time periods for limited purposes

After your account is deleted, we keep some data for a longer period but for very limited purposes. For example, we may be subject to legal or contractual obligations that require this. These may include mandatory data retention laws, government orders to preserve data relevant to an investigation, or data kept for litigation.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Privacy laws, including the General Data Protection Regulation (GDPR), give rights to individuals over their personal data. It is your right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:             
    • If you want us to establish the data's accuracy. 
    •                 
    • Where our use of the data is unlawful but you do not want us to erase it. 
    •                 
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 
    •                 
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights above, please contact us.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in August 2024. Historic versions can be obtained by contacting us.

When we make material changes to this Policy, we'll provide you with an updated version as appropriate under the circumstances.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

How to contact us

For any questions about this policy or to exercise your legal rights, contact our Data Protection Officer (DPO) by:

  • email at hello@boostcare.org or;

  • Writing to us at: Myley Education Ltd, 85 Great Portland Street, First Floor, London, W1W 7LT

Myley Education Ltd is the data controller of personal data processed under this policy.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.