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Privacy Policy

Please note, for definitions of capitalised terms used in this document, please refer to the Terms of Service, in particular section 1 Definitions.

We Pupil Progress take care to protect the privacy of Customers and Users and prospective Customers and Users of the Pupil Progress Platform and Services. This Privacy Policy explains how we, as a business (the Data Controller), collect, store and use data about you, an actual or prospective Customer or User. This includes how we do business with you, manage your account, look at how you use our website (https://pupilprogress.com/), and how we deal with marketing to you and potentially featuring you in marketing or other business communications (e.g. case studies). Among the types of Personal Data that we collect directly or through processors and partners, or through information submitted by actual or prospective Customers or Users are: cookies, Usage Data, name, establishment, contact details and job role.

Information about how we process Personal Data when engaged in using our digital Services (e.g. our core Platform https://app.pupilprogress.com/ or smartphone apps) is not covered by this policy but is available through our Data Processing Agreement.

By submitting your personal information to us directly through our website, correspondence with us including by email or phone, or by visiting / interacting with our website, social media accounts, adverts, or any other online presence, or by any other offline communications with us, you are consenting to your Personal Data being used and processed by Pupil Progress in the manner described in this Privacy Policy, unless you let us know otherwise.

Marketing and Communications Purposes

‘Marketing and Communications Data’ includes your basic information (name, the school where you work and your role) and contact details, along with preferences in receiving marketing from us and your communication preferences. It may also include other specific information related to the nature of your interaction with us.

N.B. this does not cover any use of service communications related to our delivery of the core Platform and Services, as that is delivered as part of any contracted Agreement we have with you, and as such covered in our Data Processing Agreement

Where applicable, we will seek permission for usage and specify the terms.

The main ways we use your data for marketing are:

  • to manage our relationship with you
  • to manage our events and partnerships
  • to carry out surveys and obtain feedback
  • to deliver relevant website content and provide advertisement to you
  • to carry out insight, analysis and retargeting through cookies
  • to carry out our marketing practices via email, SMS and online marketing

We may use your Marketing and Communications Data to send you marketing communications via email, social media or SMS about products and services where we have a lawful basis to do so.

Our marketing communications will include both personalised and non-personalised marketing collateral. Personalised marketing has been tailored to you as an individual, organisation or business and will include content and assets that we deem most relevant to you, based on data and sentiment. We will use your data to make suggestions and recommendations to you. Non-personalised marketing is marketing collateral not tailored to you.

If you are an actual Customer or User of the Platform or Services but your  interaction with us is not within or directly related to delivery of the Services you already have access to (e.g. a request for support), or if you are not a Customer or User but your actions reasonably imply an interest in becoming so, it is in our legitimate interest to use your Personal Data for business marketing purposes, for example to decide what marketing content we think may appeal to you. Unless you opt-out which is your right and will always be a clear option, you may receive marketing communications from us if you have requested other information from us, registered with or purchased from us. You have the right to opt-out of these communications at any time by following the unsubscribe links on any marketing message sent to you or by contacting us in one of the below ways:


We may use your data to provide you with, and analyse the accuracy and performance of, personalised ads for products and services we think you might be interested in based on your interaction with us including your use of our website.


During normal use of www.pupilprogress.com we collect and store statistical information including cookies and similar technologies to analyse how parts of our Platform is used and to allow us to offer you the ability to speak to and get help online from a Pupil Progress expert.

Please see our Cookie Policy for more information.


The services contained in this section enable us to monitor and analyse web traffic to our webpages, and can be used to keep track of user behaviour.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises data collected to track and examine interaction with our website and online Services, to prepare analysis which informs our business activities. Note that such data and analysis is also accessible and used by other Google services. Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out

Web beacons

Emails we send you may use web beacons (single, invisible 1×1 pixel images that are downloaded when emails are opened). The web beacon itself does not contain any personal data but allows us to monitor whether emails have been correctly received, opened and clicked on, and to improve the overall email experience we provide. By being a current Customer or User, or by subscribing to our newsletter or other email communications, you give us your permission to do this.

Personal data you submit

On certain pages within our website or other online services which we direct you to, you may have the option to submit personal information to us so that we might send you further information or email alerts or use quotes or information you have submitted. These pages will provide explanations as to how this information is used. On any emails sent to you using this data you will be given the option to unsubscribe from any further information emails or alert emails.

Data Processing by Pupil Progress

We as Data Controller process Personal Data in a proper manner and shall take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction.

Our Data Processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated in this Privacy Policy.

All our staff and management are fully aware of their responsibilities to protect Personal Data and are subject to a duty of confidentiality, through a contractual duty or a statutory duty or otherwise.

All staff follow an induction procedure, have a regular review and security & data protection updates are delivered as required through our regular meetings. If any issue is raised relating to data security, then this is reviewed and directly addressed with the individual/s involved and builds on our current practice.

We shall not permit any person to process Personal Data who is not under a duty of confidentiality.

Personal Data is kept for the time necessary to respond to the request by the User or individual, or for the purposes outlined in this document.

Partners (sub-processors) who process your data

Edtech businesses often use contractors and outside companies to help them run their businesses and manage relationships with individuals who may be interested in their Services. Any such company or individual that we use when processing information under this agreement is a “sub-processor”. Any agreement or contract we have with them is, at least, as strict as this agreement. We make sure that we are happy that they will also take the same level of care of the Personal Data actual or prospective Customers and Users are trusting us with, including checking if they hold any certificates for their work.

Here are the details of the main sub-processors and service providers; what data they collect, process and store; and a general explanation of why.

Service provider

Data collected or processed


Place of processing

Google Analytics (Google Inc)


Google Ads Data Processing Terms

Cookies and Usage Data

See Analytics section above


Google Mail (Google Inc)


Privacy Policy


Name, contact details, correspondence

Correspond by email with actual and prospective Customers or Users as described in this policy.


Name, contact details, organisation, role, interest in services, correspondence

Manage our relationship and communications with actual and prospective Customers and Users as described in this policy, including for marketing.


School and account details

Chat (live and automated) with and serve relevant articles and other content to actual and prospective Customers or Users as described in this policy.


Identity (including supplied name, email address, and optionally connected accounts), video call technical data.

Hold video meetings with actual or prospective Customers or Users.


Identity (including supplied name, email address, and optionally connected accounts), video call technical data.

Hold video meetings with actual or prospective Customers or Users.


Identity (including supplied name, email address, and optionally connected accounts), video call technical data.

Hold video meetings with actual or prospective Customers or Users.


Automated meeting notes on video and phone calls (optional when joining the call)

Take automated notes of any meetings


You agree that we have general permission to, from time to time, make changes to who our sub-processors are, or what they will be doing in order to provide you with an improved service. Any agreement or contract we have with new sub-processors will be, at least, as strict as this agreement.

If we do, we will notify you beforehand.  This will give you a chance to check any of the changes and raise any possible objections. If there are any objections, we will happily discuss these with you and address any concerns.

Third Parties

Pupil Progress Limited will NEVER sell your Personal Data to any other party and will only use this information to manage our relationship and interactions with you in relation to your interest in or use of our Services.

We will not disclose any Personal Data we collect about you to a third party without your knowledge.

Rights of individuals as Data Subjects including Subject Requests / Subject Access Requests

Data Subjects have rights under the Data Protection Act 2018 as amended, and other legislation, including to:

  • consult us as the Data Controller to learn about the contents and origin of the Personal Data we hold about them;
  • verify the accuracy of the Personal Data;
  • verify that the reasons and purpose the data is held are lawful;
  • ask for the Personal Data to be supplemented, deleted, updated, corrected, or transformed into anonymous format;
  • block general or specific Data Processing of the Personal Data for any and all legitimate reasons.

If you believe we hold your Personal Data and wish to exercise any of your legal rights under the Data Protection Act 2018 as amended or under any other relevant legislation as a Data Subject please make your request to us as the Data Controller at info@pupilprogress.com.

If you wish to engage with us about your Personal Data without invoking a specific legal right, you are also perfectly entitled to do so and we will be happy to respond to you on this basis. Please contact us at info@pupilprogress.com.

About this policy

Changes to this policy

We reserve the right to make changes to this policy at any time by posting revised versions on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed in the Version history section below.

If you object to any of the changes to the policy, you should cease using our Platform and Services, and cease visiting and interacting with all webpages connected with https://pupilprogress.com/, Pupil Progress social media accounts, advertisements, and any other online and offline presence. As above you can always invoke your legal rights to request that we as the Data Controller remove any Personal Data we hold on you.

Further information

More details about this policy or concerning the collection, storage or processing of Personal Data may be requested from us as the Data Controller at any time by contacting us at info@pupilprogress.com.

Version history

12th October 2022 – Further details given in the new section “Marketing and Communications Purposes” and a link to the Cookies policy in the cookies section.

11th September 2023 – Readability and clarity edits.