Data Protection Statement

Who we are‍
We are EcoSpot Ltd, a company based in London. You can contact us by emailing us at team@ecospot.io.‍ EcoSpot is a community platform for climate action. The platform is available on the web or via an iOS app. Using EcoSpot, schools will be able to take part in green challenges that help the school community live more sustainably. Users can track the positive impact their school is having on the planet and are able to compete to take the most action amongst peers within their closed community.

Personal Data We Collect: Please see this page for the detailed categories of personal information we collect from users, including the sources from which the information was collected, the business purpose for which the information was collected and the third parties with whom we share or disclose personal information for a business purpose.

How We Use the Information We Collect: We use the personal information we collect from students (or about students from teachers) to provide and improve the service, for educational purposes, security, and safety purposes, or as required by law. We will not require children to provide more personal information than is reasonably necessary in order to participate in the service.

Data Protection Statement
This document serves as our public statement on data protection. It sets out how we process the personal information of EcoSpot's student users and non-student users of EcoSpot. It is aimed at schools whose students use EcoSpot, the parents or guardians of such students, and any non-student registered users of EcoSpot (teachers of students who use EcoSpot, youth groups that work with children who use EcoSpot)

If you are a non-student registered user of EcoSpot and want to learn how we use your personal data, read our full Privacy Policy.

If you are a student user of EcoSpot, you may prefer to read our Privacy Notice for Students or you can learn more by reading the full privacy policy.

Data Protection Legislation and Roles
Our use of personal data is subject to the UK General Data Protection Regulation, the UK Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (together Data Protection Legislation). For the purposes of the Data Protection Legislation we are the controller of registered users’ (data subjects) personal data processed in connection with their use of EcoSpot.

This means that we are responsible for determining the purposes and means of the processing of their personal data. Whilst we will take into consideration all reasonable requests from schools concerning the personal data of their students, we do not act as processors on behalf of schools or charities. Neither do we act as processors on behalf of schools, charities or third party organisations in respect of the personal data of their staff registered to use EcoSpot.

Age Appropriate Design Standards
We aim to comply with the standards set out in the Information Commissioner’s Office Age Appropriate Design Code of Practice for Online Services.

Best interests of the child
EcoSpot has been designed and developed with the best interests of students and respect of their rights in mind, including:
online safety;
privacy;
freedom of expression;
accessing information regarding the environment and sustainability; and
building confidence in their contribution to their school community.

Currently, EcoSpot only offers online services indirectly to children, through their school.

Age appropriate application
We recognise that needs and capacities of children differ depending on their age. For schools with children under the age of 11 years old, EcoSpot is only to be used in the supervision of an adult, a parent or a teacher. We verify the age of children by working with schools through our sign up process, children will sign up to EcoSpot through an access code provided to them by teachers within their school. We decide not to offer our service directly to children, and we mitigate the risk of them gaining access, by requiring any type of user (student or non-student) to obtain an assigned access code to begin creating an EcoSpot account.

We enable students in all age groups to record the climate action they take by taking and uploading photos to the Service, earning green action points by taking part in challenges, viewing content posted by their school admin accounts and viewing their placement on a leaderboard.

We designed admin accounts to allow school staff to moderate content uploaded by children within EcoSpot to ensure it is appropriate to their age.

Transparency and Choice
We provide transparent age appropriate privacy information (see Privacy Policy for Students) . Our Privacy Policy for Students presents only limited, easy to understand information. However, students have the option to view more detailed information by selecting options provided within the document.

We may also anonymise personal data (so that it can no longer be associated with any specific student) for analytics, research or statistical purposes, in which case we may use this information indefinitely without further notice.

Changes to this Data Protection notice
We will be transparent about our practices, so that you can make informed choices about how your personal information is used. If we make a material change, we will post a notice on our service or this website page and/or we will notify you by email (if you have provided an email address to us).

4. Detrimental use of data
We observe the rules concerning marketing communications featuring or addressing children set out in the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code). We do not allow any third party marketing communications within EcoSpot.

5. Policies and community standards
We operate our service and use personal data of children in compliance with our published terms and policies:
this Data Protection Statement;
our Privacy Policy;
our Privacy Policy for Students;
and our Terms of Use.

Data minimisation
We collect and retain only the minimum amount of data required to provide our service. Student accounts can be created in the following ways:
- by the student if a teacher provides the student with an access code
- by the student’s parent if a teacher provides the parent with an access code
- by the student’s teacher

If a student’s school or teacher provides access codes in school or otherwise sets up a student’s account, the school will be responsible for obtaining any necessary parental consent to create the account on behalf of the student and let students access their accounts. Teachers may request unique access codes, access codes per form group or per year group at their own discretion. Alternatively, a teacher may choose to allow students to set up their own account using an access code provided by the teacher. When students set up their own EcoSpot account, we ask students to provide a unique username (we advise students not to use their real names), a password and the unique code they have been given by their teacher to connect with the school community. If EcoSpot has been provided with parent emails to obtain consent, we will only use this email for the aforementioned reason and we will not use parent emails provided this way to market our product to the parent, unless the parent has opted in to email marketing or has separately created an account on our service. We don’t ask students to enter any other personal information when setting up an account.

7. Data sharing
Photos:
Once a student has created their account and parental or school consent is obtained, students will be able to take and upload photos to participate in challenges which will be collected by EcoSpot once the content has been actively uploaded by the child within the service. The photo can only be viewed by the student, the student’s peers within the school, and the student’s teachers and school leaders. If the school or teacher elects to utilise EcoSpot in the classroom, the school will be responsible for obtaining any necessary parental consent. Additionally, the student’s teachers will moderate the school community's posts within challenges.

What Student Information is Shown Publicly? No student’s account, profile, or photo uploads are made available or visible to the public through EcoSpot. No child can upload a photo to the platform except through their account. This can’t happen for children without either (1) the parent providing parental consent directly to EcoSpot or (2) the child’s teacher representing to EcoSpot that they have obtained any necessary parental consent, including acting as the agent of the parent if their school policy allows.

We Never Sell Personal Information: We will never sell or rent your personal information or non-personal information. We will only share or disclose personal information with a limited set of third-party service providers necessary to provide or develop our services (such as database hosting) or as required by law, and we will be transparent about who these service providers are. We will require that these service providers process personal information in accordance with our Privacy Policy and ensure that these service providers employ reasonable and comprehensive data protection and security protocols.

You own your data: We don’t own any data you provide or we receive - you (students, parents and/or schools) will own your content and information.

8. Data Retention
We will not retain student personal information for any longer than is necessary for educational purposes and legal obligations, or to provide the service for which we receive or collect the student personal information. Additionally, we protect students by (1) collecting the only minimal information from students necessary to register for the Service, (2) deleting Students’ Accounts if they’re inactive for more than eighteen months.

9. Geolocation
We use Google Analytics to provide us with information about how EcoSpot is used through the use of cookies. This includes tracking the location of the country and city from which EcoSpot is accessed. The use of all non-essential cookies (including those that collect geolocation data) are only activated if the user accepts such other cookies. We do not track the exact location of students.

10. Parental controls
EcoSpot is available to children who are at least 13 years old and legally capable of providing their own consent to the use of their personal data within online services. EcoSpot is also available to under 13s only for educational purposes. For these reasons, we did not introduce any parental controls that would allow parents or guardians to place limits on or monitor students’ activity on EcoSpot.

Profiling
We do not use any forms of profiling.

12. Nudge techniques
We do not encourage children to provide unnecessary personal data or weaken their privacy settings.

Both students and non-student registered users can email team@ecospot.io to request a copy of their data, correction of their data or deletion of their data.