STAYSHARP EDUCATION LIMITED Privacy Policy

What is the purpose of this Privacy Policy?

StaySharp respects your privacy and is committed to protecting your personal data. The aim of this Privacy Policy is to give you information on how StaySharp collects and processes your personal data through:

1. your use of the StaySharp website or app, including any data you may provide through the StaySharp website or app when you make an enquiry, register for or purchase any course.
2. your use of any StaySharp social media channel; and
3. the provision of personal data to StaySharp by any other means.

This Policy will also inform you of what we do with personal data, how we look after personal data and tell you about your privacy rights and how the law protects you.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice 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 the other notices and is not intended to override them.

This Privacy Policy is provided in a layered format so, if you wish, you can select the specific areas of the Policy you are interested in, as set out below. We have also included a Glossary to help you understand the meaning of some of the terms used in this Privacy Policy.

1. WHO WE ARE
2. IMPORTANT INFORMATION ABOUT THIS POLICY
3. YOUR PERSONAL DATA
4. HOW YOUR PERSONAL DATA IS COLLECTED
5. HOW WE USE YOUR PERSONAL DATA
6. DISCLOSURES OF YOUR PERSONAL DATA
7. COMPLIANCE WITH BRIBERY ACT AND RELEVANT LEGISLATION
8. MOODLE
9. INTERNATIONAL TRANSFERS
10. DATA SECURITY
11. DATA RETENTION
12. YOUR LEGAL RIGHTS
13. GLOSSARY

1. Who we are

Data Controller

StaySharp Education Limited is a subsidiary of BPP Holdings Limited. This Privacy Policy is issued on behalf of StaySharp Education Limited so when we mention “StaySharp”, “we”, “us” or “our” in this Privacy Policy, we are referring to StaySharp Education Limited only, and not BPP Holdings Limited or other companies within that group.

This Policy shall apply to any StaySharp website including any subdomains that may be made available by us from time to time; including websites with the ending staysharp.global and all StaySharp social media channels (“ Website(s) ”):

Website Domain (and any subdomains)	Relevant Data Controller
Staysharp.global	StaySharp Education Limited

Contact details

We have appointed a data protection officer (“ DPO ”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the following details:

FAO of the Data Protection Officer

StaySharp Education Limited

Legal Team

4th Floor, 3 London Wall Buildings

London, EC2M 5PD

Email address: Dataprotection@bpp.com

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 (or other relevant authority) so please contact us in the first instance.

2. Important information about this Policy

Changes to the Privacy Policy and your duty to inform us of changes

This Privacy Policy sets out your rights under the Data Protection Act 2018 and the UK General Data Protection Regulation.

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.

We keep this Privacy Policy under review and may update it from time to time. This version was last updated on 21 January 2022.

If you reject the terms of this Privacy Policy

If you do not agree to your personal data being used in accordance with this Privacy Policy, please do not submit your personal data to us through the Website, apps or any other means.

Third-party links and products

The Website (and apps) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Website or app, we encourage you to read the privacy policy of every website you visit.

3. Your personal data

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 we have grouped together as follows:

• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account, billing information and payment card details.
• Identity Data includes first name, maiden name, last name, usernames for StaySharp sites (including for learning.staysharp.global or similar identifiers (including any registration number assigned to you by an external body such as ACCA/CIMA, SRA/BSB), marital status, title, date of birth and gender.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Profile Data includes your usernames and passwords (for StaySharp platforms), purchases or orders made by you, your interests, preferences, feedback, reviews, survey responses and enquiries submitted to StaySharp.
• Customer Data includes the course you have purchased from StaySharp, records of achievements on the course (test, assessment and mock results), course assessments submitted by you, access and progress information, emails or live chat messages sent by you to StaySharp and any complaints made by you or about you to StaySharp.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or StaySharp app.
• Transaction Data includes details about payments to and from you and other details of courses you have purchased from us.
• Usage Data includes information about your visit to a Website or StaySharp app, including the Uniform Resource Locators (URL) clickstream to, through and from the Websites or apps (including date and time), courses you viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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.

Special Categories of Personal Data

The law requires that “special categories” of particularly sensitive personal information require higher levels of protection than other personal data.

For some courses, where you choose to provide such information, we may also collect, store and use the following “special categories” of more sensitive personal information:

Information about any disabilities or learning needs – this information is collected so that any reasonable adjustments can be made to accommodate customers with disabilities and also to ensure that any learning needs are supported. This information is voluntary.

We do not collect any other 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 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 register you onto a course). In this case, we may have to cancel/restrict a course you have with us, but we will notify you if this is the case at the time.

4. How your personal data is collected

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

• Direct interactions. You may give us your Identity, Contact, Financial and Marketing and Communications Data by filling in forms or by corresponding with us. This includes personal data you provide when you:

1. purchase a course;
2. submit an online query or use our online live chat feature;
3. create an account on our Website;
4. download and use any StaySharp app;
5. request marketing to be sent to you;
6. enter a competition, promotion or complete a survey; or
7. give us feedback.

• Through your use of the Course. You may give us your Customer Data throughout your use of a course. This includes personal data you provide when you:

1. access online learning sessions;
2. take tests or other forms of assessment (including mocks) or
3. submit assessments to StaySharp.

Automated technologies or interactions. As you interact with our Website or apps, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

• Third parties. We may receive personal data about you from various third parties as set out below:
• Identity, Contact, Transaction and Customer Data from any third party survey/review organisation or portal provider, such as Qualtrics or TrustPilot ^∆ ;
• Technical Data from analytics providers such as Google, Sessioncam, Hotjar and Optimizely; or
• Contact, Financial and Transaction Data from providers of technical and payment services such as Shopify ^∆ .

5. How we use 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.
• 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 or regulatory obligation.
• Where we have your consent.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Where we are relying on your consent as a legal basis for processing your personal data, you may withdraw your consent to this processing at any time by contacting us .

Purposes for which we will use your personal data

We have set out below, in a table format, a description of 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.

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.

Please be aware that, if you have purchased a course with StaySharp, in the majority of cases we will have a contract in place with you. Therefore, our lawful basis for processing your personal data will be to perform our contract with you.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
Customers
To respond to enquiries or requests for information	a. Identity b. Contact	• Performance of a contract with you; or • Consent
To register you on a course	a. Contact b. Identity	• Performance of a contract with you
To deliver the course to you	a. Contact b. Identity c. Profile d. Customer	• Performance of a contract with you
To: • Manage payments, fees and charges • Collect and recover money owed to us • Keep records for audit/accounting purposes • Defend any legal claims brought against StaySharp	a. Identity b. Contact c. Financial d. Transaction e. Customer	• Performance of a contract with you • Necessary for our legitimate interests (to recover debts due to us or defend legal claims) • Necessary to comply with a legal obligation
Suppliers to StaySharp
To register you as a supplier of StaySharp	a. Identity b. Contact	• Performance of a contract with you
To process and receive goods/services: • Manage payments, fees and charges • Keep records for audit/accounting purposes • Defend any legal claims brought against StaySharp	a. Identity b. Contact c. Financial d. Transaction e. Marketing and Communications	• Performance of a contract with you • Necessary for our legitimate interests (to recover debts due to us or defend legal claims) • Necessary to comply with a legal obligation
For All
To manage our relationship with you which will include: • Notifying you about changes to our terms or policies • Asking you to provide a review or take a feedback survey	a. Identity b. Contact c. Profile d. Marketing and Communications	• Performance of a contract with you • Necessary to comply with a legal obligation • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey/review	a. Identity b. Contact c. Profile d. Usage e. Marketing and Communications	• Performance of a contract with you • Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our Website or apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	a. Identity b. Contact c. Technical	• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) • Necessary to comply with a legal obligation
To deliver relevant Website or apps content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	a. Identity b. Contact c. Profile d. Usage e. Marketing and Communications f. Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website or apps, products/services, marketing, customer/client relationships and experiences	a. Technical b. Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website or apps updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods, services or events that may be of interest to you	a. Identity b. Contact c. Technical d. Usage e. Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
Where applicable, to provide learning support to customers who have learning needs	a. Data relating to disabilities and/or learning needs	• Performance of a contract with you • Complying with our legal obligations (under the Equality Act 2010) • Your explicit consent (this information is voluntary)

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

• Where we have notified you of the decision and given you 21 days to request a reconsideration.
• Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
• In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do use automated technologies and decision making when deciding what marketing messages you receive. However, we do not envisage that any other decisions will be taken about you using automated means, however we will update this Policy if this position changes.

Chat bots

We do also use “bots” to automate some of StaySharp’s administrative services such as through our chat bot (this service is provided by the third party Tidio). Bots are computer programmes made from a series of algorithms that allow them to carry out tasks without specific instructions. These bots are used to carry out repetitive tasks and attempt to mimic human behaviours. They may be used to respond to you via our website chat function. The personal data collected by these bots is processed in accordance with this Privacy Policy and is processed in the same way as if it had been collected by a member of StaySharp staff. Depending on your enquiry, a member of StaySharp staff may respond to your enquiry directly through the live chat service.

Marketing

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

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, courses and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased courses from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, 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 company other than StaySharp Education Limited for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by emailing us at Unsubscribe1@staysharp.global. Please note it may take up to 72 hours to process your request. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you entering into a contract with us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. We use a third party (iSenseLabs) to manage cookies preferences. If you disable or refuse cookies, please note that some parts of this 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 and that reason is 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.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

• Internal Third Parties as set out in the Glossary .
• External Third Parties as set out in the Glossary .
• Specific third parties marked with ^∆ listed in paragraph 4 above (under the ‘Third parties’ heading).
• Specific third parties listed in paragraphs 7 to 10 below.
• Future employers or education providers where you specifically request that we provide confirmation of Identity or Customer Data to those parties for reference purposes.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

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.

7. Compliance with the Bribery Act and relevant legislation

In this Privacy Policy, we have explained that your personal data may be used for the purpose of ensuring compliance with legal obligations and that it may be disclosed to StaySharp’s service providers or governmental departments. This includes for the purpose of enabling StaySharp Education Limited and BPP Holdings Limited and it’s group companies to comply with its obligations under the UK Bribery Act 2010 (the “ Bribery Act ”), the Criminal Finances Act 2017, The Money Laundering, Terrorist Financing and Transfer of Funds(Information on the Payer) Regulations 2017, Proceeds of Crime Act 2002 and any other local laws or regulations relating to similar purposes which relate to fraudulent, illegal or unethical behaviour (the “ Conduct Legislation ”).

StaySharp Education Limited and BPP Holdings Limited and it’s group companies may appoint one or more service providers to assist them in managing a whistleblowing helpline and a webpage which acts as a reporting mechanism (“ Helpline ”) to ensure compliance with Conduct Legislation.

It is possible that a StaySharp staff member or customer may report matters of concern through the Helpline and that your personal data may be used by StaySharp Education Limited and BPP Holdings Limited and it’s group companies, its service provider(s) which manage the Helpline and by such companies for the purpose of investigating any such report and taking remedial action thereafter. For example, if an employee suspects that another employee is misusing company records for his own purposes or is committing fraud involving your personal data, they may report this through the Helpline.

Should this happen, your personal data will only be used for the purpose of ensuring compliance by StaySharp Education Limited and BPP Holdings Limited and it’s group companies with the relevant laws and regulations. Wherever reasonably possible, your personal data will be anonymised prior to use for the purpose of investigations and remedial action so that it does not relate to you. However, in some specific circumstances this may not be possible as it may prohibit a full investigation and prevent compliance with a relevant regulation or Conduct Legislation. Any transfers to BPP Holdings Limited’s group companies and their service provider(s) which manage the Helpline and which may also be in the US or elsewhere in the world will be carried out in accordance with the law.

A limited number of specially trained employees from BPP Holdings Limited’s group companies will only have access to your personal data which is disclosed through the Helpline where and to the extent that this is necessary for the purposes of carrying out their roles and for the purpose of compliance. In any event, their access will be limited, secure, controlled and justified as BPP Holdings Limited and its group companies considers is fair and necessary in the circumstances. These employees will be subject to appropriate confidentiality obligations.

We encourage our employees to use the Helpline in good faith and only for serious or substantial issues which cannot properly be reported via other means.

Provided reports are made through the Helpline in good faith, we try to protect the confidentiality of your identity as far as is reasonably possible. However, we cannot guarantee this (especially in subsequent court or tribunal proceedings) and we are required to inform the subject of the reports about the allegation(s). Those subjects have the right to request their own personal data, as do you, as set out under Your Legal Rights .

8. Moodle

StaySharp provides an online learning experience to customers through Moodle. This online learning platform is also accessed by StaySharp staff in order to deliver courses to customers. Within the platforms the following data sharing is in operation:

• Your name, last log-in date, and course may be shared with other users of the platform, including StaySharp staff.
• The above details will be searchable to such other platform users.
• The platform may plug in to other software/platforms used by StaySharp (such as Panopto, Questionmark and Century Tech) where these platforms/software are used to provide training or assessment services to you.
• Third Parties chosen by StaySharp may review your interaction with the platforms to help StaySharp continuously improve the service.

9. International transfers

We may share your personal data with other group companies of BPP Holdings Limited (including outside of the UK) for the purposes of delivering the courses, providing IT support and administrative services.

However, we may also share your personal data with suppliers of IT services (including IT support and third-party software and learning platform providers). Therefore, we will transfer some of your data outside the UK.

The Websites, apps and/or any courses may be hosted on servers located outside of the UK and maintenance and support services for the Websites, apps and/or those courses may be provided from outside the UK. This means that your personal data may be transferred to, stored and processed in other countries apart from the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

10. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 on our instructions and they are subject to a duty of confidentiality.

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.

As set out in paragraph 9 above, your personal data may be held on the IT system of StaySharp Education Limited and BPP Holdings Limited and it’s group companies (e.g. for the purpose of providing courses to you) and/or on the IT system of another third party company (within or outside of BPP Holdings Limited and its group companies) within or outside the UK which is providing IT hosting or other data processing services, in accordance with StaySharp’s arrangement in place with that company.

All information that you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Websites or apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

11. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our Retention Policy which you can request by contacting us .

In some circumstances we may 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.

12. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data .
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

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

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best course 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 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.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal Third Parties

Other group companies of BPP Holdings Limited acting as joint controllers or processors and who are based in and outside the UK and provide administration services and undertake leadership reporting.

External Third Parties

• Service providers acting as processors based both inside and outside the UK which provide IT and system administration services (including Endava, Salesforce).
• Service providers acting as processors based outside the UK which provide live chat services (including Tidio).
• Services providers acting as processors based outside the UK which provide payment and subscription services (including Shopify and Recharge).
• Third party platforms which act as processors in respect of providing education (including Pantopto or Questionmark).
• Any professional body where this is relevant to your course (for example, certain Human Resources courses may require StaySharp to share information, including assessments, with the CIPD).
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• Debt recovery agents (including Oriel Collections and High Court Enforcement Group) where you owe a debt to BPP.
• HM Revenue & Customs, the UK Home Office, regulators and other authorities acting as independent controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• The police or governmental body, where the police/ governmental body make a request for personal information to StaySharp or as and when we consider necessary for the purpose of crime / fraud prevention.

Your legal rights

You have the 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 services or products to you. We will advise you if this is the case at the time you withdraw your consent.