Privacy Policy

1. Introduction

Thank you for using our websites or otherwise interacting with us! We believe that privacy is important, and we take your privacy seriously. As used in this Privacy Notice, “Lanterna” or “we” means Lanterna Europe AB, reg. no. 556647-2931, and their subsidiaries and affiliates, as applicable depending on the context.

We are committed to protecting your privacy. This Privacy Notice outlines how we collect, use, and protect personal data obtained through our websites (including https://lanterna.com/ and https://eliteib.co.uk/), the Lanterna Learning Portal, our services, or otherwise (including if you interact with us outside of our services, for example as an event attendee or job applicant), and how you can exercise any rights available to you under applicable data privacy legislation, including the General Data Protection Regulation (GDPR), the UK Data Protection Act 2018 (UK GDPR), the Swiss Federal Act on Data Protection (FADP), the Family Educational Rights and Privacy Act (FERPA) and the Children’s Online Privacy Protection Act (COPPA).

Lanterna is the data controller in relation to the processing of your personal data in accordance with this Privacy Notice. Except for school customers as set out in Section 10, this Privacy Notice does not cover any processing of personal data that we conduct as a data processor, for example when we process data on behalf of a school (such as when we organise a course on the behalf of a school). In that scenario, the terms of the applicable data processing agreement will apply and we recommend reaching out to your educator in the first instance if you have any questions regarding that data processing.

2. PERSONAL DATA COLLECTED & PURPOSE

Below we’ve listed the main categories of data subjects and what personal data is collected, as well as the purpose for processing the personal data. It’s possible that you belong to more than one category, so make sure to read all categories that might be relevant for you. Personal data may also be collected if needed to comply with legal obligations.

Data subjects	Personal data collected	Purpose
Website visitors	IP address, location data, details about your device, how you navigate and use the website, and similar data.	The data is processed primarily for the purposes of (i) delivering the services requested by you, (ii) monitoring and improving our services, e.g. in order to optimise the website and reduce bugs, (iii) to communicate with you, including for marketing purposes where permitted, and (iv) for the purposes described for our use of cookies (see our https://lanterna.com/cookie-policy/).
Students using our tutoring services	Name, contact information, correspondence, academic information (such as school year and grade level), session recordings, etc.	The data is processed primarily for the purposes of (i) delivering, managing and improving our tutoring services, and (ii) student safeguarding.
Users of the Lanterna Learning Portal	User account related data, e.g., name and email, as well as personal data provided by users while using our services or otherwise generated through the Lanterna Learning Portal, e.g. IP addresses and metadata.	The data is processed primarily for the purposes of (i) delivering and managing the Lanterna Learning Portal, (ii) monitoring and improving the Lanterna Learning Portal, e.g. in order to optimise the website, reduce bugs and enforce security and resilience, and (iii) for the purposes described for our use of cookies (see our https://lanterna.com/cookie-policy/).
Potential or current customers (including students and/or their parents/guardians)	Contact details, name, title, email address, phone number, payment details, etc., whether obtained directly from you or from any other source.	The data is processed primarily for the purposes of (i) administering the potential or existing contractual relationship, (ii) student safeguarding, and (iii) to communicate with you, including for marketing purposes where permitted.
Job applicants (including tutor applicants)	Personal data provided by you in the recruitment process (e.g., name, CV, personal letter, etc.) and personal data generated by us (e.g., assessments). For tutors, we may also collect personal data relevant for student safeguarding purposes.  In addition, we source information from third parties, such as Facebook, Linkedin and other public sources, or occasionally, employees or others that make recommendations about potential applicants.	The data is processed primarily for the purposes of (i) managing and facilitating recruitment of new employees and consultants (including tutors) to our business, and (ii) student safeguarding.

We do not knowingly collect personal data from children under the age of 16 unless we have obtained consent from a parent or guardian. If you are under the age of 16, you may only use our website with consent from a parent or guardian. If you learn that a child has provided us with personal data in violation of this Privacy Notice, we ask you to alert us using the contact details below.

3. LEGAL BASIS FOR OUR PROCESSING

Lanterna processes your personal data for the main purposes of:

• providing the services requested by you or your parent/guardian or responding to your inquiries;
• fulfilling our obligations under the agreement with you and/or your parent/guardian for providing the tutoring services (where such an agreement has been concluded);
• student safeguarding;
• complying with legal obligations; and
• pursuing our legitimate interest in marketing and improving our services, where permitted.

If processing of personal data requires prior consent (such as a consent by a parent or guardian required by GDPR or COPPA), such consent will be collected before we carry out the processing in question. If you are under the age of 16, you may only use our website with consent from a parent or guardian.

4. HOW LONG WE KEEP YOUR PERSONAL DATA

We store your personal data only for as long as we need the personal data to fulfill the purpose it was collected for. In addition, we could be required to keep your personal data longer to fulfill legal obligations, but in that case, we won’t process the personal data for any other purpose.

Lanterna has retention routines in place to ensure that personal data is deleted as required.

5. HOW WE SHARE AND DISCLOSE PERSONAL DATA

We share your personal data with other companies in the Lanterna group of companies. 

We may also share your personal data with trusted third parties that provide services to us (such as our IT-suppliers) or other business partners. In such cases, your data may be shared with these third parties acting as service providers or subprocessors of Lanterna, and which process the data as required for the provision of the services to Lanterna. Lanterna is, as a data controller, always responsible for the correct processing of your personal data.

We will not share personal data with third parties for them to use for their own marketing purposes. We do not sell your personal data to anyone.

6. THIRD COUNTRY TRANSFERS

Your personal data may be processed outside the EU/EEA. When we transfer personal data from the EU/EEA to a country outside the EU/EEA, we’ll make sure that the transfer is lawful and safe by undertaking necessary security and contractual measures, such as (i) an adequacy decision by the EU Commission, the UK or the Swiss data commissioner of the Federal Council, as applicable, or (ii) implementing standard contractual clauses for the transfer of personal data to third countries (EUSCC) or the UK’s international data transfer agreement (IDTA).

7. DATA SECURITY

We aim to ensure that you at all times remain confident in trusting Lanterna with your personal data, and Lanterna has implemented such security measures necessary to protect your personal data from unauthorised access, modification and deletion.

With regard to your use of your Lanterna Learning Portal account, please ensure that you choose a unique and strong password, limit access to your computer and browser, and log out after having signed into your Lanterna Learning Portal account.

8. MARKETING AND DISTRIBUTION OF INFORMATION

We may send marketing and other information to you before or during our contractual relationship through channels including e-mail and WhatsApp. By providing your phone number or otherwise opting-in, you consent to receiving marketing, promotional, and informational messages via email and WhatsApp.

You can always opt-out from receiving marking information, either directly by following the instructions included in the marketing message (such as replying “STOP” via WhatsApp or using the unsubscribe link in emails) or by contacting us using the contact details at the bottom of this notice. However, it’s not possible to opt-out from our distribution of information that is not marketing but information relating to the provisioning of our services or similar.

9. OUR USE OF COOKIES 

Our websites use cookies, tags, tracking scripts, and pixels to enhance your experience and to improve our websites and services. Refer to our Cookie Policy (https://lanterna.com/cookie-policy/) for more information. By using our websites you consent to the use of website cookies in accordance with the Cookie Policy, in which you can also read more about how you can block, erase or withdraw your consent to these cookies.

10. US CUSTOMERS

Introduction

This section sets out how Lanterna collects, uses and discloses personal information and data through the provision of its education services, including its online courses, substitute teacher services and any other product or service that links to this Privacy Notice (the “Services”), to its customers (students and parents) and school customers (schools, school districts and state agencies, including their users (K-12 students, educators and staff)) in the United States.

In the course of providing the Services to a US school customer Lanterna may collect or have access to “education records,” as defined by FERPA, and personal information that is directly related to an identifiable student (collectively, “Student Data”). With respect to FERPA and US school customers, Lanterna receives Student Data as a “school official” under Section 99.31 of FERPA for the purpose of providing its Services, and such Student Data remains under the direct control of the relevant school customer.

Use of Student Data/Prohibitions

Lanterna uses Student Data collected from, or on behalf of, a US school customer to support the teaching and learning experience, to provide the Services to the school customer and its students and teachers and to ensure safe and effective operation of our Services.

Lanterna may use de-identified data as further described below in this Section 10.

Lanterna does not and will not:

• sell Student Data to third parties;
• use or disclose Student Data to inform, influence or enable targeted advertising to a student based on Student Data or information or data inferred over time from the student’s usage of the Services;
• use Student Data to develop a profile of an identifiable student for any purpose other than providing the Services to a school customer; or
• use Student Data for any commercial purpose other than to provide the Services to the school customer as authorised by the school customer, or as permitted by applicable laws (including FERPA).

COPPA: Lanterna does not knowingly collect personal information from children under the age of 13 unless and until a school customer or a parent/guardian has authorised us to collect such information. We comply with all applicable provisions of COPPA. To the extent COPPA applies to the information we collect, we process such information for educational purposes only, at the direction of the partnering school customer or a parent/guardian, and on the basis of verifiable parental consent (including the school customer’s informed consent on behalf of parents and guardians or as further detailed in the customer agreement).

Disclosure of Student Data

Lanterna shares or discloses Student Data only as needed to provide the Services under a customer agreement and in accordance with applicable laws, including:

• as directed or permitted by the school customer;
• to authorised personnel of the school customer entitled to access such data in connection with the Services;
• to our service providers, subprocessors or vendors who have a legitimate need to access Student Data in order to assist us in providing our Services. We provide these parties with the least information needed to do their work for Lanterna, and contractually bind them to protect Student Data in a manner consistent with those practices set forth in this Privacy Notice, including complying with applicable laws;
• to comply with applicable laws, respond to requests in legal or government enforcement proceedings (such as complying with a subpoena), protect our rights in a legal dispute or seek assistance of law enforcement in the event of a threat to our rights, security or property or that of our affiliates, customers, users or others, including for student safeguarding purposes;
• in the event Lanterna or all or part of its assets are acquired or transferred to another party, including in connection with any bankruptcy or similar proceedings, provided that the successor entity will be required to comply with the privacy protections in this Privacy Notice and applicable laws with respect to Student Data; and
• Lanterna may also share Student Data with Lanterna’s affiliated companies, provided that such disclosure is solely for the purposes of providing Services, including enforcing access and security protocols, and at all times is subject to this Privacy Notice, customer agreements, and applicable laws.

Lanterna maintains a record of disclosures as required under FERPA that it can make available to school customers upon request.

De-identified Data

Lanterna may use de-identified or aggregate data for purposes allowed under FERPA and other applicable laws to research, develop and improve educational sites, services (including the Services) and applications and to demonstrate the effectiveness of the Services. We may also share de-identified data with research and evaluation partners to help us analyse the information for service improvement and development purposes.

Records and information are considered to be de-identified when all personal identifiers such as name and email have been removed or obscured, such that the remaining information does not permit a student’s identity to be personally identifiable, taking into account all reasonably available information. Lanterna protects against the re-identification of de-identified data, and does not disclose de-identified data to its research and evaluation partners unless that party has agreed in writing not to attempt to re-identify such data.

Review and Correction; Student Data Retention

FERPA, COPPA, and other applicable laws require schools to provide parents and guardians with access to their children’s education records, and parents and guardians may request that the school correct records that they believe to be inaccurate or misleading. If you’re a parent or guardian and would like to review, correct or update your child’s data stored by us, contact the appropriate school customer (if your child’s use of our Services derives from a school customer) or use the details below to contact us (if your child’s use of our Services does not derive from a school customer). If applicable, Lanterna will work with your school customer to enable your access to and, if applicable, correction of your child’s education records. However, Lanterna cannot delete or modify education records or other records collected through our customer agreements unless directed to do so by a school customer. If you have any questions about whom to contact or other questions about your child’s data, you may contact us at info@lanternaeducation.com. 

Lanterna retains Student Data for the period necessary to fulfil the purposes outlined in this Privacy Notice and our customer agreements. Lanterna does not knowingly retain Student Data that has not been de-identified pursuant to this section beyond the time period required to support a school customer’s utilisation of the Services, to enforce security and resilience, for student safeguarding purposes and to comply with legal obligations. Upon notice from our school customers, Lanterna will delete Student Data stored by Lanterna in accordance with applicable laws and customer requirements. We may not be able to fully delete all data in all circumstances, such as information retained in technical support records, customer service records, back-ups and similar business records.

11. SUPPLEMENTAL PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS

Introduction

This section explains Lanterna’s commitment to comply with California law and applies to personal information of California residents collected in connection with our websites and our hiring and recruitment processes (the “Hiring Service”).

As required by the California Consumer Privacy Act of 2018 (“CCPA”), we’re providing the following details, in addition to those set out in the rest of this Privacy Notice, regarding the categories of personal information (as defined under the CCPA, and including applicable personal information collected online or offline, “CCPA Personal Information”) about California residents that we have collected or disclosed within the preceding twelve months.

What We Have Done in the Preceding twelve Months

Within the preceding twelve months, Lanterna may have collected and disclosed the following categories of CCPA Personal Information in connection with its websites and Hiring Service (with references to the category in the CCPA regulations):

• Identifiers, such as name, contact information, and online identifiers;
• Personal information, as defined in the California customer records law, such as name, contact information, and, for those using the Hiring Service, names, e-mails, pictures and videos, information from Facebook and LinkedIn accounts, titles, education, and other information provided through the Hiring Service;
• For the Hiring Service, characteristics of protected classifications under California or federal law, such as race, ethnicity, or sex;
• Commercial information, such as information about products or services purchased, used or considered;
• Internet or network activity information, such as browsing history and interactions with our websites;
• Geolocation data, such as device location and IP location;
• Audio, electronic, and visual information, such as call and video recordings;
• For the Hiring Service, professional or employment-related information, such as work history and prior employer; and
• Inferences drawn from any of the CCPA Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.
  

This does not mean that all examples of the above categories of CCPA Personal Information were in fact collected and disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected and disclosed.

We do not collect biometric information (category “E” of the CCPA). Our collection of non-public education information (category “J” of the CCPA) is only in connection with our status as a “service provider” for schools and districts, and is described in detail in Section 9 of this Privacy Notice.

As described in this Privacy Notice, we collected this CCPA Personal Information from you, external channels or sources or through our Hiring Service. Also as described in this notice, we may use this CCPA Personal Information to manage and improve our websites, administer the potential as well as the existing contractual relationship, for marketing purposes, and to manage and administer our Hiring Service. We may also use CCPA Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to: develop, improve, repair, and maintain our products and services; personalise, advertise, market, sell and distribute our products and services; communicate with customers; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

Sale and Sharing

We do not monetize CCPA Personal Information. We have not sold, within the last twelve months, any CCPA Personal Information collected through our websites, the Hiring Service or any other service. As described within this Privacy Notice, within the last twelve months, we may have shared CCPA Personal Information, including information from each of the CCPA categories specified above, with our service providers, our affiliates or our business partners.

What You Can Do

If you are a California resident, you have the right to request that we:

1. Disclose to you the following information covering the twelve months preceding your request:
   • categories of CCPA Personal Information we’ve collected about you and the categories of sources from which we collected such CCPA Personal Information;
   • specific pieces of CCPA Personal Information we’ve collected about you;
   • business or commercial purpose for collecting CCPA Personal Information about you; and
   • categories of CCPA Personal Information about you that we shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such CCPA Personal Information (if applicable).
2. Delete CCPA Personal Information we collected from you, and correct any inaccurate CCPA Personal Information we collected from you.
3. Opt you out of any future sale or sharing of CCPA Personal Information about you.
   To make a request for any of these disclosures or exercise any of these rights, please email us at info@lanternaeducation.com, with the subject line “California Rights Request” in the subject line. 
   

To make a request for any of these disclosures or exercise any of these rights, please email us at info@lanternaeducation.com, with the subject line “California Rights Request” in the subject line. 

We’ll respond to your requests consistent with applicable law. We may need to verify your identity. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Your California “Shine the Light” Rights
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please email us at info@lanternaeducation.com with “California Shine the Light Inquiry” in the subject line, indicating in your email that you are a California resident making a “Shine the Light” inquiry. We’ll respond to your requests consistent with applicable law. We may need to verify your identity.

12. YOUR RIGHTS AND HOW TO EXERCISE THEM 

According to applicable data protection laws, including the GDPR and the UK GDPR, you are entitled to certain rights. You have the right to request access to and rectification or erasure of your personal data or restriction of processing concerning you and to object to processing as well as to data portability. For more information on your rights, please see here and here.

Lanterna will normally answer your request within one month from receipt of your request. Requests are made via info@lanternaeducation.com.

13. updating this privacy policy

If you have any questions, please contact us at info@lanternaeducation.com.We may update this Privacy Notice from time to time. You can look at the last revised date at the top of this notice to see when this notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised notice on our websites. In case of substantive changes, we’ll inform you specifically (provided that we have your contact information).

14. CONTACT US

If you have any questions, please contact us at info@lanternaeducation.com.