Athena is a branded product owned wholly by Mobile Assisted Learning (MAL).
A privacy notice should address the following to key points sufficiently to inform a data subject:
Who is collecting the data?
Any registration data, test or survey questions and their replies are collected by the licensed organisation (or its employees). No other individual or organisation can access this data. MAL will not sell, distribute or use any data collected.
What data is being collected?
Athena collects data on behalf of the licensee and their users of our service. These are listed below: > Data Athena collects directly:
Organisations: You need an Organisation Account before you can populate or create tests and surveys using Athena. When an organisation registers for an Athena account, it requires unique usernames, forenames, surnames, password and unique email addresses. This is referred to as the Organisation Data.
Account settings: Users can set various preferences and personal details on pages like “My Account” e.g. a default language.
Import information: Athena will allow an Organisation to import its data (unique usernames, forenames, surnames, password and unique email addresses.) into Athena. MAL does not use this data for any other purpose.
Test/Survey data: We store test and survey questions and replies for registered Organisations.
Data collected indirectly when you interact with Athena:
Additionally, like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps.
What is the legal basis for processing the data?
Athena treats an organisation’s data, test/survey questions and responses as information that is private to a that organisation. MAL do not sell this data to third parties. Athena use the information collected on behalf of licensed organisations in connection with providing a service to them and their test/survey participants.
To provide our services: In order to provide customer support, authorised MAL personnel may access an organisation’s information to assist with troubleshooting, testing, and for service improvement, research and development purposes.
To manage our services: We will internally use an organisation’s information, including certain test/survey data, for the following limited purposes:
To monitor, maintain, and improve our services and features: We internally perform statistical and other analysis on information Athena collects to analyse and understand how our service is used, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features. Authorised MAL personnel may use your information for internal purposes designed to keep our services secure and operational, such as for troubleshooting and testing purposes, and for service improvement, research and development purposes.
To prevent potentially illegal activities.
To screen for and prevent undesirable or abusive activity. For example, screening for phishing, spam, and fraudulent activities.
To contact you about your service or account. MAL may send you communications of a transactional nature (e.g. service-related announcements, changes to our services or policies).
To respond to legal requests and prevent harm. If MAL receive a legal request, we may need to inspect any data we hold to determine how to respond.
Will data be shared with any third parties?
MAL may disclose an organisation’s data, test/survey questions and responses to third parties for a limited number of reasons as follows:
Information may be disclosed as required by law, or when we believe that disclosure is necessary to protect our rights, protect an organisation’s safety or the safety of others, and/or to comply with a legal proceeding or court order served on MAL.
If ownership of all, or substantially all of our business changes, or we undertake a corporate reorganisation (including a merger or consolidation) or any other action or transfer between Mobile Assisted Learning, you expressly consent to MAL transferring your information to the new owner or successor entity so that they can continue providing their services.
How will the information be used?
Any registration data, test or survey questions and their replies is private, belonging to, and for the use of the licensed organisation (or its employees). We do not pass on or sell this data to third parties.
Athena use the data only to provide our services to licensed organisation (or its employees) on behalf, to test/survey respondents.
How long will the data be stored for?
Athena generally retains an organisation’s data for as long as they have an organisation account with us, or to comply with our legal obligations. Data that is deleted from our servers may remain as residual copies on offsite backup media for up to approximately 1 month afterward.
What rights does a data subject have?
Access/Update user account details: As a user account holder, you may access and correct certain personal information that Athena holds about you by visiting your My Account page. Some corrections may require Athena personnel to change details. Athena will respond to your request to exercise these rights within a reasonable time and, where required by law or where we deem it otherwise appropriate and practicable to do so, we will honour your request.
Download/backup test and survey data: Athena provides an organisation with the ability to export test/survey data in a variety of formats. This allows the creation of their own backups or to conduct off-line data analysis.
Delete test/survey data: We will permanently delete your data if you request to cancel your account. Deleting test/survey data will not permanently delete this data immediately. We may also retain your deleted data for a limited time in case you delete something by accident and need to restore it (which you can request by contacting us.)
Cancelling an account: To cancel and delete your account, please contact Athena. Deleting your account will cause all the data in the account to be permanently deleted from our systems within a reasonable time period, and will disable your Athena service. We will respond to any request to access, correct, update or delete personal information within the time period specified by law or without excessive delay. We will promptly fulfil requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law.
How can the data subject raise a complaint?
Along with your right to complain, here is a list of all the rights that all individuals have under data protection laws.
The right to be informed about the processing of your personal information
The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
The right to object to processing of your personal information
The right to restrict processing of your personal information
The right to have your personal information erased (the “right to be forgotten”)
The right to request access to your personal information and to obtain information about how we process it
The right to move, copy or transfer your personal information (“data portability”)
Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the contact form on our website.