Privacy Policy

Last Updated: November 2023

At Mindless Academy, we are committed to protecting your personal information. We have published this privacy notice to ensure that you are fully aware of what personal information we collect from you, how we use it, who we share it with and what your rights are. This privacy notice applies to university students and graduates who apply for and take part in our Virtual Work Experience programme and the services we may provide to you and members of staff who work for our University Partners.

Our website uses cookies. Please read this privacy notice and cookie policy carefully as it contains important information about who we are and how we use cookies on our website. This privacy notice and cookie policy relates to your use of our website www.mindlessacademy.com.

WHO ARE WE?

“We”, “our” or “us” means Mindless Academy Limited. We offer a virtual work experience designed to empower students and graduates with the mindset, skills, and experience to work in digital marketing and content creation in the United Kingdom.

This privacy notice primarily sets out what we do with your personal information as controller. Please see below for more information.

If you have any questions about this privacy notice, please contact us at info@mindlessacademy.com.

COOKIES ON OUR WEBSITE

We have set out below what personal information we collect about you using cookies and how we use your personal information. In addition, we have set out our legal basis to use your personal information as we need to tell you this under data protection law.

What are Cookies?

We collect, store and use personal information via cookies when you visit our website. A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. These help us recognise you and your device and store some information about your preferences or past use of the website.

We use cookies on this website to:

Carry out research and statistical analysis to help improve our content, products and services and to help us better understand our users’ requirements;
Target our marketing and advertising campaigns more effectively;
Recognise your device whenever you visit this website; and
Make your online experience more efficient and enjoyable.

Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.

DOES THIS PRIVACY NOTICE AND COOKIE POLICY COVER WEBSITES YOU LINK TO FROM THIS WEBSITE?

Links within our website to other websites, such as Instagram and LinkedIn and any other links to third party websites we may add from time to time, are not covered by this privacy notice and cookie policy. You should review the privacy information on those websites to find out how they may use your personal information

Third parties that our website links you to may also use cookies, over which we have no control. The third parties may include, for example, advertising networks and providers of external services such as web traffic analysis services. These third party cookies are likely to be analytical or performance cookies or targeting cookies and will each have their own cookie policy in place that can provide you with further information that explains how they will use cookies.

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU IF YOU APPLY FOR OUR VIRTUAL WORK EXPERIENCE?

If you are a student or a graduate and apply to our Virtual Work Experience programme we will collect, store and use the following personal information:

Full Name
University Email Address
Personal Email Address
University Course
Year of Study
Student ID
Level of Study

We may also collect the following special category personal information.

Information within your application form which may contain sensitive information where accidental and incidental disclosures are made such as:
- your physical or mental health information
- your racial or ethnic origin.
Declaration of disability (if applicable).

HOW WILL WE USE YOUR PERSONAL INFORMATION IF YOU APPLY FOR OUR VIRTUAL WORK EXPERIENCES AND WHAT IS OUR LEGAL BASIS FOR USING IT?

If you apply to our Virtual Work Experience programme, we will use your personal information to:

assess your application form; and
verify that you currently attend university in the UK.

This will be done on the legal basis that it is necessary for the performance of a contract with you or in relation to taking steps to put that contract in place.

If your application is successful, we will use your personal information to:

enrol you onto our Virtual Work Experience programme;
set you up with an account to access and upload content; and
contact your university to advise that you have enrolled with us on our Virtual Work Experience programme.

This will be done on the legal basis that it is necessary for the performance of a contract with you or in relation to taking steps to put that contract in place.

We will use your special category personal information to:

make reasonable adjustments to your Virtual Work Experience programme.

Under data protection law we must also have a legal basis to use your more sensitive personal information. Our ordinary legal basis for this use is as set out above and on the additional Article 9 condition that you have provided your explicit consent. Should you wish to withdraw your consent you may do so at any time by contacting us at info@mindlessacademy.com.

If your application is unsuccessful, we will use your personal information to:

keep a record of your unsuccessful application; and
contact you about upcoming events and similar opportunities.

This will be done on the basis that it is in our legitimate interests to know if you have previously applied to our Virtual Work Experience programme, identify you and contact you with further information about upcoming events and similar opportunities. We believe that this is a proportionate use of your personal information as it is in accordance with your reasonable expectations, it is relevant and appropriate to our relationship with you and we only use your contact details and practice details for matters which relate directly to our relationship with you. We do not use them outside of the business context. Please contact us at info@mindlessacademy.com if you would like further detail about our legitimate interests.

HOW WILL WE USE YOUR PERSONAL INFORMATION IF YOU ENROL ONTO OUR VIRTUAL WORK EXPERIENCES AND WHAT IS OUR LEGAL BASIS FOR IT?

When you enrol and begin using your account, we will use your personal information to:

identify you and the content you have created;
contact you;
monitor your activity and improve our services.

This will be done on the basis that it is in our legitimate interests to identify you and the work you have created, and monitor your activity to ensure you are getting the most out of our Virtual Work Experience programme. We believe that this is a proportionate use of your personal information as it is in accordance with your reasonable expectations, it is relevant and appropriate to our relationship with you and we only use your contact details and practice details for matters which relate directly to our relationship with you. We do not use them outside of the business context. Please contact us at info@mindlessacademy.com if you would like further detail about our legitimate interests.

We will also use your personal information to:

share updates on your progress and final results with your university; and

We will do so on the basis that you have provided your consent to do so. Should you wish to withdraw your consent you may do so at any time by contacting us at info@mindlessacademy.com

If you experience any technical issues whilst on our Virtual Work Experience, we will use your personal information to:

track your user experience on our website;
create a ticket to keep track of your issue;
investigate the issue affecting our website, content, and fix this, as appropriate; and
contact you for feedback.

This will be done on the basis that it is in our legitimate interests to identify and fix the issue affecting our services for us to be able to improve them. We believe that this is a proportionate use of your personal information as it is in accordance with your reasonable expectations, it is relevant and appropriate to our relationship with you and we only use your contact details for matters which relate directly to our relationship with you. We do not use them outside of the business context. Please contact us at info@mindlessacademy.com if you would like further detail about our legitimate interests.

WHEN WE COLLECT YOUR PERSONAL INFORMATION FROM OTHER SOURCES

If you are a student at one of our University Partners and you join our Virtual Work Experience programme via your university we will collect, store and use the following personal information from your university:

Full Name
University Email Address
Personal Email Address
University Course
Year of Study
Student ID
Level of Study

We may also collect the following special category personal information.

Information within your application form which may contain sensitive information where accidental and incidental disclosures are made such as:
- your physical or mental health information
- your racial or ethnic origin.
Declaration of disability (if applicable).

We will use your personal information to:

enrol you onto our Virtual Work Experience programme;
set you up with an account to access and upload content; and
contact your university to advise that you have enrolled with us on our Virtual Work Experience programme.

This will be done on the legal basis that it is necessary for the performance of a contract with you or in relation to taking steps to put that contract in place.

We will use your special category personal information to:

make reasonable adjustments to your Virtual Work Experience programme.

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU IF YOU WORK FOR ONE OF OUR UNIVERSITY PARTNERS?

If you work as a member of staff for one of our University Partners we will collect, store and use the following personal information provided directly by you/the organisation you work for:

Full name
Business email address

HOW WILL WE USE YOUR PERSONAL INFORMATION IF YOU WORK FOR ONE OF OUR UNIVERSITY PARTNERS AND WHAT IS OUR LEGAL BASIS FOR USING IT?

If you work as a member of staff for one of our University Partners, we will use your personal information provided directly by you/the organisation you work for to:

Contact you to arrange the enrolment of students on to our Virtual Work Experience programme;
Contact you to develop bespoke module frameworks, manage university partner networks, mentoring and workshops; and
Contact you to provide feedback on the performance of students on our Virtual Work Experience programme.

This will be done on the basis that it is necessary for the performance of a contract with you or in relation to taking steps to put that contract in place.

OTHER USES OF YOUR PERSONAL INFORMATION

If you contact us by email or would like to arrange a call, we will collect, store and use the following personal information:

your name;
your email address;
your contact telephone number (if you choose to provide this); and
details of your enquiry.

When you contact us we will use your personal information to review, consider and deal with any enquiry that you have raised. This will be done on the basis that it is in our legitimate interests to be able to discuss any enquiry or issue that you raise with you. In order to ensure that you receive our best customer service, we will retain previous communications which we have had with you. Please contact us at info@mindlessacademy.com if you would like further detail about our legitimate interests.

We may also collect, store, and use your personal information for the purposes of bringing or defending any legal proceedings or meeting any legal or compliance obligations we have. Where we use your personal information for the purposes of meeting any legal or compliance obligations, we will do this on the legal basis that it is necessary for compliance with a legal obligation.

Where we use your personal information for the purpose of bringing or defending legal proceedings our legal basis will be that it is in our legitimate interests. Please contact us at info@mindlessacademy.com if you would like further detail about our legitimate interests.

WHAT HAPPENS IF YOU DON’T PROVIDE THE PERSONAL INFORMATION WE HAVE ASKED FOR?

If you don’t provide the personal information we need when we ask for it, we may not be able to respond to you or enrol you onto our Virtual Work Experience. For example, if you are a student and you do not give us your university email, we will not be able to verify your course or approve your application. Similarly, if you do not give us your business contact details if you are a member of staff at one of our University Partners, we will be unable to speak with you. If you have any concerns about whether you need to provide your personal information, please contact us at info@mindlessacademy.com.

WILL WE USE YOUR PERSONAL INFORMATION FOR AUTOMATED DECISION-MAKING?

We do not use your personal information to make decisions that will have a significant impact on you based solely on automated decision making (i.e. one without human intervention).

WILL WE CHANGE THE WAY WE USE YOUR PERSONAL INFORMATION?

We will only use your personal information for the purposes set out in this privacy notice. We can only change the purposes we use your personal information for, by telling you where we need to use it for another reason and that reason is compatible with those purposes set out in this privacy notice. If we need to use your personal information for any other purpose, we will notify you and we will explain the legal basis which allows us to use your personal information for this other purpose in a similar way to how we have done it in this privacy notice.

HOW WILL WE KEEP YOUR PERSONAL INFORMATION?

We will not keep your personal information for longer than we need it for the purposes we have explained in this privacy notice. We have outlined our retention periods below.

If you are a student/graduate and apply to or enrol onto our Virtual Work Experience:

We will keep your personal information in our active systems.

If you choose to no longer participate in the Virtual Work Experience and leave before the end of the 4-week period, we will retain your information for data purposes. We may keep your personal information in our backup systems.

If you apply for our Virtual Work Experience and your application is unsuccessful, we will retain your information for data and update purposes.

If you are a member of staff at one of our University Partners:

We will keep your personal information in our active systems for as long as needed to facilitate the University Partner relationship with you/the organisation you work for, whichever is longer.

We will only keep the personal information derived from cookies for the period specified in the table above.

If a dispute arises between us, we will keep your personal information for the purposes of responding to and dealing with this dispute and this may mean that we keep your personal information for longer than as set out above. Please contact us at info@mindlessacademy.com if you would like any further information about our retention periods.

We will ensure that your personal information is securely deleted after the retention periods stated above have expired.

WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH?

We may share your personal information with trusted third parties from time to time. We do not sell any personal information to any third party so that they can send you their marketing material.

We have set out below the third parties we may share your personal information with. If we do this, we will put in place a contract with them which controls how your personal information may be used and which requires that your personal information is treated in accordance with data protection laws.

With your university: We will share your personal information and the content you create with your university. These will be subsequently stored on your university’s record systems as part of your educational record. If you would like your personal information to be made anonymous, you can contact us at info@mindlessacademy.com.]

With companies who provide support for our internal IT systems: We use reputable third parties to provide us with our IT systems (including our website and website hosting providers) and support for them. They may access your personal information to the extent that they need to in order to provide their services and deal with any issues.

With a company that we merge with or transfer our business assets to: In the event that we sell all or part of our business, or merge with another company, we may transfer personal information that we have collected as described in this privacy notice, along with our other business assets, to the company that we are selling to or merging with.

With entities, organizations or individuals for legal reasons: We will share your personal information with entities, companies or individuals where this is strictly necessary to comply with any law, rule, regulation, governmental request or legal procedure that is applicable to us.

With entities, companies or individuals to obtain advice: We will share your personal information with external professional advisors such as lawyers or accountants in order to take advice and for the purposes of legal and tribunal proceedings or to enforce the terms of our agreements.

With website tracking companies: We will share data that we collect from cookies with external website tracking companies in order to obtain the business names for companies that visit our website in accordance with our cookie policy above.

We will only disclose such personal information to any third party as is necessary to enable them to carry out the function or purpose for which it is disclosed. If you would like further information on the third parties we may share your personal information with and our legal basis for sharing your personal information with third parties, please contact us at info@mindlessacademy.com.

WILL WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE THE UK/EEA?

European Economic Area (“EEA”) countries are all EU Member countries together with Iceland, Liechtenstein, and Norway. The United Kingdom (“UK”) is no longer an EEA country, but its data protection laws are aligned with those of the EEA countries.

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

Our IT service providers located outside the UK in Canada and the US. This is where we use the services of Thinkific to provide the platform for our programme, and Google Drive and Sharepoint where we share information with you and the university partner) for the purposes of storing a copy of your personal data on computer equipment so that it can be accessed by us and our permitted IT service providers online in order to run our business and provide our services. Our lawful safeguard for this is that we have entered into approved standard data protection clauses with such IT service providers. Please contact us at info@mindlessacademy.com if you require copies of their privacy policy documentation.

We will only transfer your personal information outside the UK and EEA where we have a legal basis for doing so and where we require that your personal information is protected to the same standard as it would be protected in the UK and EEA. We will do this by entering into data sharing agreements with the recipients of your personal information based outside the UK and EEA which comply with the EU Commission’s standard clauses or the UK’s international data transfer agreement for the transfer of personal information.

If you would like further details about our transfer of your personal information outside the UK and EEA or details of the safeguards put in place in relation to your personal information, please contact us at info@mindlessacademy.com.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We have put in place appropriate security measures to prevent your personal information being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties (see above) who have a business need-to-know.

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

Our security procedures mean that we may occasionally request proof of identity before we are able to disclose personal information to you.

WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL INFORMATION?

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) if you are unhappy about the way your personal information is being used – please refer to the ICO website for further information about this (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact us at info@mindlessacademy.com.

You have a number of other rights over your personal information which are:

The right to ask us what personal information we have about you and to have a copy of your personal information from us;

The right to ask us to correct any errors in your personal information;

The right to object to our legitimate interests, profiling activities and direct marketing communications;

The right to ask us to provide you with a copy of the personal information you have provided to us, in a structured, commonly used and machine- readable format and the right to transmit that personal information to another entity where: (i) we are using your personal information on the basis of your consent or on the basis that it is necessary to perform a contract with you; and (ii) the use we are making of your personal information if carried out by automated means;

The right to ask us to delete your personal information where: (i) we don’t need your personal information anymore; (ii) you withdraw your consent to our use of your personal information and we have no other legal basis to keep your personal information; (iii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing; (iv) our use of your personal information is illegal; (v) we have to delete your personal information to comply with our legal obligations;

The right to ask us to restrict the use that we are making of your personal information where: (i) you don’t think the personal information we have about you is correct so that we can check if it is correct; (ii) what we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it; (iii) we don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights; and (iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing; and

Where our use of your personal information is based on your consent, the right to withdraw your consent at any time by contacting us at info@mindlessacademy.com.

If you want to access or correct your personal information, request your personal information to be deleted, object to, or restrict the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us at info@mindlessacademy.com.

HOW WILL WE TELL YOU ABOUT CHANGES TO THIS PRIVACY NOTICE?

We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on our website and if the changes will have a material effect on you or the way we use your personal information, we will bring them to your attention by email where appropriate and where we have your contact details. This privacy notice was last updated in November 2023.

HOW CAN YOU CONTACT US?

If you have any questions about this privacy notice, please contact us at info@mindlessacademy.com.