Terms and Conditions

INTRODUCTION

These terms and conditions (Terms and Conditions) tell you the rules that apply in connection with any BecomingX Education subscription you take in connection with our website www.becomingx.com and mobile applications (the BecomingX Platform). This is a legally binding contract. By taking out any BecomingX Education subscription you confirm that you accept these Terms & Conditions as well as the other relevant terms which are set out below and that you agree to comply with them at all times. If you do not agree to these Terms & Conditions, you must not use your BecomingX Education subscription or the BecomingX Platform. We reserve the right to restrict, suspend or terminate your BecomingX Education subscription and use of the BecomingX Platform at any time if we believe, in our absolute discretion, that you have breached these Terms & Conditions or any other terms.

Your BecomingX Education subscription is provided by BecomingX Ventures Limited, a company registered in England and Wales (company number 11636810, VAT registration 313869194) with its registered address at 10 Queen Street Place, First Floor, London, EC4R 1BE. The terms "BecomingX", "we", "us" and "our" refer to BecomingX Ventures Limited. You can contact us at contact@becomingx.com. If we need to contact you we will do so using the details you provided to us when you registered for your BecomingX Education subscription.

The key points of our Terms and Conditions are:

• You must be over 18 years old to take out any BecomingX Education subscription.
• You must provide accurate information when taking out any BecomingX Education subscription and should not attempt to impersonate others or create multiple accounts.
• Your BecomingX Education Schools subscription is unique and personal to you and/or your institution. It cannot be shared with multiple schools.
• Your BecomingX Education Home Edition subscription is unique and personal to you and your household. It cannot be shared with multiple households or families who do not share your residential address.
• BecomingX Education Home Edition subscriptions are for individual use within a home setting by parents and homeschoolers, and cannot be used by institutions such as but not limited to Schools and Colleges.
• You cannot share any of your BecomingX Education subscription benefits with any third party.
• All of our content is copyrighted and owned (or licenced by us) and can only be used with a valid BecomingX Education subscription for educational and non-commercial use. You must not adapt or amend our content in any way or share any of our content with any third party.
• In the event your BecomingX Education subscription expires or is cancelled (for any reason) you must promptly destroy all content downloaded or otherwise obtained through BecomingX as well as copies of such materials.
• You are responsible for complying with applicable laws, in particular in connection with data protection and ensuring you comply with any legal requirements and have any consents required e.g. when using our survey product.
• You are responsible for ensuring that the content is not used for public performance except in an educational context and that any content that is presented is done so in a professional way (or example, presented by teachers or trained facilitators). We are not responsible for providing any further support to students beyond the scope of the content we provide (e.g. mental health support).
• We have no liability for any benefits, services or goods provided by third party providers you use in connection with your BecomingX Education subscription or the BecomingX Platform.

THERE ARE OTHER TERMS THAT WILL APPLY TO YOU

These Terms & Conditions refer to the following additional terms, which also apply to your use of the BecomingX Platform:

Our Terms of Use: These set out the terms of use that apply when you use the BecomingX platform.

• Our Privacy Policy.: This explains how we may use your personal information.
• Our Cookie Policy: This sets out information about the cookies on the BecomingX Platform.

WE MAY MAKE CHANGES TO YOUR BECOMINGX SUBSCRIPTION, THESE TERMS & CONDITIONS AND THE BECOMINGX PLATFORM

Minor Changes. We may make minor changes to these Terms & Conditions for your BecomingX Education subscription or the BecomingX Platform:

• to reflect changes in relevant laws and regulatory requirements;
• to change the methods of payment we accept; and
• to implement minor technical adjustments and improvements, for example to address a security threat.

These changes will not materially affect your BecomingX Education subscription.

Significant Changes. In the event we make any significant changes to these Terms & Conditions, your BecomingX Education subscription or the BecomingX Platform, we will take all reasonable steps to notify you in advance. If you do not want to want to accept these changes then you may have the right to terminate your BecomingX Education subscription. Please note depending on the change(s) you may not be due any refund for your BecomingX Education subscription in this instance.

BECOMINGX EDUCATION SUBSCRIPTION

Details of the BecomingX Education subscription and the benefits you can receive can be found on the BecomingX Platform.

BecomingX Education Subscription. To take out a BecomingX Education subscription you must:

• be over 18 years of age;
• complete all verification and other required processes;
• agree, if you are creating an account or buying a subscription on behalf of an education institution (e.g. a school or college) or other entity, that you have all necessary permissions and authority to bind that entity;
• agree you shall not use a BecomingX Education subscription if you are a direct competitor of BecomingX and the services which BecomingX offers and are investigating BecomingX for competitive research.

BecomingX reserves the right to reject your BecomingX Education subscription at its sole and absolute discretion without reason.

Subject to compliance with these Terms & Conditions and all other terms in connection with the BecomingX Platform and in particular receipt of full payment of your BecomingX Education subscription, you are granted during the term of your BecomingX Education subscription a non-transferable, non-exclusive, non-sublicensable licence to the BecomingX Platform for educational and non-commercial use only. This licence includes the ability to use of all films available on the BecomingX platform for educational purposes. You understand that your use of the BecomingX Platform does not confer to you any intellectual property rights held by BecomingX and/or its licensors. You are merely given a licence to use the BecomingX Platform in connection with your BecomingX Education subscription in accordance with these Terms & Conditions and the Terms of Use.

YOUR OBLIGATIONS

By taking out a BecomingX Education subscription you agree the following:

• Using your account. You may only use your BecomingX Education subscription account for educational and non-commercial purposes. In creating a BecomingX Education subscription account, we ask that you provide complete and accurate information and have the authority to take out a BecomingX Education subscription account. You may not impersonate someone else (e.g. adopt the identity of someone else), create or use an account for anyone other than yourself, provide an email address other than your own, or create multiple accounts. If you use a pseudonym, take care to note that others may still be able to identify you if, for example, you include identifying information, use the same account information on other sites, or allow other sites to share information about you with BecomingX.
• Your subscription benefits: You may not share any of the BecomingX Education content or benefits, or your subscription details (including your username and password), with any third party.
• Your information is accurate. You represent and warrant to us that any information you provide to BecomingX, in connection with your BecomingX Education subscription including any contact information, is accurate and that you will keep it accurate and up to date.
• Communications from BecomingX. By creating a BecomingX Education subscription account, you agree to receive communications about important administrative issues relating to your account (including technical, security-related, privacy and functional issues).
• Subscription Benefits. The BecomingX Education subscription benefits are unique to you and/or your institution or household, you must not share these with any third party or use the BecomingX Education subscription benefits on behalf of someone else.
• You acknowledge that all of our content and materials are copyrighted and owned (or licenced by us) and can only be used with a valid BecomingX Education subscription for educational and non-commercial use. You must not adapt or amend our content in any way or share any of our content or materials with any third party.
• Compliance with applicable laws and Data Privacy. You are responsible for complying with applicable laws, in particular in connection with data protection and ensuring you comply with any legal requirements have any consents required e.g. when using our surveying capability.
• Presenting Content and Providing Support.You are responsible for ensuring that the content is not used for public performance except in an educational context and any content that is presented is done so in a professional way (e.g. delivered by teachers/educators) and providing additional support to students is beyond the scope of the content we provide (e.g. mental health support).
• Deleting BecomingX content and materials. In the event your BecomingX Education subscription expires or is cancelled (for any reason) you must promptly permanently delete all content downloaded or otherwise obtained through BecomingX as well as copies of any materials, including but not limited to lesson plans and activity handouts.

Own risk. You use your BecomingX Education subscription at your own risk and are solely responsible for any interactions through the BecomingX Platform.

Provided on an “as is” basis. Your BecomingX Education subscription is provided on an “as is” basis and we disclaim to the fullest extent permitted by law all warranties, express or implied, statutory or otherwise. Specifically, we make no representations, warranties or guarantees about the following:

• the accuracy, reliability, completeness, correctness or timeliness of the BecomingX Platform or communications provided on or through the use of the BecomingX Platform;
• that the BecomingX Platform will be uninterrupted, or free of errors, viruses, or other harmful components.

Availability of the BecomingX Platform. We may discontinue or make changes to the BecomingX Platform at any time. If this has a material impact your BecomingX Education subscription you may be entitled to a refund.  We do not guarantee that your BecomingX Education subscription or the BecomingX Platform will be available at all times and on an uninterrupted basis.

Password. When you take out your BecomingX Education subscription you will be asked to create a password for your BecomingX Education subscription account. You are solely responsible for all activities that occur under your BecomingX Education subscription account and for maintaining the confidentiality of your BecomingX Education subscription account and password, payment information you use in connection with your BecomingX Platform, and for restricting access to your computer or any device which you use to access the BecomingX Platform. You agree to accept responsibility for all activities that occur under your BecomingX Education subscription account. If you have reason to believe that your account is no longer secure (for example, in the event of loss, theft or unauthorised disclosure) you are required to immediately notify us. You may be liable for the losses incurred by us or others due to any unauthorised use of your BecomingX Education subscription account. BecomingX shall under no circumstance be liable for any loss or damage arising from your failure to keep your BecomingX Education subscription account secure.

Disabling Access. We reserve the right, without liability, to disable your subscription and/or your access to the BecomingX Platform if you are in breach or we have reasonable grounds to suspect you are in breach of these Terms & Conditions or any other terms.

Commercial Use. You agree not to display, distribute, licence, perform, publish, reproduce, duplicate, copy, create derivative works from, modify, sell, resell, exploit, transfer or upload for any commercial purposes, the BecomingX Platform or anything connected to your subscription of the BecomingX Platform.

PRICE AND PAYMENT

Subscription pricing. The pricing for the BecomingX Education subscriptions available is set out on the BecomingX.com website or as advised by our organisation. We take all reasonable care to ensure that the price of the BecomingX Education subscription advised to you is correct. It is always possible that, despite our best efforts, the BecomingX Education subscription pricing is incorrect. If the price you have been given is lower than the BecomingX Education subscription price which should apply we will contact you to inform you and you may terminate your BecomingX Education subscription and we will refund you any sums you have paid. If the price you have been given is higher than the BecomingX Education subscription price which should apply we will refund you the difference.

Payment Method and Payment Cycle. Direct debit is our preferred method of payment. We also accept most credit and debit cards. You may update your payment method at the time of renewal with our third party payment provider. We will take payment at or soon after the point that you register for your BecomingX Education subscription. Unless you cancel your BecomingX Education subscription before your next billing date, you authorise us to charge the BecomingX Education subscription fee for the next payment cycle to your payment method. You must ensure that you have a valid payment method prior to your next payment cycle. If a payment is not successfully settled, due to expiration, insufficient funds, or otherwise, and you do not cancel your BecomingX Education subscription, we may suspend your access to the service until we have successfully charged a valid payment method. You are responsible for any charges such as foreign transaction fees or other fees relating to the processing of your payment method.

14 Day Cancellation Period. If you cancel your BecomingX Education subscription within the first 14 days and have not accessed any content or used any BecomingX Education subscription benefits we will provide you with a full refund. After the 14 day period you can cancel your subscription at any time (and any subsequent renewals), and you will continue to have access to the BecomingX Platform through to the end of your BecomingX Education subscription subscription period (e.g. 1 year). To the extent permitted by the applicable law, payments are non-refundable, and we do not provide refunds or credits for any partial BecomingX Education subscription periods. An administrator can cancel the account at www.becomingx.com.

Changes to BecomingX Education subscription pricing. We may change our BecomingX Education subscription plans and pricing from time to time; however, any plan or pricing changes will apply no earlier than 30 days following notice to you.

OUR RIGHTS TO END YOUR BECOMINGX EDUCATION SUBSCRIPTION OR ACCESS TO THE BECOMINGX PLATFORM

We may end your BecomingX Education subscription or access to the BecomingX Platform if you breach these Terms & Conditions or any other terms. If we reasonably believe that you have breached these Terms & Conditions or any other terms, we may immediately terminate your BecomingX Education subscription with you upon written notice and cease to provide you access to the BecomingX Platform and any benefits.

We may withdraw the BecomingX Platform. We may write to you to let you know that we are going to stop providing the BecomingX Platform. We will let you know at least one month in advance of our stopping the supply of the BecomingX Platform.

NO RESPONSIBILITY FOR ANY BENEFITS, SERVICES OR GOODS PROVIDED BY THIRD PARTIES

There are a number of benefits which are provided by third parties that are promoted on the BecomingX Platform. BecomingX has no control over any benefits provided by third parties and they may change at any time and without notice. The third parties are solely responsible for fulfilling any benefits, services or goods and it is your responsibility to ensure you enter into any contractual arrangements required with the third party. BecomingX is not an agent of any third-party provider. BecomingX makes no claims or promises with respect to any third party, including our information sharing partners or any businesses, partners or advertiser that you use in connection with your BecomingX Education subscription. Accordingly, BecomingX is not liable to you for any loss or damage that might arise from the actions or omissions of such third parties, including, for example, cancellation of any trips they have organised or any loss or injury that is incurred on any experience or trips.

OUR RESPONSIBILITY FOR LOSS OR DAMAGE SUFFERED BY YOU

We exclude all implied conditions, warranties, representations or other terms that may apply to your BecomingX Education subscription or the BecomingX Platform.

We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

• use of, or inability to use, your BecomingX Education subscription;
• use of, or inability to use, the BecomingX Platform; or
• use of or reliance on any content displayed on the BecomingX Platform.

In particular, we will not be liable for:

• loss of profits, sales, business, or revenue;
• business interruption;
• loss of anticipated savings;
• loss of business opportunity, goodwill or reputation; or
• any indirect or consequential loss or damage.

If applicable law does not permit exclusion of all damages, then your direct damages arising out of or relating to your use of BecomingX Platform shall be limited to £100.

INDEMNIFICATION

You agree to indemnify us and our officers, directors, employees, partners, agents, affiliates and licensors from all liabilities, claims, and expenses, including reasonable legal fees (Claims), that arise from your breach of these Terms & Conditions, your use or misuse of your BecomingX Education subscription, the BecomingX Platform or any content contained on the BecomingX Platform. We reserve the right, at our own expense, to assume the exclusive defence and control of any matter otherwise subject to your indemnification, in which event you will cooperate with us in asserting any available defences.

HOW WE MAY USE YOUR PERSONAL INFORMATION

We will only use your personal information you disclose to us in connection with your subscription to fulfil our obligations under these Terms & Conditions and as set out in our Privacy Policy.

OTHER IMPORTANT THINGS YOU SHOULD KNOW

We may transfer this agreement and your BecomingX Education subscription to someone else. We may transfer our rights and obligations in respect of your BecomingX Education subscription and these Terms & Conditions to another organisation. We will always tell you in writing if this happens and we will ensure that the transfer will not affect your rights under these Terms & Conditions.

If a court finds part of these Terms & Conditions illegal, the rest will continue in force. Each of the paragraphs of these Terms & Conditions operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect.

Even if we delay in enforcing these Terms & Conditions, we can still enforce it later. If we do not insist immediately that you do anything you are required to do under these Terms & Conditions, or if we delay in taking steps against you in respect of your breaking this Terms & Conditions, that will not mean that you do not have to do those things and it will not prevent us taking steps against you at a later date. For example, if you miss a payment and we do not chase you, but we continue to provide the BecomingX Platform, we can still require you to make the payment at a later date.

Which laws and jurisdiction applies to these Terms & Conditions. These Terms & Conditions are governed by English law and under the jurisdiction of the English courts.

Last updated:  29 April 2022

Privacy Policy

INTRODUCTION

This policy (Policy) relates to your personal information in connection with your use of and access to the BecomingX website www.becomingx.com and mobile applications (the BecomingX Platform) and together with our Terms of Use, Terms and Conditions and Cookie Policy set out the terms which apply when using the BecomingX Platform.

The terms "BecomingX", "we", "us" and "our" refer to BecomingX Ventures Limited, a company registered in England and Wales (company number 11636810) with its registered address at 10 Queen Street Place, First Floor, London, EC4R 1BE. BecomingX is the controller (also known as a data controller) and is responsible for your personal information. The term "you" refers to you, as a user of the BecomingX Platform.

We are committed to protecting your Information and your right to privacy. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where information about your identity has been removed (anonymous data).

When you use the BecomingX Platform, you trust us with your Information (as defined below). We take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of the BecomingX Platform.

The key points of this Policy are:

• We are committed to ensuring the privacy of your data and will observe the rights granted to you under applicable privacy and data protection laws
• We will only collect and use your Information (as defined below in ‘Information we may collect about you’) where we have lawful grounds and legitimate business reasons to do so
• We will never sell your Information to third parties
• We aim to provide clear and age appropriate communications relating to data collection, usage and privacy
• We aim to provide you with the ability to access and control the key information provided to us
• The BecomingX Platform is for over 13’s only and we do not knowingly allow anyone under the age of 13 to register on the BecomingX Platform

Information we may collect about you

Personal information you disclose to us

In short: We collect personal information that you provide to us including information such as name, address and contact information

We collect personal information that you voluntarily provide to us when registering and using the BecomingX Platform, purchasing products or services in connection with the BecomingX Platform or otherwise contacting us. The personal information that we collect depends on the context of your interactions, the choices you make and the services, products and features you use. When you use the BecomingX Platform and/or when you otherwise deal with us, we may collect the following information about you (Information):

• Identity Data: This includes first name, last name, date of birth and gender.
• Contact Data: This means the data we use to contact you including your billing address, delivery address, email address and contact number.
• Financial Data: This means the payment method and card association used to process your payments for any services which you order. We do not store or process your card details ourselves, they are processed and stored via one of our contracted third-party service providers. We encrypt your payment card details in your browser and securely transfer this data to Stripe, our third-party payment provider to process a payment.
• Transaction Data: This means details about transactions you have made using the BecomingX Platform, including the payments from you (or to you), along with other details of products you have purchased from us.
• Profile Data: This includes your username (email address), your login data, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data: This includes information about how you use the BecomingX Platform. This includes your browsing patterns and information such as how long you might spend on one of our webpages on the BecomingX Platform and what you look at and for, the page that referred you to the BecomingX Platform and the click stream during your visit to our website, page response times and page interaction information (clicks you make on a page).
• Marketing and Communications Data: This includes your preferences for receiving marketing from us and your communication preferences.
• Other information: This includes any other information relevant to services, customer surveys and/or offers.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to your Information.

Information automatically collected

In short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you use the BecomingX Platform.

We automatically collect certain information when you visit, use or navigate the BecomingX Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the BecomingX Platform and other technical information. This information is primarily needed to maintain the security and operation of the BecomingX Platform, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy.

How do we use your Information?

In short: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We use your Information collected via the BecomingX Platform for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons). We indicate the specific processing grounds we rely on next to each purpose listed below.

We may process your Information for the following purposes:

• operate, maintain, and optimise the BecomingX Platform and your account (Contractual).
• To send administrative information to you for Business Purposes, Legal Reasons and/or possibly Contractual. We may use your Information to send you product, service and new feature information and/or information about changes to our terms and/or policies.
• To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our brand partners may use your Information for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails, see below for further details.
• Administer surveys and promotions for our Business Purposes and/or with your Consent.
• Request Feedback for our Business Purposes and/or with your Consent. We may use your Information to request feedback and to contact you about your use of the BecomingX Platform.
• To protect BecomingX for Business Purposes and/or Legal Reasons. We may use your Information as part of our efforts to keep the BecomingX Platform safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms or policies for Business Purposes, Legal Reasons and/or possibly Contractual.
• To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• For other Business Purposes. We may use your Information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the BecomingX Platform, products, services, marketing and your experience.

We use information from surveys administered by BecomingX customers for multiple purposes, including to:

• provide customers with reports and data from their users (e.g. student provided responses)
• provide individual respondents with reports, feedback and insights based on the data provided
• analyse the effectiveness of BecomingX products and services
• research broader social, economic and demographic factors which may impact individual performance, perceptions and achievement

Will your Information be shared with anyone?

In short: We only share your Information to comply with Contractual obligations, fulfil our Business Purposes, or with your Consent

We only share and disclose your Information in the following situations:

• Contractual: to enable any orders for products or services in connection with the BecomingX Platform to be fulfilled.
• Vital Interests: We may disclose your Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• Third-Party Service Providers: We may share your Information with third-party vendors, service providers, contractors or agents who perform services and require access to such information to do that work. Examples include; data analysis, email delivery, hosting services, customer service and marketing efforts. They will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as we ask them to and always in accordance with this Policy.
• Business Transfers: We may share or transfer your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third-Party Advertisers: We may use third-party advertising companies to serve ads when you visit the BecomingX Platform. These companies may use information about your visits to the BecomingX Platform and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookie Policy for further information.
• Business Partners: Provided you have given us Consent to do so, we may share your Information with our business partners to offer you certain products, services or promotions.
• Legal Obligations: We may disclose your Information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• With your Consent: We may disclose your Information for any other purpose with your Consent.

We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the BecomingX Platform. In such circumstances we do not disclose any information which can identify you personally.

Marketing and opting out

If you have given Consent to marketing, we may contact you about our products, services, promotions and special offers. If you no longer wish to receive such information you can withdraw your Consent at any time by unsubscribing from the communications or sending an email to privacy@becomingx.com.

If you have given Consent, we may share your Information with carefully selected third-party organisations and business partners and they may contact you directly. If you prefer not to receive direct marketing communications from the third-party please contact them directly to withdraw the Consent.

CHILDREN

Although our education products are designed to be used with children, the BecomingX Platform is targeted at general audiences, educators and businesses. It is not targeted at children under 13 and children under 13 are not permitted to register to use the BecomingX Platform. We do not knowingly collect personal data from children under 13 and have in place safeguards to reduce the risk of this occurring. If you become aware that a child has provided us with personal data without parental consent, please contact us at privacy@becomingx.com. If we become aware that a child under 13 has provided us with personal data without parental consent, we will take reasonable steps to remove information and terminate any account made by a child under 13 as soon as possible.

As a provider of surveying and reporting capabilities to our customers, we recognise that our education customers will likely administer surveys for students both under 16 and under 13. In this instance, BecomingX is a processor of the data on behalf of customers. It is essential that customers who administer surveys in their organisations follow all applicable laws relating to data privacy and are solely responsible for obtaining any consents required by data protection law. Educational institutions administering surveys must adhere to applicable child and student privacy standards, in particular ensuring parental consent for respondents under 13.

BecomingX designs its surveys in a way that limits the risk to any child respondents and supports a trusted relationship between customers administering surveys, their respondents and BecomingX. Specifically, we:

• Provide guidance to customers (see our Terms & Conditions for more details): We stress to our customers the importance of them following the relevant data protection laws and guidelines when administering our surveys to children.
• Provide age appropriate messaging: We provide clear and concise messaging to ensure children completing surveys understand its purpose and how the information they provide will be used.
• Limit the information captured: We endeavour to design our surveys so that the responses are anonymous and child respondents have the confidence to provide truthful responses. Unless explicitly needed or requested, our surveys do not capture the following data from children:
  • Name
  • Day of birth (month and year only)
  • Contact information (e.g. email, phone number, address)
• Limit the information provided to customers: In providing reports or data back to customers who have administered a BecomingX designed survey, we may suppress or aggregate any information if we believe they may be able to identify individuals.

For Business Purposes, BecomingX may use data from surveys which may include data provided by children. In these instances, we make the following commitments:

• We will not use or share data beyond that required for educational, research or Business Purposes
• Any data shared or published will never be personally identifiable i.e. it will always be anonymised or aggregated (unless explicitly requested or authorised)
• We will never sell your Information
• We will never build a personally identifiable profile of a student other than for supporting authorised educational purposes, or if authorised by the child or parent
• We will never use this data for any targeting or advertising to children
• We will maintain a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of children’s personal information against risks

Is your Information transferred internationally?

In short: We may transfer, store, and process your Information in countries other than your own but will take all reasonable steps to ensure it is p­­­­­rotected.

Whenever we transfer your Information outside of the UK, we will take all reasonable measures that we can to protect your Information in accordance with this Policy and applicable law. If the Information will be transferred outside of the European Economic Area, we will ensure than any additional required measures and/or safeguards are in place (e.g. the EU/US Privacy Shield if the transfer is to the USA, or that the EU model contract clauses are used, if applicable).

Your Consent to processing

You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the BecomingX Platform.

If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing privacy@becomingx.com.

If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so, subject to your legal rights.

Please note that if we need to process your Information in order for you to use the BecomingX Platform and you object or do not provide Consent to us processing your Information, the BecomingX Platform will not be available to you.

How long do we keep your Information?

In short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy, unless otherwise required by law.

We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing Business Purpose to process your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.

How do we keep your Information safe?

In short: We aim to protect your Information through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any Information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Information, transmission of your Information to and from the BecomingX Platform is at your own risk. You should only access our services within a secure environment.

Third-party websites

In short: We are not responsible for the safety of any Information that you share with third-party providers who feature or advertise, but are not affiliated with, the BecomingX Platform.

The BecomingX Platform may feature links to third-party websites or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the BecomingX Platform. You should review the policies of such third parties and contact them directly to respond to your questions.

SOCIAL MEDIA FEATURES AND WIDGETS

The BecomingX Platform may integrate with social sharing features or other related tools which let you share actions you take on the BecomingX Platform with other apps, sites or media, and vice versa. These features may enable the sharing of information with your friends or the public, depending on the settings you establish with the social sharing site. For example, you may click on a Facebook "like" button, which publishes to your Facebook account that you "like" one of the videos or items featured on the BecomingX Platform. These features may also collect your IP address and which page you are visiting on the BecomingX Platform, and may set a cookie to enable the feature to function properly. Your interaction with these features is governed by the privacy policy of the relevant social sharing site. Please refer to the privacy policies of those social sharing sites for more information. We cannot control the information or content you choose to make available publicly or how it is used by others.

ACCOUNT TERMINATION

You may terminate your account by deleting it on the BecomingX Platform. Once your account is closed, no further data will be collected, but we may retain your Information about you for the purposes authorised under this Policy, unless prohibited by law. We may keep and maintain anonymised data after you delete your account for analytics purposes.

WHAT ARE YOUR PRIVACY RIGHTS?

In short: You have certain rights in respect of your Information.

You have certain rights in relation to the Information that we hold about you. Details of these rights and how to exercise them are set out below. Please note we will require evidence of your identity before we are able to respond to your request. This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up your response. To exercise or discuss any of your rights please contact us at privacy@becomingx.com.

• Right of Access: You have the right at any time to ask us for a copy of the Information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your Information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
• Right of Correction or Completion: If Information we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.
• Right of Erasure: In certain circumstances, you have the right to request that the Information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the Information is based on your consent and there are no other legal grounds on which we may process the Information.
• Right to Object to or Restrict Processing: In certain circumstances, you have the right to object to our processing of your Information. For example, if we are processing your Information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests.

You may also have the right to restrict our use of your Information, such as in circumstances where you have challenged the accuracy of the Information and during the period where we are verifying its accuracy.

• Right of Data Portability: In certain instances, you have a right to receive your Information that we hold about you in a structured, commonly used and machine-readable format.

In such circumstances, you can ask us to transmit your Information to you or directly to a third-party organisation.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.

If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

Please note that we have the right to reject deletion requests that are unduly burdensome or repetitive or that cannot be honoured in light of legal obligations or ongoing disputes, or where retention is necessary to enforce our agreements or protect our or another party's rights, property, safety, or security. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the BecomingX Platform or to comply with legal obligations.

CHANGES TO THIS PRIVACY POLICY OR YOUR PERSONAL INFORMATION

We review this Policy regularly and it is your responsibility to check you agree with any changes the terms set out. If you do not agree to any change to this Policy, then you must immediately stop using the BecomingX Platform. In the event we make any significant changes to this Policy we will use our best endeavours to inform you of such changes in advance in writing.

It is important that the information we hold about you is accurate and current. Please keep us informed of any changes e.g. if you change your email address.

CONTACT INFORMATION

BecomingX has a Data Protection Officer who is responsible for matters relating to privacy and data protection. If you have any questions regarding our privacy practices or your Information, please contact our Data Protection Officer at privacy@becomingx.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Last updated 5 July 2020

Cookie Policy

INTRODUCTION

This policy (Policy) relates to how we use cookies on the BecomingX website www.becomingx.com and mobile applications (the BecomingX Platform) and together with our Terms of Use, Terms and Conditions and Privacy Policy set out the terms which apply when using the BecomingX Platform. Please be aware that restricting cookies may impact on your user experience and may prevent you from using parts of the BecomingX Platform.

The terms "BecomingX", "we", "us" and "our" refer to BecomingX Ventures Limited, a company registered in England and Wales (company number 11636810) with its registered address at 10 Queen Street Place, First Floor, London, EC4R 1BE. The term "you" refers to you, as a user of the BecomingX Platform.

WHAT COOKIES DO WE USE?

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. This helps us to provide you with a good experience when you browse the BecomingX Platform and also allows us to improve the BecomingX Platform.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of the BecomingX Platform. They include, for example, cookies that enable you to log into secure areas of the BecomingX Platform, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the BecomingX Platform when they are using it. This helps us to improve the way the BecomingX Platform works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to the BecomingX Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to the BecomingX Platform, the pages you have visited and the links you have followed. We will use this information to make the BecomingX Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about some of the individual cookies we may use and the purposes for which we may use them in the below table:

WHAT DO WE USE COOKIES FOR?

We use cookies for a number of purposes, including, but not limited to:

1. Authentication: If you are signed into BecomingX, cookies help us to show you the right information and personalise your experience.
2. Security: We use cookies as part of our security features and to help us detect and suspicious activities and violations of our Privacy Policy, Terms of Use and/or Terms and Conditions
3. Functionality and s.ervices: Cookies enable us to determine key elements of functionality and user preferences, e.g. language preferences, features and customised content.
4. Analytics: We use cookies for analytical and performance purposes, to enhance and optimise our BecomingX Platform and determine its usage.
5. Advertising: We may use cookies to show you relevant advertising and content both on and off the BecomingX Platform. Our partners may also use cookies to determine how an advertisement has performed and how you interacted with it.

MANAGING COOKIES

The most popular web browsers all allow you to manage cookies. You can choose to accept or reject all cookies, or just specific types of cookies.

How to manage cookies in different web browsers 

Most browsers will allow you to turn off cookies. Please note that turning off cookies will restrict your use of the BecomingX Platform. For further information, please see the website for your browser for information on how to modify the cookies settings.

Please note that we do not currently respond to Do Not Track (DNT) signals.

We strongly recommend that you leave cookies active, because they enable you to take advantage of the the most attractive features of the BecomingX Platform, but this remains your personal choice.

You can also visit About Cookies, for more information about cookies and how to manage them.

THIRD PARTY COOKIES

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

If you would like more information about these third-party cookies, it is available from youronlinechoices.com/UK/.

Note that when third parties are collecting information about you, these third parties are acting as controllers in their own right (i.e. they are not acting on our behalf).

EMBEDDED CONTENT

We embed images or videos from sites such as Vimeo. As a result, when you visit a page featuring such content, you may be presented with cookies from these websites. We do not control these cookies and cannot prevent these sites or domains from collecting information on your use of this content.

You should check the relevant third-party website for more information about them and how to opt out. They may still gather usage information about you (e.g. number of views, plays, loads etc.) and may also be able to work out who you are even if you are not logged in to their services.

Read more about Vimeo’s privacy policy.

SOCIAL NETWORKING AND SHARING TOOLS

On some pages, we may also feature embedded 'Share' buttons or widgets that enable you to share content with friends through a number of popular social networking sites such as Twitter; Facebook and Instagram.

These sites may set cookies which can identify you as an individual when you are also logged in to their services and even when you are not logged in to their service. This means they may be collecting information about what you are doing all around the internet, including on the BecomingX Platform. We do not control these cookies and you should check the relevant third-party site to see how your information is used and how to opt out.

CHANGES TO THIS COOKIE POLICY

We will review, and where necessary update, this policy from time to time. In the event we make any significant changes to this Cookies Policy, and where we have your email address, we will use our best endeavours to inform you of such changes in writing. If we need to, we will also ask you to confirm that you are happy with those changes. Every time you wish to use the BecomingX Platform, please check this Cookies Policy to ensure you understand the terms that apply.

CONTACT INFORMATION

If you have any questions regarding our Cookies Policy, please contact us at support@becomingx.com

Last updated 5 July 2020.

Safeguarding Policy

INTRODUCTION

As part of our activities, we at times work directly with children in schools, students in Universities and other youth-focused organisations. We are committed to providing an environment where young people feel secure, valued and listened to.

BecomingX has a responsibility to promote and protect child welfare in all that we do. Children and young people who feel secure make more successful learners and will be more likely to achieve their potential. As a UK-based company, this policy has been drawn up based on legislation, policy and guidance that seeks to protect children across the UK. In the UK, the 4 nations of England, Northern Ireland, Scotland and Wales, each have their own child protection system and laws based on the same principles to help protect children from abuse and neglect.

A summary of the key legislation and guidance is available from the NSPCC.

PURPOSE

The purpose of our safeguarding policy is:

1. To protect children and individuals who use BecomingX’s products and services
2. To ensure our core product and services are suitable for the intended audience
3. To provide everyone that works with us, including children, our own staff and volunteers, with the overarching principles that guide our approach to child protection

POLICY STATEMENT

Our position on safeguarding is that:

• No-one should experience abuse of any kind and everyone has the right to be protected from discrimination, in all its forms.
• We have a responsibility to promote the welfare of everyone, to keep them safe and to operate at all times in a way that protects them.
• The welfare of the child is paramount.
• All people regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation have a right to equal protection from all types of harm or abuse.
• Some people are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues.
• Working in partnership with schools, children, their parents, carers and other agencies is essential in promoting young people’s welfare.

We will seek to keep children safe by ensuring that:

• We value, listen to and respect everyone we work with.
• We have a nominated safeguarding lead; and our policies and procedures will be regularly reviewed to ensure best practice.
• We ensure that all of our staff that work with young people have appropriate background checks completed (e.g. in the UK, Enhanced Disclosure and Barring Service).
• We ensure that all of our staff working with children complete appropriate training
• We ensure all staff know they have a responsibility to report concerns to the appropriate safeguarding lead as soon as possible.
• We provide effective management for staff and volunteers through supervision, support, and training.
• We ask all partner organisations, who may provide services in conjunction with BecomingX, have their own safeguarding policies and processes in place.
• We take any allegations against staff and volunteers seriously and we will respond swiftly and appropriately, in line with our complaints and whistleblowing procedures.
• We record and store information professionally and securely, in line with regulations.
• We provide a safe physical environment for children, young people, staff and volunteers when organising events ourselves.

CONTACT INFORMATION

If you have any questions regarding our Safeguarding Policy, please contact us at potential@becomingx.com

Last updated 31^st July 2020.