Privacy Policy
This privacy policy explains how we collect, use, and protect your personal data when you use our services.
Important information and who we are
Information about Dr Frost Learning and our services
This privacy policy gives you information about how we at Dr Frost Learning collect and use your personal data that you give us when you register with us or use our website.
Your ‘personal data’ means any information about you that can be used to identify you (like your name, your age, or your email address).
This website is intended for adults and children, alike, so we will be collecting personal data relating to children.
You can download a PDF copy of this Privacy Policy here.
You can view the most current version of this Privacy Policy online at https://www.drfrost.org/privacy
Controller
Dr Frost Learning is the controller and is responsible for your personal data (collectively referred to as “Dr Frost Learning”, "we", "us" or "our" in this privacy policy).
Where a school or similar organisation has chosen to enrol multiple students with accounts on Dr Frost Learning, they will be an independent controller of the personal data that they gather and provide to us.
The types of personal data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect and use aggregated data which is not personal data as it does not reveal your identity. For example, we may combine students' Identity and Profile Data to calculate and assess how different age groups are using our website and progressing with their maths.
Identity Data
Contact Data
Transaction Data
Technical Data
Profile Data
Usage Data
Marketing and Communications Data
Support Data
How is your personal data collected?
We use different methods to collect data from and about you including through:
Your interactions with us.
You may give us your personal data when you contact us or use our website. This includes personal data you provide when you:
- create an account on our website
- sign up for a subscription
- request information about new features to be sent to you
- give us feedback or contact us
Automated technologies or interactions.
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
Third party sources.
If you are a student using our website, we may receive personal data about you from your parents, tutor, or your school.
Our Help Centre (support.drfrost.org) is provided by Zendesk Inc., a third-party service where you can access support documentation, browse FAQ articles, and contact us with questions or feedback. When you submit information through our Help Centre, this data is processed by Zendesk Inc. on our behalf as a data processor under GDPR. Zendesk processes this data in accordance with their privacy commitments, which can be found on their Privacy and Data Protection website (https://www.zendesk.com/company/privacy-and-data-protection/).
Payment sources.
If you purchase a subscription, we will receive Contact, Financial and Transaction Data from providers of technical and payment services.
How we use your personal data: Legal Basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract with you
Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests
We may use your personal data where we need it to conduct our business and pursue our legitimate interests (for example to prevent fraud and enable us to give you the best and most secure customer experience). We make sure we consider any potential impact on you 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 outweighed by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation
We may use your personal data where it is needed to comply with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent
We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.
How we use your personal data: Purposes
We have set out below a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so.
To register you as a new user
When you register with us as a user, we will take the information you give us (like your name, age, and email address) to complete your profile. You will be able to use this profile to use our website.
Data types:
- Identity
- Contact
Legal basis:
- Necessary for our legitimate interests (to provide access to our service to you)
To record your progress with the materials and tests provided on our website
As you use our website, we will track and record how you have got on with materials you have engaged with and tests you have done. This means you can monitor how you are progressing in your studying.
Data types:
- Profile
- Usage
Legal basis:
- Necessary for our legitimate interests (to provide the best service to you)
To process your subscription
Including managing payments, fees and charges, and collecting and recovering money owed to us.
When someone (whether that be a student, parent, or school official) signs up for our paid subscription, we will receive certain information (such as the payer’s name) and certain financial information (such as their bank account details).
We will use this information to process payment, and can use contact information to get in touch if there are any issues.
Data types:
- Identity
- Contact
- Financial
- Transaction
- Marketing and Communications
Legal basis:
- Performance of a contract with you
- Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you
Including notifying you about changes to our terms or privacy policy, and dealing with your requests, complaints and queries.
Where we need to make changes to our Terms and Conditions or our Privacy Policy, we may need to use your Contact details to tell you about this.
We may also need to use your Profile and Identity information when handling any queries, requests, or complaints from you.
Data types:
- Identity
- Contact
- Profile
- Marketing and Communications
Legal basis:
- Performance of a contract with you
- Necessary to comply with a legal obligation
- Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)
To administer and protect our business and this website
Including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
We may need to use your information when we are ensuring our website (and your data) is secure, functional, and optimised.
Data types:
- Identity
- Contact
- Technical
Legal basis:
- Necessary for our legitimate interests (of running our charity and ensuring network security)
- Necessary to comply with a legal obligation
To use data analytics to improve our products
Including our website, service, customer relationships and experiences, and the effectiveness of our communications.
We may use data to help us know how students are using our website, and how we might improve it and your user experience.
Data types:
- Usage
Legal basis:
- Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to improve our website)
To send you relevant communications
Including personalised suggestions and recommendations to you about website features that may be of interest to you based on your Profile Data.
If we have new website features that we think might be helpful to you in particular, we may use your data to tell you about it.
Data types:
- Identity
- Contact
- Usage
- Profile
- Marketing and Communications
Legal basis:
- Necessary for our legitimate interests (to carry out direct marketing and develop our services)
- Consent, having obtained your prior consent to receiving direct communications from us
To provide customer support through our Help Centre
Including responding to your enquiries and support requests, improving our help documentation and resources, and developing new support content based on user needs
Data types:
- Identity
- Contact
- Support Data
Legal basis:
- Necessary for our legitimate interests (to provide customer support and improve our services)
How we use your personal data: Direct Marketing
How we use your personal data: Cookies
International transfers
We may send your personal data to service providers that support us in our work. This may involve sending personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that we will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
Data security
We have security measures to stop your personal data being accidentally lost, used or accessed in an unauthorised way, changed, or disclosed.
We also only give access to your personal data to people who work for us or our sub processors and who have a real need to know it. They will only process your personal data following our instructions and will need to keep it confidential.
We have procedures to deal with any suspected personal data breach and will tell you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may keep your personal data for a longer time in the event of a complaint or if we reasonably believe there might be a legal dispute concerning our relationship with you.
To determine how long we will keep your personal data, we consider the amount, nature and sensitivity of it, 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, regulatory, tax, accounting or other requirements. We reserve the right to delete your account details and personal data if you have not logged into your account in two years.
In some circumstances you can ask us to delete your data. See below for further information.
Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
Ask for access to your personal data
(Commonly known as a "subject access request")
This means we will give you a copy of the personal data we hold about you so you can check that we are processing it lawfully.
Ask us to correct the personal data that we hold about you.
This lets you correct any incomplete or inaccurate data we hold about you, although we may need to check the accuracy of the new data you provide to us.
Ask us to erase your personal data.
You can ask us to erase your personal data where:
- there is no good reason for us continuing to process it;
- you have exercised your right to object to processing (see below);
- we may have processed your information unlawfully; or
- We are required to erase your information to comply with local law.
We may not always be able to comply with your request to erase your personal data for specific legal reasons. If this is the case, we will tell you when you make your request.
Object to us processing your personal data where we are relying on a legitimate interest as the legal basis for that particular use of your data.
Sometimes, we may have legitimate reasons to process your information which outweigh your right to object. We will tell you if this is the case.
Object to the processing of your personal data for direct marketing purposes.
You can object at any time to the processing of your personal data for direct marketing purposes.
Ask us to transfer your personal data to you or to someone else.
We will provide to you or the person you have chosen your personal data in a structured, commonly used, machine-readable format.
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 products or services to you. We will tell you if this is the case at the time you withdraw your consent.
Ask for restriction of processing of your personal data.
This means you can ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to check 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.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay anything to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.We could also refuse to comply with your request in these circumstances.
What we may need from you
We may need to ask you for specific information 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 to make sure that personal data is not disclosed to someone 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Sometimes it could take us longer than a month if your request is complex or if you have made lots of requests. If this is the case, we will tell you so and keep you updated.
Contact details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us at [email protected]
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 18th August 2025.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes (for example, if you get a new address or email address).
Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Need Help?
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us at:
