RM Technology and HP work together to create brighter futures for students, teachers and the environment.

HP Brighter Futures 2026 | Terms & Conditions

1. Definitions & Interpretation:

“Approved Distribution Partner” means a distribution partner authorised by the manufacturer to supply products to RM Technology.

“Business Day” means a day other than a Saturday, Sunday or public holiday in Scotland or England.

“Claim” means a Claim submitted by a Customer in accordance with these Terms to receive a Reward in respect of a Qualifying Product and (where applicable) a Trade-In Device.

“Customer” means an Eligible Customer (and “you” and “your” shall be construed accordingly).

“Eligible Customer” means a school, college or academy trust located in England, Wales, Scotland or Northern Ireland.

“ITAD” means Circular IT Group (or any successor appointed by the Promoter), being the IT asset disposition provider responsible for arranging collection, receipt and assessment of Trade-In Devices.

“Payit” means the secure payment link and payment processing service operated by NatWest through which Rewards are paid.

“Programme Sponsor” means HP Inc UK Limited, a company registered in England under company number 09408979 with the registered address being Earley West, 300 Thames Valley Park Drive, Reading, United Kingdom, RG6 1PT; including any of its group companies involved in sponsoring or supporting the Programme.

“Promoter” means Consenna Limited, a company registered in Scotland under company number SC357063 with the registered address being Unit C, Brown Egg Farm, Inchinnan, Renfrewshire, United Kingdom, PA4 9LS

“Promotional Period” means 00:01 on 1 March 2026 until 23:59 on 28 February 2027.

“Qualifying Product” means a product listed on the Qualifying Products page at the time of purchase, which is purchased directly from RM Technology and sourced by RM Technology from an Approved Distribution Partner.

“Qualifying Products page” means the page (or pages) made available by RM Technology identifying the products eligible for the Promotion and the applicable Reward value for each such product, as updated from time to time.

“Reward” means the incentive payable under the Promotion in respect of an approved Claim, being either the Standard Reward Value (cashback) or, where available and selected, the Reward Hub Reward Value, subject to these Terms.

“Standard Reward Value” means the applicable cashback Reward value per approved Trade-In Device for the relevant Qualifying Product, as stated on the Qualifying Products page at the time of purchase, being either one hundred pounds sterling (£100) or fifty pounds sterling (£50), as applicable.

“Reward Hub” means the Brighter Futures Reward Hub environment through which Reward Hub credit may be applied towards eligible goods and services.

“Reward Hub Claim” means a Claim submitted through the Reward Hub dashboard in accordance with clause 10 to apply Reward Hub credit towards an eligible invoice.

“Reward Hub Qualifying Product” means a product or service designated as eligible within the Reward Hub at the time of purchase.

“Reward Hub Reward Value” means the Standard Reward Value plus a flat uplift of twenty-five pounds sterling (£25) per approved Trade-In Device, available only where the Reward Hub option is offered and selected. Accordingly, where the Standard Reward Value is one hundred pounds sterling (£100), the Reward Hub Reward Value shall be one hundred and twenty-five pounds sterling (£125), and where the Standard Reward Value is fifty pounds sterling (£50), the Reward Hub Reward Value shall be seventy-five pounds sterling (£75).

“Trade-In Device” means an eligible desktop or laptop computer or Microsoft Surface device submitted by the Customer for assessment in connection with the Promotion.

“URN” means the Unique Reference Number of an educational establishment (or such other identifier as the Promoter may reasonably require).

Headings are for convenience only and do not affect interpretation. References to legislation include amendments and re-enactments. Where a time period is expressed in days, it means calendar days unless expressly stated as Business Days.

2. The Promotion

The Promotion enables Eligible Customers who purchase Qualifying Products during the Promotional Period and meet all requirements in these Terms to receive a Reward, subject to the submission and approval of a Claim and (where applicable) the successful trade-in of eligible Trade-In Devices.

3. Registration and Eligibility

Participation is conditional upon the Customer registering an account on the Promotion platform and providing complete, accurate and up-to-date information, including a valid finance or business manager contact. Payment links will be issued to one nominated contact only, and it is the Customer’s responsibility to ensure that the nominated contact is able to complete the Payit process within the applicable time limits.

By registering and/or submitting a Claim, the individual doing so warrants and represents that they are aged eighteen (18) years or over and have full authority to act on behalf of and legally bind the Customer.

By registering and/or submitting a Claim, the Customer warrants and represents that:

(a) it is an Eligible Customer;

(b) it complies with these Terms;

(c) all information provided is true, accurate, complete and not misleading;

(d) participation does not breach any applicable law or regulation; and

(e) it will comply with all deadlines and process requirements stated in these Terms.

4. Purchase Requirements and Qualifying Products

To be eligible, the Customer must purchase one or more Qualifying Products directly from RM Technology during the Promotional Period. RM Technology must have sourced the Qualifying Products from Approved Distribution Partners.

Qualifying Products must be purchased for the Customer’s own internal educational use only. Claims relating to products purchased for resale, hire, rental, leasing, managed services, onward supply to third parties, or any other commercial onward use are ineligible and will be rejected.

The Customer is responsible for confirming that a product is a Qualifying Product by reference to the Qualifying Products page at the time of purchase.

Return of any Qualifying Product to RM Technology (or cancellation/credit of the relevant invoice) following submission of a Claim will disentitle the Customer to the Reward. In such circumstances, no Reward may be Claimed and any Reward already paid must be repaid to the Promoter on demand. If repayment is not made, the Promoter may deduct the relevant amount from any future Rewards otherwise payable to the Customer.

5. Claim Submission and Supporting Documents

Claims must be submitted within thirty (30) calendar days of the invoice date stated on the invoice issued by RM Technology for the relevant Qualifying Product. Claims submitted outside this period will be rejected and cannot be reopened.

Each Claim must include all information and supporting documents required on the platform, including a valid invoice clearly showing Customer details, invoice date, invoice number, product description(s), quantities and the reseller details. Incomplete Claims and/or incomplete supporting documentation will be rejected.

Each Claim (including Claims submitted by an academy trust) must be linked to an individual educational establishment and include a valid URN (or such identifier as the Promoter may reasonably require).

6. Claim Caps and One-for-One Requirement

During the Promotional Period, the maximum number of Trade-In Devices that may be Claimed is:

(a) 250 per school;

(b) 400 per college;

(c) 1,000 per academy trust.

The Promoter may reject any Claim (in whole or in part) that would cause these caps to be exceeded.

Only one (1) Trade-In Device may be submitted for each Qualifying Product purchased and Claimed. Claims that do not comply with this one-for-one requirement will be rejected.

7. Claim Review, Approval or Rejection

Newly submitted Claims will be reviewed by the Promoter within five (5) Business Days of submission.  Where additional information or clarification is required, the Claim may be placed into query status and the Customer will be notified by email.  The Customer must provide the requested information within seven (7) calendar days of notification. If the requested information is not received within this period, the Claim may be rejected and treated as expired. Rejected or expired Claims cannot be reopened.  If a Claim meets the eligibility criteria, it will be approved and processed further in accordance with these Terms. If a Claim is ineligible, it will be rejected.

For Claims submitted between 13 July 2026 and 6 September 2026 (inclusive), the Promoter will operate the following temporary summer holiday claims process in place of the standard claim review process described above.

The purpose of this temporary process is to ensure that Eligible Customers are not disadvantaged by school closures during the summer holiday period. By temporarily delaying the commencement of claim processing, the Promoter will ensure that Customers receive the same opportunity to complete Trade-In Device collections and, where applicable, redeem payment links within the standard Programme timeframes as they would at any other time of the year.

Accordingly:

(a) newly submitted Claims received between 13 July 2026 and 6 September 2026 will be placed on temporary hold prior to entering the standard claim review process;

(b) the standard claim review process for these Claims will commence during the week beginning 7 September 2026;

(c) the applicable collection period for Trade-In Devices, together with all subsequent Programme timeframes under these Terms, including payment processing and Payit payment link validity, will commence only once the Claim has entered the standard claims process and will not be reduced as a result of the temporary summer holiday hold;

(d) Customers who have appropriate staff available to administer their Claim and Trade-In Device collection during the school holiday period may request that their Claim proceeds immediately. Upon such request, the Promoter will remove the temporary hold and process the Claim in accordance with the standard Programme timescales;

(e) where a Customer elects to proceed with immediate processing under clause (d), the Claim will be subject to all standard Programme timeframes set out in these Terms. No additional extensions, exceptions, suspensions or discretionary allowances will be granted in respect of claim review, Trade-In Device collection, payment processing, Payit payment links or any other Programme deadlines on the basis of school holiday closures.

The temporary summer holiday claims process applies only to Claims submitted during the period specified above. From the week commencing 7 September 2026, all newly submitted Claims will be processed in accordance with the standard provisions of these Terms.

8. Reward Options and Election

For each approved Trade-In Device, the Customer may receive a Reward. The Customer must select the Reward option at the point of Claim submission, and the selection is final and cannot be changed after submission.

The Standard Reward Value is the applicable cashback Reward value per approved Trade-In Device for the relevant Qualifying Product, as stated on the Qualifying Products page at the time of purchase, being either £100 or £50, as applicable.

Where the Reward Hub option is offered and selected, the Reward Hub Reward Value shall be the applicable Standard Reward Value plus a flat uplift of twenty-five pounds sterling (£25) per approved Trade-In Device. Accordingly, this will be £125 where the applicable Standard Reward Value is £100, and £75 where the applicable Standard Reward Value is £50. The uplift element is available only through the Reward Hub mechanics and is not payable as cashback except as expressly provided under clause 11 (Expiry and Conversion).

9. Trade-In Devices and Trade-In Process

Trade-In Devices must be desktop or laptop computers or Microsoft Surface device that are complete, power on, are in full working order and are no more than eight (8) years old. The appropriate power adapter must be included.

Trade-In Devices must be owned outright by the Customer and must have been owned by the Customer since original purchase. There must be no outstanding finance, lease, hire purchase, rental arrangement or third-party interest of any kind in respect of the Trade-In Devices.

The Promoter reserves the right to request evidence of ownership and to reject any Claim where it is not satisfied that the Customer is the lawful owner.

Thin clients, tablets, displays, password-protected devices and BIOS-locked devices do not qualify.

The Customer is solely responsible for:

(a) cancelling any contracts or subscriptions relating to the Trade-In Devices;

(b) deregistering and unlinking the Trade-In Devices from any MDM, provisioning or security systems (including without limitation Microsoft Intune, Autopilot or similar platforms);

(c) permanently removing all data and information from the Trade-In Devices;

(d) retaining any backups required by the Customer. Neither the Promoter nor the ITAD shall be responsible for any loss or damage to data arising from any failure to comply with these obligations.

There is no revaluation under this Promotion. Where a Trade-In Device does not meet the eligibility requirements, the Claim (or the affected part of the Claim) will be treated as invalid in accordance with clause 9.8.

Following Claim approval, the Claim will be passed to the ITAD. The ITAD will contact the Customer within four (4) Business Days of receiving notification of the approved Claim to arrange collection.

Collections of Trade-In Devices must be arranged directly with the ITAD and collection dates must occur within sixty (60) calendar days of the ITAD contacting the Customer. If a scheduled collection is missed or fails due to Customer fault or unavailability, the Claim will be deemed ineligible for further processing. A secondary collection may be requested; any additional costs associated with a second (or subsequent) collection attempt must be paid by the Customer.

Following collection and receipt at the ITAD facility, the ITAD will assess the Trade-In Devices against the eligibility criteria. This assessment process may take up to thirty (30) calendar days.

If, following assessment, a Trade-In Device is determined not to meet the eligibility requirements (including where an incorrect device has been submitted in error), the Customer will be notified. In such circumstances, the Customer may, within seven (7) calendar days of notification, elect either: (a) return of the non-qualifying device at the Customer’s sole cost and risk; or (b) recycling free of charge. If the Customer does not provide an instruction within the seven (7) day period, the device will be recycled free of charge. No Reward is payable for non-qualifying devices and any associated Reward entitlement is forfeited.

Title to and ownership of Trade-In Devices does not transfer at the point of physical collection. Ownership transfers irrevocably to the ITAD only once the ITAD has confirmed that the Trade-In Devices meet the eligibility criteria and are accepted for processing. Once accepted, Trade-In Devices cannot be returned under any circumstances.

10. Reward Hub Mechanics

Where the Customer selects the Reward Hub option, the Reward Hub Reward Value will be recorded as a credit balance in the Customer’s Reward Hub account following approval of the underlying Claim.

To apply (“consume”) Reward Hub credit, the Customer must purchase one or more Reward Hub Qualifying Products from the same RM Technology entity through which the Qualifying Product associated with the approved Claim was purchased (the “Originating Reseller”). Purchases from any other supplier, reseller or third party are not eligible for reimbursement through the Reward Hub.

Following purchase of a Reward Hub Qualifying Product from the Originating Reseller, the Customer shall submit a Reward Hub Claim through the Reward Hub dashboard and upload the relevant invoice together with any required supporting documentation. All Reward Hub Claims must be submitted within thirty (30) calendar days of the invoice date.

An invoice dated more than thirty (30) calendar days prior to the date of submission shall only be accepted where the eligible Reward Hub products are included on the same invoice that was used to support the original trade-in claim. In all other circumstances, claims submitted outside the thirty (30) calendar day period shall be invalid and rejected.

Reward Hub Claims follow the same administrative review approach as standard Claims. The Promoter will review newly submitted Reward Hub Claims within five (5) Business Days. Ineligible Reward Hub Claims will be rejected and cannot be reopened.

11. Reward Hub Expiry and Cashback Conversion

Reward Hub credit must be consumed within ninety (90) calendar days of the date on which it is credited to the Customer’s Reward Hub account.

If the Reward Hub credit has not been consumed in any part during the ninety (90) day period, then at the end of that period the Reward will be converted and paid as cashback at the applicable Standard Reward Value for the relevant approved Claim only (and any uplift will be forfeited), provided that the value eligible for conversion exceeds ten pounds sterling (£10). Where the value eligible for conversion is equal to or less than ten pounds sterling (£10), such value shall expire automatically, and no cashback payment shall be made.

If the Reward Hub credit has been partially used during the ninety (90) day period, any remaining unused balance at expiry will be converted on a pro rata basis to the equivalent proportion of the applicable Standard Reward Value for the relevant approved Claim and paid as cashback. Any uplift element associated with the unused portion will be forfeited. Where the remaining unused balance is equal to or less than ten pounds sterling (£10), such balance shall expire automatically, and no cashback payment shall be made.

If the Reward Hub credit has been fully utilised within the ninety (90) day period, no cashback will be payable in respect of that credit.

For the avoidance of doubt, no extensions, grace periods, deferrals or discretionary allowances will be granted in respect of Reward Hub credit, whether partially used or unused, and any expiry of Reward Hub credit is final. For the avoidance of doubt, any invoice issued by RM Technology or any other supplier in connection with goods or services purchased using or intended to be reimbursed through the Reward Hub is issued directly to the Customer and remains payable by the Customer in full in accordance with the supplier’s standard payment terms. The Promoter does not purchase goods or services on behalf of the Customer, does not assume responsibility for payment of any supplier invoice, and does not guarantee that Reward Hub credit will be sufficient, available, approved, converted or paid in time to meet any invoice due date.

The Customer remains solely responsible for settling all supplier invoices irrespective of the status, availability, expiry, partial use, conversion or forfeiture of any Reward Hub credit. The Promoter shall have no liability to the Customer or to any supplier where Reward Hub credit expires, is not consumed, is partially consumed, is insufficient to cover an invoice value, or is converted or forfeited in accordance with these Terms.

12. Payment of Rewards via Payit

Rewards are issued to the Customer via a secure Payit payment link (operated by NatWest). Upon validation and approval of the applicable Reward entitlement, the Customer will receive a secure Payit link through which it may either link a bank account to receive payment or manually enter bank details within the Payit portal.

For cashback Rewards arising from Trade-In Device approval, the Promoter will issue the Payit link within twenty-one (21) Business Days of the ITAD confirming that the relevant Trade-In Devices are eligible and accepted.

For approved Reward Hub Claims, the Promoter will issue the Payit link within twenty-one (21) Business Days of approving the Reward Hub Claim.

The Customer must complete the Payit process and submit accurate and complete payment details within thirty (30) calendar days of the date and time the Payit link is issued, Payit links will always be issued to the designated finance contact stated on the claim as instructed by the customer. Payit links expire after thirty (30) calendar days and will not be reissued. Failure to complete the Payit process within this timeframe may result in disqualification from the Promotion and forfeiture of the Reward. Expired Claims cannot be reopened. Payit links cannot be re-issued, only one (1) Payit link can be generated for each claim.

The Promoter shall not be liable for any failure or delay in payment resulting from the Customer’s failure to provide accurate and complete payment details including eligible finance contacts or to complete the Payit process correctly and within the required timeframe.

All Rewards paid to the Customer are inclusive of VAT and the Customer is responsible for paying all tax due in connection with any Reward.

For clarity, payments made following approval of a Reward Hub Claim are made to the Customer (not to the Originating Reseller) to enable the Customer to settle the Originating Reseller invoice. The Customer remains solely responsible for paying the Originating Reseller invoice in accordance with its terms.

All communications relating to the Programme, including (without limitation) claim confirmations, query notifications, approval notices, ITAD collection correspondence and Payit payment links, will be sent to the email addresses provided by the Customer at the time of registration or claim submission.

The Customer is solely responsible for ensuring that all Programme-related email addresses, including support@brighterfuturesedu.com and, where applicable, payouts@email-services.natwestpayments.com, are added to approved sender lists and that inbox, junk and spam folders are regularly monitored.

The Promoter shall not be liable for any loss, delay, expiry or disqualification arising from non-receipt of emails or payment links where such communications have been correctly issued to the contact details provided.

For the purposes of the Programme, any email or payment link shall be deemed received at the time it is sent by the Promoter or its appointed payment provider.

Failure by the Customer to access, action or complete any communication within the applicable timeframes shall not extend or vary the deadlines set out in these Terms.

13. Audit

The Promoter reserves the right to audit any Claim and/or Reward Hub Claim to ensure compliance with these Terms, including the right to request additional information and supporting documents. Rewards will only be paid where the Promoter is satisfied that the requirements of the Promotion have been met. If a Claim is refused or invalidated on the grounds that these Terms have not been met, the Promoter’s decision is final and binding.

14. Incomplete Claims and Technical Failures

The Promoter reserves the right to disqualify incomplete Claims and/or Reward Hub Claims. No responsibility will be accepted for Claims that are incomplete, lost, late, not properly submitted, or where Trade-In Devices are received late, collections are missed, or devices do not meet the requirements of the Promotion.

The Promoter is not responsible for, and shall not be liable for, any technical, hardware, software, server, network or website failure to the extent it prevents or delays a Customer from participating in the Promotion or Claiming a Reward.

15. Fraud, Misleading Claims and Recovery

Submission of false, incomplete, misleading or fraudulent information or documentation may result in disqualification from the Promotion (and any future promotions) and may result in legal action. In the event of any overpayment or incorrect payment, the Customer shall repay such sums within seven (7) calendar days of a written request from the Promoter and shall indemnify the Promoter for any costs, losses, expenses or tax liabilities incurred in connection with the overpayment and/or recovery.

16. Modification, Suspension or Termination

The Promoter reserves the right to withdraw, amend, suspend or terminate the Promotion and/or these Terms. The Promoter will endeavour to provide fourteen (14) days’ notice of material changes or termination where reasonably practicable. However, the Promoter may modify, suspend or terminate the Promotion immediately where required by law or due to unforeseen circumstances or other good reason in the Promoter’s sole discretion. Amended Terms will apply from the time they are posted or otherwise communicated.

17. Privacy and Data Protection

In order to administer the Promotion and process Claims, the Promoter will collect and process personal data relating to the Customer, including the name and address of the participating educational establishment and the name and contact details of authorised representatives (including finance or business manager contact details).

Personal data will be shared with the Promoter’s subcontractors and service providers, including the ITAD and, where applicable, the Promoter’s appointed recycler (Circle IT Group), solely for the purposes of administering the Promotion and processing Claims.

The Promoter is the controller of the personal data provided and will process such data in accordance with its privacy policy Privacy Policy and applicable data protection law. By participating in the Promotion, the Customer consents to such processing and sharing. The lawful basis for processing and sharing is performance of a contract and the Promoter’s legitimate interests in administering the Promotion.

18. Limitation of Liability

The Promoter’s responsibility is to pay Rewards in respect of eligible Claims that comply with these Terms. The Promoter’s liability to the Customer is limited to the amount of any valid Reward payable.

Neither the Promoter nor its subcontractors shall be liable for any loss, damage or injury of any nature arising from or in connection with the Promotion or any Trade-In Device, except where such liability cannot be excluded by law, including liability for death or personal injury caused by negligence.

The Promoter accepts no responsibility for loss of data or information contained on a Trade-In Device. Deletion and backup of all data is the Customer’s responsibility.

19. Governing Law and Jurisdiction

These Terms and any dispute or Claim arising out of or in connection with them shall be governed by and construed in accordance with the laws of England and Wales, and the courts of England and Wales shall have exclusive jurisdiction.

 HP Brighter Futures 2026 | Privacy Policy 

Introduction: 

Welcome to Consenna Limited’s privacy policy for the HP Brighter Futures Programme 2026 (the “Programme”). 

We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we collect, use, store and protect your personal data when you: 

• visit and use the HP Brighter Futures Programme website and any associated partner or reseller claim pages (together, the “Platform”); 

• register for an account; 

• submit a Claim (including a Reward Hub Claim); 

• correspond with us; or 

• otherwise participate in or engage with the Programme. 

It also explains your privacy rights and how the law protects you. 

This privacy policy should be read together with the Programme Terms & Conditions and any other privacy notice provided at the point we collect your personal data. It supplements those notices and is not intended to override them. 

Controller: 

For the purposes of the Programme, Consenna Limited is the data controller and is responsible for your personal data (referred to in this privacy policy as “Consenna”, “we”, “us” or “our”). 

Consenna Limited 

Company number: SC357063 

Registered office: India Of Inchinnan, Greenock Road, Inchinnan, Renfrew, Renfrewshire, United Kingdom, PA4 9LH 

Consenna acts as Programme manager and claims administrator and determines the purposes and means of processing personal data collected in connection with the Programme. 

Where personal data is provided directly to third parties (for example, payment service providers or IT asset disposition providers), those organisations may act as independent controllers in respect of the personal data they collect and process. Their use of your personal data will be governed by their own privacy policies. 

If you have any questions about this privacy policy or how we handle your personal data, please contact us using the details below: 

Email: support@brighterfuturesedu.com 

Address: India Of Inchinnan, Greenock Road, Inchinnan, Renfrew, Renfrewshire, United Kingdom, PA4 9LH 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you raise with the ICO 

Changes to this Privacy Policy: 

We keep this privacy policy under regular review and may update it from time to time. 

Where we make material changes, we will post the updated version on the Programme Platform and update the “Last updated” date at the top of this policy. Where appropriate, we may also notify registered users by email. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or during your participation in the Programme. 

The data we collect about you: 

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

In connection with the Programme, we may collect, use, store and transfer different kinds of personal data, which we have grouped as follows: 

Identity Data 

Includes first name, last name, title, job role and organisation details (for example, school, college or academy trust name). 

Contact Data 

Includes business email address, telephone number, billing address and establishment address. 

Financial Data 

Includes bank account details provided through the Payit payment process for the purpose of issuing Rewards.  We do not store full bank account details directly where payment is processed via our appointed payment service provider; such details are entered into and processed within the secure Payit environment. 

Transaction Data 

Includes details relating to: 

• Qualifying Product purchases; 

• Claims submitted; 

• Trade-In Devices submitted for assessment; 

• Reward selections (Standard cashback or Reward Hub option); 

• Reward Hub usage; 

• payment status and Reward history. 

Technical Data 

Includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices used to access the Platform. 

Profile Data 

Includes your Platform username and password, Claim history, Reward history, correspondence records, and preferences. 

Usage Data 

Includes information about how you use the Platform and interact with Programme features. 

Marketing and Communications Data 

Includes your preferences in receiving communications from us and records of correspondence. 

Special Categories of Personal Data 

We do not collect any special categories of personal data (such as data relating to race, religion, health, or biometric data) in connection with the Programme. We also do not intentionally collect data relating to criminal convictions or offences. 

How we process your personal data: 

We will only process personal data where permitted under UK GDPR. 

We rely on the following lawful bases: 

• Performance of a contract – administering your participation in the Programme 

• Legitimate interests – fraud prevention, audit, programme governance and recovery of overpayments 

• Legal obligation – accounting, tax and regulatory compliance 

How your personal data is collected: 

We use different methods to collect data from and about you, including: 

(a) Direct interactions 

You may give us your personal data by filling in forms, registering an account, submitting a Claim, uploading supporting documentation, corresponding with us by email, or otherwise communicating with us. 

This includes personal data you provide when you: 

• register for the Programme on behalf of an eligible educational establishment; 

• submit a Claim (including a Reward Hub Claim); 

• upload invoices and supporting documentation; 

• correspond with us regarding Claim queries; 

• arrange Trade-In Device collections; 

• complete the Payit payment process; or 

• request support or provide feedback. 

Where a Claim is submitted by a reseller or partner on behalf of a Customer, we may receive your personal data from that reseller or partner. 

(b) Automated technologies or interactions 

As you interact with the Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. 

We collect this data using cookies, server logs and similar technologies. Please refer to our Cookie Policy {{INSERT LINK}} for further details. 

(c) Third parties 

We may receive personal data about you from third parties involved in administering the Programme, including: 

• the relevant reseller or partner through whom Qualifying Products were purchased; 

• the appointed IT asset disposition provider responsible for Trade-In Device collection and assessment; 

• our appointed payment service provider (Payit operated by NatWest); 

• the Programme Sponsor for governance and reporting purposes where required. 

Where personal data is collected directly by those third parties, their processing will be governed by their own privacy policies. 

How we use your personal data: 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

Performance of a contract – where we need to perform the Programme Terms & Conditions or take steps at your request before entering into a contract. 

Legitimate interests – where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 

Legal obligation – where we need to comply with a legal or regulatory obligation. 

We do not generally rely on consent as a legal basis for processing personal data in connection with administering the Programme. However, where we send marketing communications outside the core administration of the Programme, we will rely on consent where required by law. 

Purposes for which we use your personal data: 

We use your personal data for the following purposes: 

(a) To register you as a Programme participant 

Types of data: Identity Data, Contact Data 

Lawful basis: Performance of a contract 

This includes creating and managing your Platform account. 

(b) To administer Claims and Reward Hub Claims 

Types of data: Identity Data, Contact Data, Transaction Data, Financial Data 

Lawful basis:  

• Performance of a contract 

• Legitimate interests (to administer and operate the Programme effectively) 

This includes: 

• assessing eligibility to participate in the Programme; 

• validating supporting documentation; 

• arranging Trade-In Device collection and assessment; 

• managing Claim queries; 

• recording Reward selections (Standard cashback or Reward Hub option); 

• processing cashback payments via Payit; 

• maintaining records of Rewards issued. 

For clarity, the Reward Hub mechanism is an alternative reward administration pathway under the Programme. It does not constitute a separate financial product or regulated financial service. Where cashback is ultimately paid, it is processed via the same secure Payit payment route as Standard Rewards. 

(c) To arrange Trade-In Device collection and assessment 

Types of data: Identity Data, Contact Data, Transaction Data 

Lawful basis: Performance of a contract 

This includes sharing necessary details with our appointed IT asset disposition provider to coordinate collection and assessment. 

(d) To process Reward payments 

Types of data: Identity Data, Contact Data, Financial Data, Transaction Data 

Lawful basis: Performance of a contract 

This includes issuing secure Payit payment links and processing cashback payments. 

We do not store full bank account details where these are entered directly into the secure Payit portal operated by our appointed payment provider. 

(e) To manage our relationship with you 

Types of data: Identity Data, Contact Data, Profile Data, Communications Data 

Lawful basis: 

• Performance of a contract 

• Legal obligation 

• Legitimate interests (to maintain accurate records and administer the Programme) 

This includes: 

• notifying you of changes to Programme Terms or this privacy policy; 

• responding to queries or complaints; 

• conducting compliance checks or audits. 

(f) To administer and protect the Platform 

Types of data: Identity Data, Contact Data, Technical Data, Usage Data 

Lawful basis: Legitimate interests 

This includes: 

• troubleshooting; 

• system administration; 

• data analysis; 

• testing; 

• network security; 

• fraud prevention; 

• business continuity and system integrity. 

(g) To comply with legal and regulatory requirements 

Types of data: Identity Data, Contact Data, Transaction Data 

Lawful basis: Legal obligation 

This includes compliance with tax, audit, fraud prevention, anti-bribery and other regulatory obligations. 

Change of purpose: 

We will only use your personal data for the purposes for which we collected it. If we consider that we need to use your personal data for a different purpose, we will assess whether that purpose is compatible with the original purpose for which the data was collected. 

Where the new purpose is compatible, we may process your personal data on that basis. Where the new purpose is not compatible, we will only process your personal data if we are permitted or required to do so by law, or where we have another lawful basis for doing so. 

If we need to use your personal data for a materially different and unrelated purpose, we will notify you and explain the legal basis that allows us to do so, where required. 

Disclosure of your personal data: 

We may share your personal data with selected third parties where necessary to administer and operate the Programme. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit third parties to process your personal data for specified purposes and in accordance with our instructions, unless they act as independent data controllers. 

(a) Service Providers 

We may share personal data with third-party service providers who support the administration of the Programme, including: 

• IT asset disposition provider (ITAD) responsible for arranging collection, receipt and assessment of Trade-In Devices; 

• Payment service provider (Payit operated by NatWest) for issuing secure payment links and processing cashback payments; 

• Technology providers hosting or supporting the Platform; 

• Professional advisers including legal, audit or compliance advisers where required. 

Where these providers process personal data on our behalf, they act as data processors and are contractually required to implement appropriate security measures. 

(b) Independent Controllers 

Certain third parties may act as independent data controllers in relation to personal data you provide directly to them. This may include: 

• The payment provider in relation to bank details entered into the secure Payit environment; 

• The ITAD in relation to device handling and processing activities; 

• The Programme Sponsor where limited reporting or audit data is required for governance purposes. 

Their processing of personal data is governed by their own privacy policies. 

(c) Legal and Regulatory Disclosures 

We may disclose personal data where required to do so by law or where necessary to: 

• comply with legal obligations; 

• respond to lawful requests from public authorities; 

• enforce Programme Terms; 

• prevent fraud or abuse; 

• protect our rights, property or safety, or that of others. 

International transfers: 

We primarily store and process your personal data within the United Kingdom. 

Where it is necessary to transfer your personal data outside the UK, we will ensure that appropriate safeguards are in place to protect it in accordance with applicable data protection law. 

These safeguards may include: 

• transferring personal data to countries that have been deemed to provide an adequate level of protection by the UK Government; 

• using approved standard contractual clauses or international data transfer agreements; or 

• relying on another lawful transfer mechanism permitted under UK data protection legislation. 

You may contact us if you would like further information about the specific safeguards used in relation to any international transfer of your personal data. 

Data security: 

We have implemented appropriate technical and organisational security measures designed to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

These measures include, where appropriate: 

• secure hosting environments; 

• restricted access controls; 

• encrypted data transmission; 

• role-based access to Programme systems; 

• contractual confidentiality obligations for staff and service providers. 

Access to your personal data is limited to employees, agents, contractors and third parties who have a legitimate business need to know. They will only process your personal data on our instructions (where acting as processors) and are subject to a duty of confidentiality. 

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator where we are legally required to do so. 

Data retention: 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of administering the Programme and satisfying any legal, regulatory, tax, accounting or reporting requirements. 

In general: 

• Account and Claim records will be retained for the duration of the Programme and for a reasonable period afterwards to enable audit, compliance and dispute resolution. 

• Payment and financial transaction records will be retained in accordance with applicable financial and tax record-keeping requirements. 

• Technical and usage data may be retained for system security, fraud prevention and performance monitoring purposes. 

We may retain personal data for a longer period where: 

• there is an ongoing complaint or dispute; 

• we reasonably believe there is a prospect of litigation; 

• we are required to do so by law or regulatory obligation. 

When determining the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and applicable legal requirements. 

When personal data is no longer required, it will be securely deleted or anonymised. 

Your legal rights: 

Under UK data protection law, you have certain rights in relation to your personal data. 

You have the right to: 

Request access 

Request access to the personal data we hold about you (commonly known as a “data subject access request”). This enables you to receive a copy of your personal data and to check that we are lawfully processing it. 

Request correction 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data corrected, although we may need to verify the accuracy of the new information you provide. 

Request erasure 

Request erasure of your personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where: 

• you have successfully exercised your right to object to processing; 

• we may have processed your information unlawfully; or 

• we are required to erase your personal data to comply with the law. 

Please note that we may not always be able to comply with your request for erasure where there are specific legal grounds that require us to retain certain data. We will inform you if this is the case. 

Object to processing 

Object to processing of your personal data where we are relying on legitimate interests and there is something about your particular situation which makes you want to object because you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. 

Request restriction of processing 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

if you want us to establish the personal data’s accuracy; 

where our use of the personal data is unlawful but you do not want us to erase it; 

where you need us to hold the personal 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 personal data but we need to verify whether we have overriding legitimate grounds to use it. 

Request transfer 

You may request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. This right applies only to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you. 

Withdraw consent 

Where we rely on consent as the lawful basis for processing your personal data, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal. If you withdraw consent, we may not be able to provide certain aspects of the Programme to you where consent is necessary for delivery. 

No fee usually required 

You will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee or refuse to comply with your request if it is clearly unfounded, repetitive or excessive. 

Time limit to respond 

We aim to respond to all legitimate requests within one month. If your request is complex or you have made multiple requests, it may take longer. In that case, we will notify you and keep you informed of progress. 

Marketing Communications: 

We will not send you marketing communications unrelated to the administration of the Programme unless we are permitted to do so under applicable law. 

You may receive communications from us where they are necessary for: 

• administering the Programme; 

• processing Claims and Reward Hub Claims; 

• arranging Trade-In Device collections; 

• issuing payment links; 

• responding to queries; or 

• notifying you of changes to Programme Terms or this privacy policy. 

These communications are considered service communications and are not marketing communications. You cannot opt out of receiving service communications where they are necessary for participation in the Programme. 

Where we send marketing communications about future promotions or related services, we will do so in accordance with applicable electronic marketing laws. You may opt out of receiving marketing communications at any time by: 

• using the unsubscribe link in the relevant communication; or 

• contacting us at support@brighterfuturesedu.com. 

Opting out of marketing communications will not affect your participation in the Programme. 

Cookies: 

The Platform may use cookies and similar technologies to: 

• ensure the proper functioning of the Platform; 

• maintain session security; 

• analyse usage patterns; 

• improve user experience; and 

• support system integrity and fraud prevention. 

For detailed information about the cookies we use and how to manage your preferences, please refer to our Cookie Policy. 

Complaints: 

If you have concerns about how we process your personal data, you should contact us in the first instance using the details provided above. 

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters. Further information is available at www.ico.org.uk.