privacy notice



Privacy Notice

1 Who we are
Thinkfour is operated by The Glasgow Academicals War Memorial Trust (Glasgow Academy), a company limited by guarantee with registered number SC011313 and having our registered office address at Glasgow Academy, Colebrooke Street, Glasgow, G12 8HE.
2 How to contact us
2.1 If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
  • By post: 25 Colebrooke Street, Glasgow, G12 8HE
  • By phone: 0141 334 8558
  • By email: []
2.2 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3 Privacy Information
3.1 We are committed to protecting your personal data and your privacy. This privacy notice aims to give you information on how we collect and process your personal data through your use of our digital learning platform “thinkfour” (the Platform)
3.2 It is important that you read this privacy notice when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.
3.3 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
3.4 This version of our privacy notice was last updated on 1st August 2021.
4 About the personal data that we collect and process
4.1 “Personal data”, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (“anonymous data”).
We do not collect or process special categories of personal data.
4.2 To access tutorials on thinkfour we will ask you for:
  • Your username (Identity Data)
  • Your email address (Contact Data)
4.3 We may also collect Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform (Technical Data)
When you give us your personal data we may use it to:
  • Grant you access to content on the Platform;
  • Provide you with information that you have requested from us;
  • Provide you with information about thinkfour; and
  • Ensure that content from thinkfour is presented in the most effective manner for you by understanding how you use the Platform.
4.4 We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate data to calculate the percentage of individuals accessing a specific feature of our Platform. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
5 With whom do we share your personal data?
5.1 There may be circumstances in which we may also need to share your personal data with certain third parties (strictly on a confidential, business need-to-know basis). The third parties to which we may transfer your personal data include:
5.1.1 Service providers acting as processors who provide IT and system administration services.
5.1.2 Any relevant accreditation body.
5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6 International transfers
6.1 We generally do not transfer your personal data out of the UK. However, whenever we are required to transfer your personal data out of the UK (for example where a third party supplier is located outside of the UK), we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, including any of the following:
6.1.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK.
6.1.2 Where we use certain service providers, we may use specific contracts approved by the UK government which give personal data the same protection it has in the UK.
7 Cookies and Technical Data
7.1 When you visit our Platform you should see a pop-up at the bottom of your screen directing you to this Privacy Notice and our Cookie Policy.
7.2 If you do not click or select the “Accept” button that appears in the pop-up at the bottom of your screen then we will endeavour to not collect your personal data through our cookie. However, even if you do not click or select the “Accept” button there is still some information that we may automatically collect about you – this will be Technical Data.
7.3 Technical Data is sent by you to our site automatically and it isn’t something that we can prevent. We only use this information to administer our site including troubleshooting, load testing, traffic throughput, data analysis, performance testing, and for anonymised research and statistics purposes that we only use internally.
7.4 If you do not see a pop-up at the bottom of your screen then you may have already accepted our Cookie Policy. You may also be using a pop-up blocker or similar tools that may prevent this policy from being brought to your attention. Please ensure that any pop-up blockers are disabled when you use the Platform.
8 Lawful basis of processing
8.1 Personal data may be processed by us where you consent to the processing or where that processing is necessary for 1) the performance of a contract with you; or 2) compliance with a legal obligation to which we are subject; or 3) the purposes of our legitimate interests (or those of a third party).
8.2 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
8.3 We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground or grounds we are relying on to process your personal data.
Type of data
Lawful basis for processing (including basis of legitimate interest)
To administer and protect our business and the Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services and network security)
(b) Necessary to comply with a legal obligation
To enable you to use the Platform
(a) Identity
(b) Contact
(c) Technical
(a) To provide you with our services
(b) With your consent
(c) Necessary for our legitimate interests (to respond to your enquiries)
(d) Necessary to comply with a legal obligation
To generate Aggregated Data
(a) Identity
(b) Technical
Necessary for our legitimate interests (to improve the Platform)
To establish, exercise and defend our legal rights
All data
Necessary for our legitimate interests (in protecting our legal rights)
8.4 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [].
8.5 Where we use legitimate interest as our lawful basis of processing, this means the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
9 How long do we retain your personal data?
9.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements.
9.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
10 Data security
10.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
10.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner’s Office of a breach where we are legally required to do so.
11 Your rights
11.1 Your personal data is protected by legal rights, which include your rights to:
  • Request access to your personal data (commonly known as a “data subject access request“). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, following your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party (data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of these rights, please contact us at [].
11.2 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
11.3 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
11.4 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11.5 You also have the right to complain to the Information Commissioner’s Office, which regulates the processing of personal data, about how we are processing your personal data.
12 Changes to our Privacy Notice
We may need to change this Privacy Notice if it is necessary for legal reasons or to reflect changes to our Platform and services. In any case, the provisions of this Privacy Notice may be changed without prejudice to your rights. When we change our Privacy Notice we will update the “Last Updated” date at the beginning of the Privacy Notice.