1. Purpose Of The Policy
Please note that this Policy applies in conjunction with other policies and procedures. It does not establish contractual or legal rights for any persons, but intends to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, the ‘General Data Protection Regulation’ or ‘GDPR’).
2. Who Controls Your Personal Data
English in Manchester Ltd is the controller of the personal data you submit to us and is responsible for the processing of your personal data under the applicable data protection legislation. Our registered address is The Ivy Business Centre, Crown Street MAnchester M35 9BG. English in Manchester Ltd is registered in the England company number 10701400.
3. How We Collect & Process Your Personal Data
3.1 Personal Data We Collect About You
Because data privacy is of high importance for us, we intend to remain open and transparent about how we use your personal data. English in Manchester Ltd will only collect your personal data where necessary for our services.
Depending on your use of our services and our website, we may collect, use and disclose (i.e., process) the following types of personal data about you: your contact information, such as a name, surname, address, e-mail address, IP address and telephone number. We may also collect payment, credit and order information. For more information about the way we process personal data, we invite you to read the following sections.
Although we are technically considered ‘data controllers’, the ultimate control over your personal data remains with you at all times. Provided you give us a proof of your real identity, you have the right to request access to a copy of the personal data we currently maintain about you in a structured, commonly used and machine-readable format and obtain information regarding the processing, including whether we process your personal data for profiling purposes. In case you notice an error in your personal data, you may also request that we rectify the inaccurate personal data or complete your personal data. Following this, we will notify each third party to which we have disclosed your personal data, so that they can make sure your personal data is accurate with them too. Where technically feasible, you have the right to request that English in Manchester Ltd transmits your personal data to another company of your choice.
3.2 Legal Grounds For Processing
Under the applicable data protection legislation, personal data may only be collected and processed based on a limited number of legal grounds. At English in Manchester Ltd, we rely on one of the following grounds to process your personal data:
Necessity for the performance of a contract with you (e.g. when you purchase English courses from us);
Legal obligation to which English in Manchester Ltd is subject (e.g. when we handle your payment details);
Legitimate interests of English in Manchester Ltd (e.g. when we send you marketing e-mails regarding our activities);
Your explicit and informed consent (e.g. when you subscribe to our newsletters through your marketing preferences, or if you participate in a contest)
3.3 Marketing E-mail Newsletters
Some of our Students might be genuinely interested in receiving newsletters about our latest courses and Services. However, we understand not everyone feels the same way. Therefore, the processing of your personal data for marketing purposes is based solely on your explicit prior consent, which means we will never send you marketing communication if you don’t want to, unless you have already bought courses from us.
If you wish to receive newsletters regarding our latest products and Services, you are able to opt in to our e-mail newsletters through our websites, in which case we will process your e-mail address.
Once subscribed, you may object at any time to the use of your personal data for profiling by English in Manchester Ltd or any of the third-party recipients we have shared your personal data with, provided that we process your personal data based on our legitimate interests. If we process your personal data for direct marketing purposes, such as sending you newsletters, you have the right to object at all times to the use of your personal data for that purpose by contacting our data protection officer using the contact details below, without any additional cost.
3.4 Information We Collect In Our School
When you book a course in our school, we may process personal data such as your name, contact details and limited payment details because this information is necessary for the performance of the contract with you.
Since we can process your personal data based on our legitimate interests, you have the right to object at any time to the use of your personal data for profiling by English in Manchester Ltd or any of the third-party recipients we have shared your personal data with. You can do so by contacting our data protection officer by using the e-mail address mentioned below this policy.
3.5 Customer Service
It is in our legitimate interest to make sure technical support as well as complaints and queries relating to our courses are handled quickly and efficiently. In order to do so, we may process details such as your name, contact information, date of birth, bank account number (e.g. for refunds) and purchasing history. Where you contacted our Customer support through social media, we may also process some of your social media account information.
4. How We Protect Your Personal Data
English in Manchester Ltd is committed to the processing of your personal data in a lawful, fair and transparent manner. Accordingly, we will only use your personal data if we have a valid reason for doing so and provided you have been informed of the processing purposes beforehand, at the time we collected your personal data.
Moreover, English in Manchester Ltd guarantees that any processing of your personal data will be limited to what is necessary, adequate and relevant in order to achieve the purposes for which personal data is collected. Whenever possible and technically feasible, English in Manchester Ltd will use anonymized or pseudonymized data, e.g. for our internal statistics and financial reporting purposes.
Because the protection of your personal data is of the upmost importance to us, English in Manchester Ltd is also dedicated to protect your personal data and the systems it is held in. We have defined and implemented adequate technical and organisational measures against any unauthorised access, unlawful use, accidental loss, corruption or destruction. This way, English in Manchester Ltd is confident that your personal data will be processed on a strictly ‘need to know basis’, when and where appropriate and necessary.
As we are fully aware threats evolve and diversify and we wish to sustain your trust throughout the years, we regularly review and update our security measures and infrastructure, with a view to mitigate operational risks and maintain our security programs up to the latest industry-accepted standards and best practices.
5. External Parties With Whom We May Share Your Personal Data
Where relevant and necessary for the purpose of the processing activity, we may occasionally need to disclose your personal data to other appropriate organisations who have a need to know (so-called ‘third party recipients’), based on our legitimate interest.
With the purpose of helping us understand more about your interests and preferences, offer you more relevant advertisements, we may for example share your personal data with data analytics companies and advertisers based on our legitimate interest.
Each time your personal data is shared externally, this will be covered by strict data processing agreements, where English in Manchester Ltd remains the data controller and the third parties involved act as data processors. English in Manchester Ltd shall restrict the access and transfer of your personal data to trusted third party recipients who demonstrate an adequate level of data protection. Moreover, these third-party recipients will be required to delete or return all the personal data to English in Manchester Ltd after the end of the provision of Services relating to the processing and delete existing copies, unless the law requires storage of the personal data.
6. International Transfers Of Your Personal Data
7. How Long We Keep Your Personal Data
As a general rule, English in Manchester Ltd only keeps your personal data for as long as necessary to fulfil the purpose for which we initially collected it. However, because these needs can vary for different data types in the context of different English courses, actual retention periods can vary significantly. In addition, there are laws and regulations that apply and which set minimum periods for retention of personal data.
English in Manchester Ltd will always ensure you are kept informed of the criteria used to determine the effective retention period as well as the underlying reasons thereof, which will depend on whether we process your personal data in the context of a contractual relationship with you or based on your explicit consent; whether we process the personal data for our own legitimate interest, or whether English in Manchester Ltd is legally obligated to retain the personal data for a specific period or to comply with specific legal obligations.
8. How We Erase Your Personal Data
Under certain circumstances, and provided you give us a proof of your real identity, you may exercise your right to request the erasure of your personal data and have us inform third-party recipients to whom we provided your personal data of this request. Please be aware that this is only possible to the extent that the personal data is no longer necessary for the initial purpose (i), if the processing was based on your consent and you withdrew it (ii), or where you have already objected to the processing based on our legitimate interest (iii).
Except when we need to keep a copy of your personal data for statistical purposes, to establish, exercise or defend legal claims or insofar as we are legally required to retain a copy of your personal data, you can rest assured English in Manchester Ltd shall either securely dispose of or permanently anonymize your personal data once we have fulfilled the initial processing purpose and when further retention of your personal data is not necessary anymore.
9. Your Rights As Data Subjects
For further information or if you wish to exercise one of your above-mentioned rights, please contact us at firstname.lastname@example.org. We will do our best to reply to your e-mail as soon as possible, and in any case within one week. If fulfilling your request necessitates more time, we will keep you informed of this and come back to you within one additional month. English in Manchester Ltd will charge you nothing for this request, unless we have already provided you with the requested information previously or it appears unreasonably difficult for us to retrieve it. In such case, we will inform you beforehand of the administrative fee.
If you are not satisfied with the way we handled your request, you have the right to request the restriction of our use of your personal data and lodge a complaint with the supervisory authority responsible for the protection of personal data in your country of residence. Although we sincerely hope this won’t be necessary, we have provided the contact details of the relevant data protection authorities below.
The Information Commissioner’s Office