Privacy Policy

Table of Contents

Summary Version

This version of the Privacy Policy is aimed at Children and Young People.

1. About the Platform

What is the Platform

The Navigatr App (the Platform) is an internet-based platform for adults and young people aged 13 years and above. The platform provides a service for you to access and collect digital badges which recognise your learning and achievements and help you find opportunities for further learning, skills, to improve your wellbeing or to progress your career.

It also helps organisations who provide these opportunities (providers) to make them easier to find.

When you join, you will need to choose a ‘community’. A community is a collection of organisations that provide learning, training and work-related opportunities around a theme or in a city or region. The community you join will determine which data you are asked to give, and who will see it.

Who are we?

The Platform is managed by Navigatr Limited. They work with two different technical partners including Real Ideas Organisation (Badge Nation) and Credly Inc, to deliver this service.

Region of Learning

This is the name given to the Community on the Platform that hosts Providers in Cambridgeshire and Peterborough and lists the opportunities to learn or work in the Region and that can be accessed through the Platform.

2. About this privacy policy

A privacy notice tells you what personal data we collect about you and how we use it and what you can do about it. Personal data means any information that can be used to identify you, such as your name, home address, date of birth, email address, or picture of you.

You must read and agree (give your consent) to this privacy policy before giving Navigatr or any communities your personal data.

The information in this privacy policy is for children and young people and covers Navigatr and all the partners for the Platform. Updates and changes are available through the Platform, so check back regularly to see them.

If you are under 13 years old you must not use the Platform.

3. Why we are collecting data

Navigatr may recommend activities and opportunities based on your interests, where you live, what you've earned as digital badges, and what pathways you're following. You can update any of this information at any time in your profile settings.

Credly may display your digital badges on other websites if you decide to share (for example, Facebook or Linkedin).

Community organisations will use information in the following ways:

Region of Learning

In order to create your library user account and smart card, Cambridgeshire Libraries will collect your name, email address, address, and date of birth.

Cambridge City Council may send you occasional e-newsletters or surveys, informing you of special offers or promotions, or asking what you think about Region of Learning. By clicking on the "unsubscribe" link at the bottom of the e-newsletter, you can unsubscribe at any time.

Only applicable if you joined Navigatr before 1 February 2023:

Credly may display your digital badges on other websites if you decide to share (for example, Facebook or Linkedin).

4. Who decides how my information is used

The community you join on The Platform will determine who decides what data to collect, how it is used and who it is shared with.

Unless you sign up to one of the communities below, Navigatr decides what data to collect, and how it is used and shared (Data Controller).

We will share your email and name with a company called Credly in the USA who will let you know when your digital badge is ready. You will need to accept their Terms and Conditions and their Privacy Policy.

Some communities may also decide how your data is used:

Region of Learning

If you join the Region of Learning community for Cambridgeshire and Peterborough, Cambridge City council decides what data is collected, how it is used and who it is shared with and Navigatr follow these rules (Data Controller). Your personal data (email address and name only) is shared with Cambridgeshire Libraries (Data Controller) if you would like to receive a smart library card to use alongside the digital Platform to receive digital badges.

Only applicable if you joined Navigatr before 1 February 2023:

We will share your email and name with a company called Credly in the USA who will let you know when your digital badge is ready. You will need to accept their Terms and Conditions and their Privacy Policy.

5. What information is collected about you

Navigatr collects personal information such as your name and email address when you join the Platform. In order to display digital badges from Credly, Navigatr will use your Credly account information. If necessary, we may ask for information about your interests and needs.

Other Communities may also ask for your consent to collect other personal or sensitive information about you:

Region of Learning

You do not have to provide additional personal information but providing it will mean you have an improved and more personalised experience of the Platform. You can decide not to tell us any of this information.

6. Where does the Platform get my information from

All of the personal and sensitive data is provided to us directly by you when you join the Platform. We will also share and receive information from Credly (your name and email address) so we can show your digital badges on your Platform profile.

Region of Learning

Only applicable if you joined Navigatr before 1 February 2023:

We will also share and receive information from Credly (your name and email address) so we can show your digital badges on your Platform profile.

7. Who we will share information with

Navigatr will share your personal information (name and email address) with that activity or opportunity provider and some other third party organisations so they can issue you a digital badge. You can find out more about our third parties in our full document.

We work with Credly, an American company that stores your data there. Upon attending an activity, Credly will ask for your name and email address so that a digital badge (credential) can be issued. Credly will email you instructions for claiming the badge. To learn how Credly handles your information, read their privacy policy.

Navigatr will share personal and/or sensitive information with the following Community providers and their partners:

Region of Learning

Cambridge City Council will share information with Cambridgeshire Libraries and Civica Spydus (who process the information on the Cambridgeshire Libraries database).

Only applicable if you joined Navigatr before 1 February 2023:

Upon attending an activity, Credly, an American company that stores your data there, will ask for your name and email address so that a digital badge (credential) can be issued. Credly will email you instructions for claiming the badge. To learn how Credly handles your information, read their privacy policy.

8. How long we will keep your information

Navigatr will keep your personal information for as long as you are a member of the Platform. You can request at any time for your information to be deleted, which they will do within 30 days of your request.

Credly will keep your personal information for as long as your account is active, or until you close your account when your data is permanently deleted. Credly’s privacy policy is located at https://info.credly.com/privacy-policy. The Real Ideas Organisation (Badge Nation) will request Credly to delete the data of anyone who hasn't claimed their badges after 6 months. Badge Nation’s privacy notice is located at: https://realideas.org/policies/.

The following Community providers (and their partners) will keep the information as follows:

Region of Learning

Navigatr will notify Cambridge City Council if you request deletion of your information, and the Council will notify Cambridgeshire Libraries and your personal data (as well as any stored special category data) will be deleted from the databases of the Council and Cambridgeshire Libraries within 14 days.

Cambridgeshire Libraries only keep information for as long as it is needed which can be between one and six years depending on the specific details. Their Library Service Privacy Notice explains this in more detail.

Only applicable if you joined Navigatr before 1 February 2023:

Credly will keep your personal information for as long as your account is active, or until you close your account when your data is permanently deleted. Credly’s privacy policy is located at https://info.credly.com/privacy-policy. The Real Ideas Organisation (Badge Nation) will request Credly to delete the data of anyone who hasn't claimed their badges after 6 months. Badge Nation’s privacy notice is located at: https://realideas.org/policies/

9. Your data protection rights

You have the right to:

  • Be told how we use your information
  • Ask to see the information we hold about you.
  • Ask us to change your information you think is wrong.
  • Ask us to remove information we hold about you when it’s not needed anymore.
  • Ask us to only use your information in certain ways.
  • Tell us you don’t want your information to be processed.

10. Our contact details

For any questions about this Privacy Policy, or, to exercise any of your data protection rights, please email Navigatr at gdpr@navigatr.app or write to Data Protection, Navigatr, Castleton Mill, Castleton Close, Leeds, West Yorkshire, LS12 2DS. A detailed version of the Privacy Policy is also set out below.

Region of Learning

If you have a query regarding your rights, please contact the Cambridge City Council emailing infogov@3csharedservices.org or you can write to them and mark your letter for the attention of the Data Protection Officer and address it to Cambridge City Council, Mandela House, 4 Regent Street, Cambridge, Cambridgeshire CB2 1BY.

Detailed Version

1. About the Navigatr Platform

What is the Platform?

The Navigatr App (“the Platform”) is an internet-based platform for adults and young people aged 13 years and above that is hosted and stores data in the UK. The Platform is designed to enable individuals that subscribe to the Service to access digital badges and pathways that connect learning achievements with job opportunities or further learning. Navigatr enables individuals (“Earners”) to receive digital badges via a unique QR code. The Platform enables Earners to display badges they have online on the Service or on third party sites such as Linkedin.

What is the purpose of the Platform?

The Platform is designed to promote opportunities to individuals to engage in learning, career progression, skills or personal development, and to recognise their learning and civic participation using digital badges containing skills information. Engagement data in activities and opportunities can be used by Providers and Communities to understand participation in their local offer.

What is a Provider?

A Provider is an organisation, employer or business that provides the Platform content. Content includes; activities, opportunities, or digital badges on the Platform. A Provider could be a local authority, training, education or certification provider, membership organisation, non profit organisation or corporation.

What is a Community?

A “Community” is a collection of “Providers” - organisations that provide learning, training, certifications and employment opportunities for individuals in a city, region or across an institution. Communities can create pathways, badges and activities and opportunity content on the Platform on behalf of Providers.

The community you join will determine the kind of data you’re asked to provide and who is the Data Controller and Data Processor of your data (see below description)

Region of Learning

This is the name given to the Community on the Platform that hosts Providers in Cambridgeshire and Peterborough and lists the opportunities to learn or work in the Region and that can be accessed online.

Who are we?

The Platform is managed by Navigatr Limited (“Navigatr”) (company no: 11761403) of Navigatr, Castleton Mill, Castleton Close, Leeds, West Yorkshire, LS12 2DS.

Who are our technical partners?

We work with different technical partners to deliver our core services and these are:

  • Real Ideas Organisation (operated as Badge Nation) of Devonport Guildhall, Kerr Street, Plymouth PL1 4EL; and
  • Credly, Inc. (a Delaware corporation) of New York City. Our registered address is 368 9th Avenue, 6th Floor, New York, NY 10001. Credly is a wholly owned subsidiary of NCS Pearson, Inc.

Region of Learning

Only applicable if you joined Navigatr before 1 February 2023:

We would share and receive information from Credly (your name and email address) so we can show your digital badges on your Platform profile.

  • Credly, Inc. (a Delaware corporation) of New York City. Our registered address is 368 9th Avenue, 6th Floor, New York, NY 10001. Credly is a wholly owned subsidiary of NCS Pearson, Inc.

2. About the Navigatr privacy policy

Navigatr is committed to data security and the fair and transparent processing of personal data. This privacy policy “Policy” sets out how we will treat the personal data provided to us in compliance with applicable data protection law, in particular the General Data Protection Regulation (EU) 2016/679 (GDPR).

Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share your personal data, your rights in relation to your personal data, how to contact us and the supervisory authorities you can report a concern to about the way we process your data. You must confirm that you provided consent by reading this Privacy Notice before providing Navigatr with your personal data.

The information in this Privacy Policy applies to Navigatr and all partners, and any exceptions are clearly identified and explained in relation to specific Communities (for example Region of Learning).

Children’s privacy

The Platform is not provided to any individual under the age of 13 years and we do not collect personal information from anyone under the age of 13 years. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us using the details provided below under ‘our contact details’.

Terms and definitions we use

Within this Policy, we use the following terms as defined in the data protection legislation which includes but is not limited to GDPR (UK) the Data Protection Act 2018, Privacy and Electronic Communications Regulation (PECR), and any other relevant legislation in place at the time of reading this Privacy Policy:

Important note

Any exceptions to how your data are processed is clearly identified and explained in relation to specific Communities (for example Region of Learning).

Changes to our Policy

Any changes we may make to how your data is processed will be included in an updated Privacy Policy made available through the Navigatr app. You will be notified of any changes via email. Please check back frequently to see any updates or changes to our Policy.

3. Why Navigatr is collecting data

The Platform is designed to recognise learning and civic participation using digital badges that contain skills information. The Platform highlights what additional or related badges you can engage with on a pathway in order to work towards a destination in employment or further education or training.

In order for us to create and manage your account, provide a personalised experience, display content based on your interests and location and to provide you with the best possible service; we need to collect and use personal information about you.

Communities

In addition, the following Communities have additional reasons for collecting information:

Region of Learning

Cambridge City Council is the lead partner for the Region of Learning Community and the Cambridgeshire and Peterborough areas. Cambridge City Council provides services for local communities and the people who live in them. Undertaking this work means that we must collect and use information about the people we provide services to and keep a record of those services. Because we collect and use personal information about individuals, we must make sure that they know why we are collecting their information.

We use information to support equal access to opportunity and we ask consent to collect personal and sensitive data to monitor and ensure equality of access, signpost opportunities to diverse groups, lessen disadvantage, offer targeted discounts, or help remove barriers or obstacles faced by people when accessing opportunities. For example, because they are under-represented in employment, or whose participation is disproportionately low.

Cambridge City Council has additional reasons for collecting your information in relation to the following purposes:

Offer you an integrated smart library card to use alongside the Platform

With delivery partners Cambridgeshire County Council and Cambridgeshire Libraries; Cambridge City Council will offer you an integrated smart library card as a secondary means to record your attendance and participation at activities and events which can be used to award your digital badge and recognise your experience and skills in real time; that does not rely upon having a mobile phone. The smart library card will also provide you full access to all library services. Together, the app and smart library card enables people to explore, engage, articulate, and evidence their skills and learning experiences to opportunity providers.

Communication and e-newsletters

By opting in, Cambridge City Council will use your personal data (email address) to send you a periodic e-newsletter that will tell you about special offers, competitions, new Platform features, and news about the Region of Learning Community. We may also contact you for feedback or evaluation purposes through occasional short surveys. We may, from time to time, contact you regarding other services offered by Cambridge City Council. You may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in the email from us.

4. Who are the Data Controllers and Data Processors

The Data Controller and Data Processor are determined by which Community you join when creating an account on the Navigatr app.

(If you join the Region of Learning Community for Cambridgeshire and Peterborough, please skip this section and jump directly to read the information in the box below)

Upon registering an account with the ‘Navigatr Community’, Navigatr Limited is the Data Controller for all your data (personal) stored in the Navigatr digital app platform in a UK database. Navigatr are the data controller for any Community, except for those listed under ‘Communities that are data controllers’ below.

Communities that are data processors

When you are engaged in any activities, events, pathways, or digital badges (credentials) listed on a Community, the respective Community Administrator is the Data Processor of the personal data (your email address and name only). Unless other communities content you interact with also ask for special category (sensitive) data in which case you will be asked to give consent in order to proceed. Some Communities may be data controllers (see below).

Technical partners that are data processors

When you create a new account on the Platform, your email address and name are shared with Credly to process and send you a notification of your digital badge via email.

To claim your badge, you are asked to sign in to an existing account or register for a Credly account as part of this process (https://credly.com/users/sign_up). You will be asked to accept the Credly Earner Terms and Conditions of Use (https://credly.com/terms) and the Credly Data Privacy Policy (https://credly.com/privacy). At this point, Credly becomes the Data Controller of your personal data and stores your data (name and email address) in the USA.

The Platform searches for your email address to connect your Credly account ID with your profile to display digital badges you have earned on Credly (this is called a ‘badge assertion’).

Region of Learning

Only applicable if you joined Navigatr before 1 February 2023:

When you create a new account on the Platform, your email address and name are shared with Credly to process and send you a notification of your digital badge via email.

To claim your badge, you are asked to sign in to an existing account or register for a Credly account as part of this process (https://credly.com/users/sign_up). You will be asked to accept the Credly Earner Terms and Conditions of Use (https://credly.com/terms) and the Credly Data Privacy Policy (https://credly.com/privacy). At this point, Credly becomes the Data Controller of your personal data and stores your data (name and email address) in the USA.

The Platform searches for your email address to connect your Credly account ID with your profile to display digital badges you have earned on Credly (this is called a ‘badge assertion’).

Communities that are data controllers

Region of Learning

Cambridge City Council is the Data Controller at the point you register your information with the Region of Learning Community.

If you joined Navigatr before 1 February 2023:

Credly is the ‘processor’ of the personal data (your email address and name only).

Digital badges were issued by Credly. Credly is the ‘processor’ of the personal data (your email address and name only).

When you create a new account on the Platform, your email address and name are shared with Credly to process and send you a notification of your digital badge via email.

To claim your badge, you are asked to sign in to an existing account or register for a Credly account as part of this process (https://credly.com/users/sign_up). You will be asked to accept the Credly Earner Terms and Conditions of Use (https://credly.com/terms) and the Credly Data Privacy Policy (https://credly.com/privacy). At this point, Credly becomes the Data Controller of your personal data and stores your data (name and email address) in the USA. The Platform searches for your email address to connect your Credly account ID with your profile to display digital badges you have earned on Credly (this is called a ‘badge assertion’).

If you joined Navigatr on or after 1 February 2023:

Navigatr Limited is the Data Processor for all data (personal or special category data) stored in the Platform which has a UK database. Real Ideas Organisation (operating as Badge Nation) is the ‘processor’ of the personal data (your email address and name only).

When you create a new account on the Platform, your email address and name are stored in the Navigatr digital app platform and we will send you a notification of your digital badge via email. To claim your badge, you are asked to sign in to an existing account or register for an account as part of this process.

If you are a member of another Community and engage in any activities, events, pathways, or digital badges (credentials) hosted by Providers in the Region of Learning Community, Cambridge City Council is the Data Processor of the personal data (your email address and name only).

When you join the Region of Learning Community, your personal data (email address and name only) is shared with other Data Controllers - Credly (only applicable if you joined Navigatr before 1 February 2023 and at the point you claim your digital badge), Cambridgeshire County Council, and Cambridgeshire Libraries who are the “controllers” of this data.

Understand the impact of digital badges and the Platform

Cambridge City Council is developing an approach with trusted partner Cambridgeshire County Council to provide a data research platform with depersonalised data from Region of Learning. Both Cambridge City Council and Cambridgeshire County Council are the Data Controllers of your personal data.

Offer you an integrated smart library card to use alongside the Platform

Cambridgeshire County Council is the Data Processor of your personal data (email address, name, home address and date of birth) when you connect your Region of Learning Community account with your Cambridgeshire Libraries Smart Library Card. Your data will then be sent to their database for the creation of a new user account or connection to your existing account. At this point, Cambridgeshire Libraries are then the Data Controller when your personal data is extracted from their database to use your new, smart library card.

5. What data is collected

Data you provide to us

When you create an account on the Platform, Navigatr will collect and process the following personal data:

Personal data

To create a user profile on the Platform and to receive digital badges issued by Credly:

  • First name
  • Last name
  • Email address

To personalise your experience on the Platform:

  • Home address (full address including city and postcode)
  • Date of birth
  • Profile picture

Region of Learning

Providing this personal data is optional but encouraged to provide a more personalised experience.

Cambridge City Council believes in equal access to opportunity and we ask to collect the following personal data with your consent:

Highest qualification

We ask you to tell us your highest qualification so that we can match this to any learning or employment opportunities that have qualification level requirements in order to apply or participate in. It also allows us to better signpost opportunities to gain any qualifications that you might need.

Employment status

We ask you to tell us your employment status so that we can monitor and ensure equality of access to the platform, and signpost and make visible opportunities to more diverse groups including those who are unemployed, economically inactive, or at risk of/not in education, training or employment (NEET). We also use your employment status where a Provider or Employer is taking positive action to lessen disadvantage, or remove barriers or obstacles it reasonably believes are faced by people who are not in work when accessing their opportunities. For example, because they are under-represented in their organisation, or whose participation is disproportionately low. This also helps us to support the economic wellbeing of people using this Platform.

Free school meal status

We ask you to tell us if you receive free school meals/pupil premium or have received free school meals/pupil premium previously, so we can offer targeted special incentives such as reduced cost or free activities and special initiatives to make participation more affordable to low-income groups. This also helps us to support the economic wellbeing of people using this Platform.

Number of UCAS points you have

We ask you to tell us the number of UCAS points you have so that we can match this to any learning or employment opportunities that have UCAS points requirements in order to apply or participate in.

Only applicable if you joined Navigatr before 1 February 2023:

Digital badges were issued by Credly. When you create a user profile on the Platform and to receive digital badges issued by Credly, Navigatr will collect and process the following personal data:

  • First name
  • Last name
  • Email address

To display digital badges issued by Credly on your profile:

  • Your Credly account details

Special category (sensitive) data

We will ask your permission to collect, store and use special category data, including ethnicity, and information relating to disability or learning difficulties in order to personalise and optimise your experience of the Platform.

Choosing not to provide special category data will not prevent your use of the Platform but may limit access to additional services and support provided by your Community.

Region of Learning

Providing special category (sensitive) data is optional but encouraged to provide a more personalised experience. This data has extra protection in law and requires us to identify a condition for processing under Article 9 of the GDPR.

Cambridge City Council believes in equal access to opportunity and we ask to collect the following special category (sensitive) data with your consent:

Gender We ask you to tell us your gender so that we can monitor and ensure equality of access to the platform, and signpost and make visible opportunities to more diverse groups. We also use your gender where a Provider or Employer is taking positive action to lessen disadvantage, or remove barriers or obstacles it reasonably believes are faced by people of a particular gender when accessing their opportunities. For example, because they are under-represented in their organisation, or whose participation is disproportionately low.

Ethnicity

We ask you to tell us your ethnicity so that we can monitor and ensure equality of access to the platform, and signpost and make visible opportunities to more diverse groups. We also use your ethnicity where a Provider or Employer is taking positive action to lessen disadvantage, or remove barriers or obstacles it reasonably believes are faced by people of different ethnicities when accessing their opportunities.

Work limiting health conditions

We ask you to tell us this so we can signpost to you more relevant work-related opportunities. This also helps us to support the economic wellbeing of people using this Platform.

Disability or learning difficulty

We ask you to tell us if you have a disability or learning difficulty so that we can signpost you to activities or opportunities that are accessible or to employers who are disability confident for example. We also use this information where a Provider or Employer is taking positive action to lessen disadvantage, or remove barriers or obstacles it reasonably believes are faced by people with disabilities or learning difficulties when accessing their opportunities. This also helps us to support those with a particular disability, and support the economic wellbeing of certain individuals.

Accessibility requirements

We ask you to tell us this if you have any special needs, for example if you are a wheelchair user and require ramp-friendly access.

In addition, Cambridge City Council is processing data on behalf of the DWP with the following special category condition for processing `special category’ (sensitive) data: Article 9(2) (b) “processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject”.

Only applicable if you joined Navigatr before 1 February 2023:

To display digital badges issued by Credly on your profile, Navigatr will collect and process your Credly account details.

Interest and preference data

We ask you for the following types of information to enable you to have a more personalised experience of the Platform, and to ensure that any activities or opportunities recommended by the Platform will meet your needs or interests:

  • What type of activities/learning style would you like to participate in
  • What type of personal goals you like to achieve
  • What type of career aspirations you have
  • What self-development goals do you want to achieve

Data we collect automatically

If you visit the Platform, Navigatr may automatically collect the following information:

  • Technical information, including the internet protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Information about your visit to our website such as the credential products you searched for and view, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Data we derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer preferences based on your activity history.

6. Where does the Platform get my data from?

Data you supply

All of the personal and special category data is provided to us directly by you for one of the following reasons and if you:

  • Sign up for a new account on the app
  • Join a Community that asks for Special Category data
  • Correspond with us by phone, e-mail, or in writing
  • Report a problem
  • Make a request related to your Data Protection Rights
  • Fill out a form on our website
  • Give consent to receive communications such as e-newsletters from your Community.
  • Accept a digital badge issued by Credly

Information we receive from other sources

Credly

Navigatr receives your Digital Badge Assertion data (Digital Badges you have earned) from Credly in order to display your Digital Badges on your Navigatr profile.

When you create an account on the Platform, Navigatr will share your name and email address with Credly to find a Credly account with the same email address. Credly will then send you a notification that you have earned a digital badge to your email address.

Region of Learning

Only applicable if you joined Navigatr before 1 February 2023:

Navigatr receives your Digital Badge Assertion data (Digital Badges you have earned) from Credly in order to display your Digital Badges on your Navigatr profile.

When you create an account on the Platform, Navigatr will share your name and email address with Credly to find a Credly account with the same email address. Credly will then send you a notification that you have earned a digital badge to your email address.

7. Who we will share your information with

Personal data

Content Providers and Communities

Navigatr will share your personal data (name and email address) with the Provider - the organisation who has listed the content you have engaged with; this includes activities, digital badges or pathways to work or learning opportunities and their associated Community when you:

  • Join a Community
  • Attend an activity
  • Start a pathway
  • Complete a pathway
  • Are issued with a Digital Badge
  • Accept a Digital Badge from Credly
  • Save a Badge, Pathway or Activity
  • Upload a profile picture

Technical Partners

Credly

Navigatr delivers the digital badge functions of our Services through Credly, an authorised third-party technical partner and Data Processor that is American based and stores your data in the United States of America.

You will need to provide Credly with certain information about yourself when you sign up for their service or use it.

When creating a new account in the Platform, you will receive a digital badge from Credly, you will receive a notification via email. The process will prompt you to connect your Credly account details with your Platform account, so that digital badges (credentials) issued via Credly can appear on your profile.

You will be required to share your personal information (such as name, email address) with Credly so that a digital badge (credential) can be issued to you after attending an activity. Credly will email you instructions on how to claim the digital badge.

It is important to note that Credly's services require you to sign up and create an account with them, and you will be required to agree to Credly's privacy policies and terms of use when you do so. For more information, please see Credly's privacy policy or contact privacy@credly.com. You can read Credly's privacy policy to learn how they handle the information you share with them. Credly's privacy policy also explains how data subject rights can be exercised.

Badge Nation

When a Digital Badge is issued to you from Credly, Badge Nation will have access to your personal data (name and email address) in relation to the badge issued via Credly’s Digital Badge Statistics.

Other organisations

Navigatr may also share your information with:

  • Legal and other professional advisers, consultants, and professional experts
  • Service providers contracted to us in connection with provision of the products and services such as providers of IT services, hosting, development, management and consultancy, and customer relationship management services
  • Analytics and search engine providers, such as Google Analytics IP Anonymization that assists us in the improvement and optimisation of our product. This includes anonymised data on the number of users, session statistics, approximate geolocation, browser and device information.
  • Law enforcement or other authorities if required by applicable law.

Where the third party is our data processor, we will ensure there is a contract in place which includes obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them. Navigatr will ensure that these GDPR requirements are replicated for any third party contracts.

Region of Learning

Only applicable if you joined Navigatr before 1 February 2023:

Navigatr will share your personal data (name and email address) with Credly when you create a new account in the Platform or accept a Digital Badge.

Navigatr delivers the digital badge functions of our Services through their technical partner Credly, an authorised third-party technical partner and Data Processor that is American based and stores your data in the United States of America.

You will need to provide Credly with certain information about yourself when you sign up for their service or use it.

When creating a new account in the Platform, you will receive a digital badge from Credly, you will receive a notification via email. The process will prompt you to connect your Credly account details with your Platform account, so that digital badges (credentials) issued via Credly can appear on your profile.

You will be required to share your personal information (such as name, email address) with Credly so that a digital badge (credential) can be issued to you after attending an activity. Credly will email you instructions on how to claim the digital badge.

It is important to note that Credly's services require you to sign up and create an account with them, and you will be required to agree to Credly's privacy policies and terms of use when you do so. For more information, please see Credly's privacy policy or contact privacy@credly.com. You can read Credly's privacy policy to learn how they handle the information you share with them. Credly's privacy policy also explains how data subject rights can be exercised.

Badge Nation

When a Digital Badge is issued to you from Credly, Badge Nation will have access to your personal data (name and email address) in relation to the badge issued via Credly’s Digital Badge Statistics.

Special Category data

When you join a community that requests your consent to provide special category data, Navigatr will collect and will share the special category data you provide with your community.

Community Providers

Navigatr will share personal and/or special category data with the Community providers. Community Providers may also share data with trusted partners as detailed below:

Region of Learning

By joining the Region of Learning Community, you consent to us collecting special category data about you. Navigatr will collect on behalf of and will share the special category data you provide with Cambridge City Council.

Cambridge City Council take all reasonable steps to ensure that our staff protect your personal and special category data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it. Our registered address is:

  • Cambridge City Council, Mandela House, 4 Regent Street, Cambridge, Cambridgeshire CB2 1BY.

The Council will ask for consent to share data with the following trusted partners:

Cambridgeshire Libraries (part of Cambridgeshire County Council)

If you opt to receive a smart library card that can be used in conjunction with the Platform as an alternative way to record your participation and trigger your digital badges, your personal data (name, email address, home address and date of birth) with Cambridgeshire Libraries and their management system Civica Spydus (operated as Civica UK Ltd).

8. What we will do with your information and how it is used

Navigatr will use the personal data we collect to provide, maintain, and improve Our Services, which includes publishing and distributing user-generated content and personalising the content you see. We will use your information in the following ways:

  • Create and maintain your Platform account on the Navigatr app
  • Respond to your questions and comments and provide customer service
  • Monitor and analyse trends, usage, and activities in connection with our Services;
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Navigatr and others
  • Debug to identify and repair errors in our services
  • Communicate with you in relation to the provision of the contracted products and services
  • Comply with our legal and financial obligations
  • Carry out any other purpose described to you at the time the information was collected.
  • Send you technical notices, security alerts, support and administrative messages

Send you content recommendations

Automated decision-making is the process of making a decision by automated means without any human involvement. These decisions can be based on factual data, as well as on digitally created profiles or inferred data. The Platform will automatically suggest content to you through notifications.

These notifications are based both on the interests provided during onboarding and the skills data present in your earned badges (badge assertions). For example, if you have selected in your preferences that you are interested in ‘coding’ and/or have earned a digital badge with the skill tag ‘coding’; you will be notified of upcoming activities near your location that include the tag ‘coding’.

Display content that is most relevant to you based on your interests and preferences

Profiling analyses aspects of an individual’s personality, behaviour, interests and habits to make predictions or decisions about them. The Platform displays content based on your location, interests and preference data, provided by you during the onboarding process, and digital badges contained in your profile. These preferences can be changed at any time from your account settings page.

This doesn't hide or limit access to any content within the library and is purely to help an individual see the information most relevant to you, based on your preferences.

Cookies

Navigatr uses Cookies in line with our Cookie Policy. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications preferences

You may opt out of receiving certain communications from us or Community Providers, such as newsletters, and notifications, by following the instructions in those communications or through your account’s Settings page.

If you opt out, Navigatr may still send you administrative emails, such as those about your account or our ongoing business relations.

In addition, the following organisations have additional ways of using your information:

Credly

Our digital badge (credential) partner and provider Credly uses and, where specified, shares your information in the following ways:

Credly may use your information to display digital badges (credentials). Credly may use your information to display Credentials that you receive through the Service or through Third-Party Services on the Credly website or on third-party websites or applications that you choose to share your personal information.

Credly may notify you of relevant opportunities and use your information to improve quality and facilitate the use of the Service.

Credly may use third-party service providers to operate the Service. These service providers are required to implement appropriate privacy and security measures to safeguard against the unauthorised use or disclosure of your information.

Credly may disclose information about you to comply with legal requirements, or when they believe that disclosure is reasonably necessary to enforce their rights.

Credly’s privacy policy is located at https://info.credly.com/privacy-policy and will apply to Credly’s processing of your personal data. Credly stores your personal data in the United States of America.

Communities

Our Community organisations will use information in the following ways:

Region of Learning

Offer you an integrated smart library card to use alongside the Platform

If you opt to receive a smart library card that can be used in conjunction with your app, your personal data including name, email address, address, date of birth will be shared with Cambridgeshire Libraries to create your smart card and library user account. If you opt to register as a member and receive a smart library card, Cambridgeshire Libraries will: * Use the information you provide to offer you the card and offer their library service to you, issue you with a unique account, maintain records of items that are issued to you and returned, as well as contacting you in relation to this when required. Their legal basis for using your information in this way is provided by the Public Libraries and Museums Act 1964, which requires them to provide a comprehensive and efficient library service. * Offer your library membership and ask you to accept and read their Condition of Memberships. Adult guarantors may complete this registration on behalf of children under the age of 16. * Ask you to agree to share your details with all institutions in the library network in order to join online. You understand your details will not be disclosed to organisations outside their network without your consent. * Ask you to consent to the Privacy Policy of Cambridgeshire Libraries when they collect and use information about you. * Hold details of you when you sign-up and use their library services, as well as details of your use of services. * Use your information to provide a library service to you, to manage bookings of their facilities, and to contact you when required. * Their Library Service Privacy Notice explains how they treat the information you provide.

Credly (only applicable if you joined Navigatr before 1 February 2023):

Our digital badge (credential) partner and provider Credly uses and, where specified, shares your information in the following ways:

Credly may use your information to display digital badges (credentials). Credly may use your information to display Credentials that you receive through the Service or through Third-Party Services on the Credly website or on third-party websites or applications that you choose to share your personal information.

Credly may notify you of relevant opportunities and use your information to improve quality and facilitate the use of the Service.

Credly may use third-party service providers to operate the Service. These service providers are required to implement appropriate privacy and security measures to safeguard against the unauthorised use or disclosure of your information.

Credly may disclose information about you to comply with legal requirements, or when they believe that disclosure is reasonably necessary to enforce their rights.

Credly’s privacy policy is located at https://info.credly.com/privacy-policy and will apply to Credly’s processing of your personal data. Credly stores your personal data in the United States of America.

9. How long we will keep your information

Navigatr will retain your personal data as long as we provide the Navigatr services in order to maintain the integrity of your digital credentials. We store personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

This includes the hosting of metadata on the Platform provided by Navigatr that ensures links from your digital credentials still function when shared (by you) with third party websites, like your social media accounts.

If you request deletion of your information, your personal account data will be deleted within 30 days of your request.

Navigatr will retain personal data for as long as needed for the purposes for which it was collected or as long as your account remains active.

Communities

In addition, the following Community providers or their partners will retain information and will share data with the following partners:

Region of Learning

Cambridge City Council will share your information with the following partners, who have the following data retention policies:

Cambridgeshire Libraries

Cambridgeshire Libraries only keep information for as long as it is needed and in library services this varies between one and six years depending on the specific details. This is set out in their retention schedule, and their Library Service Privacy Notice explains how they handle the information you provide.

Navigatr will notify Cambridge City Council if you request deletion of your information, and the Council will notify Cambridgeshire Libraries and your account data will be deleted within 14 days.

Cambridge City Council

Navigatr will notify Cambridge City Council about your request if you request deletion of your information and your personal data (as well as any stored special category data) will be deleted within 14 days.

Credly

Credly may retain your personal information for as long as your account is active and so long as retention is required or permitted in accordance with their Privacy Policy, or otherwise by law. When Credly deletes your personal information, Credly will do so in a manner designed to ensure that it cannot be reconstructed. Credly’s privacy policy is located at https://info.credly.com/privacy-policy and will apply to Credly’s processing of your personal data.

Region of Learning

Only applicable if you joined Navigatr before 1 February 2023:

Cambridge City Council would share your information with Credly who may retain your personal information for as long as your account is active and so long as retention is required or permitted in accordance with their Privacy Policy, or otherwise by law. When Credly deletes your personal information, Credly will do so in a manner designed to ensure that it cannot be reconstructed. Credly’s privacy policy is located at https://info.credly.com/privacy-policy and will apply to Credly’s processing of your personal data.

Badge Nation

Badge Nation will keep your data for as long as is necessary for the purpose for which it was collected.

Badge Nation will delete the data of anyone who hasn't claimed their badges after 6 months.

Badge Nation will keep your personal information for as long as they need to in order to comply with their legal and regulatory requirements.

Badge Nation will not keep more information than they need.

Badge Nation’s privacy notice is located at: https://realideas.org/policies/

Navigatr requires your consent to share your personal data.

With your consent, your data is shared for the purpose of delivering a contract for example, a Community Provider who is a data controller.

Navigatr takes all reasonable steps to ensure that our operations and employees are compliant with security obligations in relation to the confidentiality, security, and lawful processing of any special category data shared with third parties.

Region of Learning

Cambridge City Council require your consent to share your personal data and special category data. Navigatr collect your data on our behalf.

11. Your data protection rights

Under the General Data Protection Regulation (GDPR), you have the following rights:

Right to access

You have the right to request a copy of the personal data that we hold about you by contacting Navigatr at the email or postal address given below. Please provide proof of identity. Navigatr will respond within 30 days of request.

Region of Learning

If you have a query regarding your rights, please contact their Data Protection Officer by emailing infogov@3csharedservices.org or you can write to them and mark your letter for the attention of the Data Protection Officer and address it to Cambridge City Council, Mandela House, 4 Regent Street, Cambridge, Cambridgeshire CB2 1BY.

If you have signed up for a Navigatr account, you may at any time request an export of your personal information from the Settings page, or by going to Settings and then selecting Account within our app.

Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information. Or if your request is manifestly unfounded or excessive. For more information, you may refer to the Information Commissioner’s Office (ICO)’s webpage located here.

Right to rectification

Navigatr aims to keep your personal data accurate and complete. You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

You may also correct information associated with your account from the Settings page, or by going to Settings and then selecting Account within our app, and the Your Interests section to update your interests.

Right to erasure

You have the right to request the deletion of your personal data where, for example, the personal or special category data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed.

You may withdraw consent by deleting your account at any time through the Settings page. Please note that if you choose to delete your account, Navigatr may continue to retain your email address, first name, surname for our legitimate business purposes.

Right to object to processing

In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. You may object at any time to the use of your personal data by contacting gdpr@navigatr.app

Right to restrict processing

In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have queried the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted.

Right to data portability

In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means.

Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.

You are not required to pay any charge for exercising your rights. If you make a request, Navigatr has 30 days to respond to you. Please contact us using the details provided below.

Raising a complaint

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint with the applicable supervisory authority or to seek a remedy through the courts. Please visit https://ico.org.uk/concerns/ for more information on how to report a concern to the UK Information Commissioner’s Office.

Communities

Where you are a member of a Community who shares data with their partners, Navigatr has the responsibility to contact the relevant Community Provider and share your data protection rights request on your behalf. The Community Provider will be responsible for ensuring your data rights are actioned by relevant partners.

Region of Learning

If you have a query regarding your rights, or if you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, please contact their Data Protection Officer by emailing infogov@3csharedservices.org or you can write to them and mark your letter for the attention of the Data Protection Officer and address it to Cambridge City Council, Mandela House, 4 Regent Street, Cambridge, Cambridgeshire CB2 1BY.

12. Our contact details

To exercise any of your data protection rights, or if you have a query about this Policy, please email Navigatr at gdpr@navigatr.app or write to Data Protection, Navigatr, Castleton Mill, Castleton Close, Leeds, West Yorkshire, LS12 2DS

Region of Learning

Cambridge City Council leads the Region of Learning Community. If you have a query regarding your rights, please contact their Data Protection Officer by emailing infogov@3csharedservices.org or you can write to them and mark your letter for the attention of the Data Protection Officer and address it to Cambridge City Council, Mandela House, 4 Regent Street, Cambridge, Cambridgeshire CB2 1BY.