Privacy Policy

Introduction

Purlos, a trading name of My Digital College Ltd (registered business number 11287890), provides software and services to the education sector, acting as a data processor for its clients in its Purlos App. This policy explains how we collect, process, and protect personal data in compliance with the UK Data Protection Act (DPA) and General Data Protection Regulation (GDPR).

By engaging with our services, you agree to the practices outlined in this policy.

Who We Are

Purlos partners with schools, colleges, and universities in the UK to enhance learner engagement, destination data collection and career development through digital tools, including WhatsApp Business integrations. We act as a data processor, handling data only as instructed by our clients, the data controllers.

Our Partners

As part of our services, we collaborate with:

  • Twilio, a messaging service provider enabling WhatsApp Business communications.
  • Meta Platforms, Inc., for WhatsApp onboarding and communication.

Data Collection and Usage

We process personal data strictly to provide our services.

Categories of Data Processed

  1. For Learners (on behalf of educational institutions):
    • Identity Data: Name, phone number.
    • Messaging Data: WhatsApp display name, template messages, and onboarding information.
  2. For Educational Institutions:
    • Contact Data: Staff names, email addresses, phone numbers.
    • Account Information: User preferences and activity logs.

Purpose of Processing

We process data to:

  • Facilitate WhatsApp onboarding via Meta.
  • Enable communication between learners and educational institutions through Twilio-powered messaging.
  • Provide reporting and insights to our clients.

Legal Basis

The lawful basis for processing is the performance of a contract with our clients. All data is processed as per client instructions and applicable legal obligations.

Third-Party Sharing

We share data only with trusted third parties essential for service delivery:

  1. Twilio: Enables WhatsApp messaging functionality. Data shared with Twilio includes phone numbers, message templates, and metadata. Twilio’s Privacy Policy.
  2. Meta Platforms, Inc.: Facilitates WhatsApp Business onboarding and communication. Data shared with Meta includes phone numbers and onboarding details. Meta’s Privacy Policy.

We ensure all third-party partners comply with relevant data protection laws.

Data Retention

We retain data for the duration specified by our clients or as required by law. Upon contract termination, data is securely deleted as instructed by the client and as per the agreement.

Data Security

We employ robust security measures to protect personal data:

  • Data is hosted on Salesforce data centres within the UK, using encrypted servers.
  • All transmissions use Transport Layer Security (TLS) with 2048-bit RSA encryption.
  • Access to personal data is restricted to authorised personnel only.

Your Rights

As a data subject, you have the following rights:

  • Access: Request a copy of your personal data.
  • Correction: Request corrections to inaccurate data.
  • Erasure: Request deletion of your data, subject to contractual or legal obligations.
  • Objection: Object to data processing based on legitimate interests.
  • Data Portability: Request the transfer of your data to another service provider.
  • Lodge a Complaint: Submit complaints to the UK Information Commissioner’s Office (ICO) or contact our Data Protection Officer (DPO).

Contact Information

If you have questions about this policy or wish to exercise your rights, please contact our Data Protection Officer (DPO):

David Bartlett
Email: ask@purlos.co.uk

Postal Address:
My Digital College Ltd
20 Wenlock Road, London, N1 7GU

Changes to This Policy

We may update this policy periodically to reflect changes in our services or legal requirements. Updates will be published on our website.