Ngaged Ltd Privacy Policy   

This Privacy Policy outlines how Ngaged Ltd ("we", "our", or "the Company") practices with respect to information collected from users who access our website at www.ngagedltd.uk or otherwise share personal information with us. The responsible authority within the meaning of data protection laws is Ngaged Ltd, operating in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are an alternative provision dedicated to providing teaching and mentoring support for students unable to attend traditional school settings.

Individuals have the following rights under UK GDPR, subject to exemptions:

• Receive confirmation as to whether or not personal information concerning you is being processed and access your stored personal information.
• Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
• Request rectification of your personal information that is in our control.
• Request erasure of your personal information.
• Object to the processing of personal information by us.
• Request to restrict processing of your personal information by us.
• Request data transfer (Right to data portability).
• Exercise rights related to automated decision making including profiling.
• Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. If you wish to exercise any of the above rights, please contact our Data Protection Officer via dpo@ngagedltd.uk.

We retain personal data only as long as necessary for the purposes for which it was collected, or as required by law. Specific retention periods are outlined in our data retention schedule, taking into account the type of information, the purpose for its collection, and applicable regulations.

Processing of your Personal Information is necessary for the performance of our contractual obligations towards you, providing you with our educational services, and protecting our legitimate interests. We also process data for compliance with legal and regulatory obligations to which we are subject. Data processing activities are conducted in accordance with the lawful bases set out in the UK GDPR and further detailed in the Data Protection Act 2018.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

We collect two types of data and information from Users: Non-personal Information (unidentified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site) and Personal Information (individually identifiable information).

As an alternative provision, the Personal Information we collect includes:

• Student Data: Personal details, Education, Health and Care Plans (EHCPs), educational records, and safeguarding information. This includes Special Category Data processed in compliance with specific conditions.
• Staff Data: Personal details, employment records, and DBS certificate numbers.
• Tutor Data: Contact information, qualifications, and payment details for our peripatetic tutors and mentors.
• Device Information: Geolocation data, IP address, unique identifiers (e.g., MAC address and UUID), and other information relating to your activity on the Site.

We do not rent, sell, or share Users' information with third parties, except as described in this Privacy Policy.

Data is collected and used for the following purposes:

• Providing teaching and mentoring support to students.
• Managing staff and tutors.
• Complying with legal and regulatory requirements.
• Operating our business, including banking and tutor management.

We may share data with:

• Schools and learning authorities.
• Relevant regulatory bodies.
• Service providers (e.g., banking, tutor management tools).

Data sharing is always conducted in compliance with UK GDPR. We may also disclose information if we have good reason to believe it is helpful or reasonably necessary to comply with applicable laws, investigate breaches, detect fraud, or protect the rights, property, or safety of us, our users, or the public.

The Site uses cookies, which are small pieces of information assigned to your device while viewing a website, to allow you to navigate efficiently and compile statistical data. We use session cookies (deleted when the browser is closed), persistent cookies (saved for a fixed period to remember preferences), and third-party cookies (set by services like analytics companies). You may remove cookies by following your device preferences, though disabling them may limit some features.

In order to present our contents correctly and make them graphically appealing across all browsers, we use script libraries and font libraries such as Google Web Fonts ( https://www.google.com/webfonts ) on this website. Google Web Fonts are transferred to your browser's cache to avoid multiple loading. If your browser does not support Google Web Fonts or does not allow access, content will be displayed in a default font. 

• Calling script libraries or font libraries automatically triggers a connection to the library operator. In theory, it is possible – but currently also unclear whether and, if so, for what purposes – that operators of corresponding libraries collect data.
  
  
• The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy.

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy. 

We implement appropriate technical and organisational measures to ensure data security. We use Google Workspace for Education to store data, and additionally use tablet computers, phones, and desktops to log and store young person data as well as staff data.

Our security measures include:

• Encryption of data at rest and in transit.
• Access controls and authentication.
• Regular security assessments.
• Data backup and recovery procedures.

In the event of a data breach, we will follow our Data Breach Response Plan, which includes notifying the ICO (Information Commissioner's Office) and affected individuals as required by the UK GDPR and the Data Protection Act 2018. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

We may use your Personal Information such as your name, email address, telephone number, etc., ourselves or by using our third-party subcontractors, for the purpose of providing you with promotional materials concerning our services which we believe may interest you. 

To respect your right to privacy, within such marketing materials we provide you with the means to opt out of receiving further marketing offers from us. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt out of receiving them. These may include announcements or administrative notices.

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

We understand the importance of protecting children's privacy. As an educational provider, we routinely process student data, including special category safeguarding information. Under no circumstances shall we allow the use of our services by minors without prior consent or authorisation by a parent, legal guardian, or the referring learning authority. If a parent or guardian becomes aware that their child has provided us with Personal Information without consent outside of our contracted services, they should contact us at office@ngagedltd.uk.

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. This policy will also be reviewed and updated regularly to ensure ongoing compliance with UK GDPR and the Data Protection Act 2018.

If you have any general questions about the Site, the information we collect about you, or how we use it, please contact our Data Protection Officer.

• Email: dpo@ngagedltd.uk

Last Modified 08/09/2026