picturepath Mobile Application | Privacy Policy

At picturepath we are committed to protecting and respecting your privacy. This Privacy Policy (“policy”) outlines details of the personal data (“information”) that we collect, store and process, the measures we take to protect and safeguard this information and how we will ensure we meet our legal obligations to you under the UK data protection rules.

Please read this privacy policy carefully as it contains important information about how we will use your information.

Who are we?

The picturepath application (“app”) is brought to you by picturepath Ltd. picturepath is a limited company registered in England (Company number 10746396) with registered address 17 Boundary Street, Liverpool, England, L5 9UB. For the purposes of this policy, picturepath Ltd is the ‘Data Controller’ and assumes that role under UK and European Law and is registered with the Information Commissioner’s Office.

What information do we collect and how do we use it?

We collect personally identifying information from you in a number of ways though your use of our application – broadly this breaks down into two categories:

Information you provide to us within the application
Information obtained relating to the use of the application

Information you provide through the application

In signing up to use the application you will have provided details of your Name, email address and password. This information is used to provide login capabilities with a distinct identity and to keep the data you enter into the application secure We will use your email address to send password reset and other account management communications. Our basis for this processing is the legitimate interest of picturepath in providing you with the benefits of the application and developing and improving the application.

Your email address may also be used to send you updates to the service we provide you with including details of new features and updates to the application and customising the application and its content to your particular preferences. Our processing basis for this communication is Consent, which you will be requested for at the time you signed up for the service.

Within the application you are able to add the details of the children under your care. This information consists of the name of the child (note: this does not have to be the child’s full name) along with a photo or image to represent the child in the application. This data is used to provide personalisation within the application and is optional.

At the time of adding a child’s details you will be prompted to verify that you are an adult with legal responsibility to grant consent for the storage and processing of the information you have supplied relating to the child. Our legal basis for processing and storing this information is legitimate interest, qualified by reasonable expectation for the use of the data.

We may retain a record of any contact you make with us.

Information about application usage

Picturepath gather information about the users of the application and their use of the application. This information consists of details of the Picturepath account being used and the application use (screens used, input fields filled out, etc). This data is obtained and processed using a system called Amplitude, operated by Amplitude, Inc., 501 2nd Street, Suite 100 San Francisco, CA 94107, United States of America. Amplitude was accredited with the EU-US Privacy Shield Framework, ensuring that it provides the same level of security and privacy protection as in the UK and EU.

Picturepath also gather information relating to the network (IP) address of your computer / tablet / phone. This information is considered to be personally identifiable data and is processed to allow us to provide a reliable experience and to allow us to better secure and protect our users’ information. Our basis for this processing is Legitimate Interests, to support network security.

Picturepath does not perform any automated decision making based upon any personal data.

How long do we hold data for?

We only hold your data for as long as you have an active account, after which we will remove it.

Picturepath only retain data for as long as it is strictly required. This means data that you provide through the application is held for as long as you have an active account. We consider an account to be active if it has been logged into in the prior 12 months. After this time the account will be removed and all stored data for that account will be removed from our systems. Prior to removal we will attempt to contact you to inform you of the account closure.

In order to operate a reliable system and to avoid data loss we perform regular encrypted backups of the system. These backups are retained for up to 90 days, and after this time are removed. This means that a removed account will be completely removed from all backups 90 days after removal.

Who has access to your data?

We won’t share or sell your information or allow the use of your information for marketing, however we will share relevant information with our suppliers to help us deliver our services to you.

Picturepath will not sell or rent your information to third parties, and we do not share information for marketing purposes with any third parties

Picturepath may share data with 3rd party suppliers working on our behalf – this includes contractors, agents and other subcontractor who work for PicturePath to provide services and complete tasks for the delivery of our service. Where such a relationship is in place there are contractual safeguards in place to protect your information. Picturepath will only share data that is relevant to the tasks being completed and to the delivery of service to you, and where possible the data will be anonymised. None of these organisations and individuals are permitted to use the data for any other purpose.

You may elect to use the Picturepath system to share information you have entered into the system with third parties (such as teachers, other carers, etc). This data sharing is consent based, and managed in the application. At any time you will be free to remove consent through the application.

How will we keep your data secure?

Picturepath has been designed with a privacy first development methodology meaning that we follow a rigorous development process which places the security of personal information at its core. To that end we host our application using a GDPR compliant cloud data provider (Amazon Web Services) hosting the application in the UK. All of our services run over HTTPS using TLS ensuring data transmitted between the application and our servers is secure. Data you provide to us which is stored is encrypted when it is stored, and in any backups taken. We take lengths to ensure that the network environment in which the application is hosted is kept secure by following best practices and ensuring that security updates are applied in a timely fashion

How do we support your rights?

You have the right to request confirmation that your information is being processed, access to it (through us providing a copy) and other information about how we process your personal data.

We will not contact you for marketing purposes by email unless you have given your prior consent. You can change your marketing preferences at any time by contacting us by email: support@picturepath.co.uk.

The accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate, not complete or out of date and you cannot already change it in the app, please email us at support@picturepath.co.uk

You have the right to ask for a copy of the information PicturePath holds about you. We may, in some circumstances, charge £10 for information requests to cover our costs in providing you with details of the information we hold about you.

You have the right to ask us to erase or delete your information where there is no reason for us to continue to process it. This right would apply if we no longer need to use it, where you withdraw your consent for us to process special categories of your information, or where you object to the way we process your information.

You have the right to ask us to restrict or block the processing of your information. This right applies where you believe the information is not accurate, you would rather we block the processing of it rather than erase your information.

You have the right to port your information by obtaining it from us to reuse for your own purposes across different services. This allows you to move personal data easily to another organisation, or to request us to do this for you.

Right to remove consent

Where we rely upon your consent to perform data processing we allow you to revoke the previously granted consent by contacting us at support@picturepath.co.uk whereupon we will comply with your request.

Use of cookies

Like many other websites and apps, PicturePath uses cookies. Cookies are small pieces of information sent by an organisation to your computer or device and stored on your hard drive to allow that app to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. This helps us to improve our app and deliver a better, more personalised service.

It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit our full cookies policy. Turning cookies off may result in a loss of functionality when using our app. For further information about cookies and how to disable them please to go www.aboutcookies.org or www.allaboutcookies.org