PRIVACY & COOKIES POLICY
We, The Language Plan Limited (incorporated and registered in England and Wales with company registration no. 09894267) and whose registered office is at 5 Stratford Place, London, W1C 1AX value our customers and respect their privacy.
We are registered with the Information Commissioner’s Office under Registration Number ZA326693
This Policy only relates to the collection, protection, disclosure and use of personal data belonging to individuals who visit www.thelanguageplan.com (“our site”) or who otherwise provide us with their personal information. We will use your information only for the purposes for which it was collected.
We will comply with all relevant laws and regulations relating to data protection, whether local, national or supranational, including (i) the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (EC Directive) 2003 (S/2003i2426) (ii) all applicable requirements of the General Data Protection Regulation ((EU) 2016/679) (the “GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK unless and until the GDPR is no longer directly applicable in the UK and then (iii) any successor legislation to the GDPR or the Data Protection Act 2018.
By providing your personal information to us, you understand and agree that we may collect and use it in the ways described in this Policy. If you do not agree with the terms of this Policy, please do not provide personal details to us.
- What information do we collect from you?
- It is your choice to provide us with personal information. Personal information (or ‘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).
- The information we may collect from you includes, but is not limited to:
- personal contact details such as name, title, address, telephone number and email address, that you may provide to us by filling in forms on our site, or if you communicate with or request information from us, or when telephoning us;
- correspondence, or a record of it if you should contact us;
- details of your visits to our site (including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise) and the resources that you access;
- surveys that we use for research purposes, which we may ask you to complete, although you do not have to respond to them.
- It is important that the personal data we hold about you is accurate and current. Please advise us if your personal data changes during your relationship with us.
- How do we collect your information?
- Ways in which you may be providing us with personal information include, for example:
- By registering on our site;
- signing up for a newsletter or marketing information;
- contacting us with an enquiry;
- completing a survey which contains your personal information;
- reporting a problem; and/or
- giving us some feedback.
- How do we use your Personal Data?
3.1 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:
3.1.1 Where we need to perform our obligations to you.
3.1.2 Where it is necessary for our legitimate interests, and your interests and fundamental rights do not override those interests.
3.1.3 Where we need to comply with a legal or regulatory obligation.
- Opting Out
You can ask us to stop sending you marketing messages at any time by logging into the site and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by sending an email to us at firstname.lastname@example.org
- IP Addresses and Cookies
- We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
Cookies. A “cookie” is a small electronic file that collects information when someone visits a website. A cookie can identify the pages that are being viewed, and this can assist us to select the pages that the viewer sees. Some cookies only exist whilst viewers are online, but “persistent” cookies – which are not session-based – remain on the viewer’s computer, so that he or she can be recognised as a previous visitor when he or she next visits our website. This allows us to collect information about a viewer’s browsing habits whilst on our site, and this can be useful in assisting us to monitor and improve our services.
- We do not store sensitive information such as account numbers or passwords in “persistent” cookies, and cookies in themselves, do not contain enough information to identify you. You will only acquire a personal identity in relation to your browsing habits after you have formally provided us with your personal data for the purposes outlined in point 1 above.
5.4 GIF and Other Web Tools. In addition to using cookies, we might also use GIFs and other web tools to collect information about your browsing activities whilst on our site. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.
5.5 Any information that we acquire about you using cookies, GIFs or other web tools is subject to the same restrictions and conditions as any other information we collect about you.
- The Cookies Used on Our Site
6.1 Cookies set by our site and/or Google Analytics:
|Cookie||Usage||Is cookie essential to site operation?|
|_ga||distinguishes users, records IP address of user’s computer (expires 2 years)||required for effective measurement of site usage to improve user
experience and site performance via Google Analytics
|_gid||adds a unique identifier to distinguish users, distinguishes users (expires 24 hours)|
|wpm-auth||stores user auth details – limited to /wp-admin/ (expires 2 days)||essential to allow the login and editing of pages by the CMS administrators|
|wordpress_logged_in_||indicates when you’re logged in / who you are for interface use|
|trx_addons_is_retina||checks if the user’s screen is retina, one year||Yes for retina screens|
6.3 Cookies set by Google Analytics:
|Google Analytics is a web analytics service provided by Google Inc. By default, Google Analytics sets two cookies in order to evaluate your use of the Site, (including number of visits, duration of browsing and referring sites), and compile reports for us on activity on the Site. Google stores the information collected by the cookies on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google state that they will not associate your IP address with any other
data held by Google. For more information about the way Google Analytics uses these cookies please visit the following link: https://developers.google.com/
|These cookies collect information about how you use a website, for instance which pages you go to the most and if you get error messages from web pages. This information is aggregated and therefore anonymous. These cookies are only used to improve how a website works, by managing the performance and design of the Site.|
- How To Disable/Enable Cookies
7.1 You have the ability to accept or decline cookies by modifying the settings on your browser. For example, in Internet Explorer, you can go to Tools and then Internet Options, where there is the option to change your settings to disable cookies. However, you may not be able to use all the interactive features of our Site if the cookies are disabled.
7.2 You also have the ability to delete cookies that have been installed in the cookie folder of your browser. To do this, you should search for “cookies” in your Help function for information on where to find your cookies folder.
7.4 To prevent Google Analytics cookies being set, you may install the Google Analytics Opt-Out Browser Add-On by clicking on the following link and following the instructions at https://tools.google.com/dlpage/gaoptout
- Change of Purpose
8.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by sending an email to us at email@example.com
8.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
8.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Why do we collect your information?
- We will only use personal information collected from you for the purpose it was collected (or for related purposes) or in the following circumstances:
9.1.1 Services – To provide specific services that you request.
9.1.2 Ease of Use – To ensure that content from our site is presented in the most effective manner for you and for your computer.
9.1.3 Communication – To notify you about changes to information we place on our site or our services.
- Marketing Communications and Analysis – We may use your personal information to communicate with you about our products and services which may be of interest to you and we may contact you about this by post or e-mail.
- Compliance – To comply with a legal duty or regulatory obligation to which we are subject.
- Legitimate Interests – Where it is necessary for our legitimate interests, and when your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Any information or statistics relating to our business that we disclose to others shall not identify you personally. We may, for example, perform statistical analyses of the behaviour of the users of our website in order to measure interest in the various areas of our site. This information, and any other general information about our users that we share with our tutors will not disclose personal information about you.
- We will not, under any circumstances, sell your personal information to anyone else.
- How do we store your information?
- All personal information we collect from you is stored on secure servers.
- The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. If your personal information is shared, you can expect a similar degree of protection in respect of your personal information as we require third parties to respect the security of your data and to take appropriate measures to protect your personal information in line with this Policy.
- Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
- How long do we keep your information?
We will only retain your personal information for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, and for the uses set out in this Policy. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- When might we disclose your personal information
- We may disclose your personal information:
To prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the delivery and/or provision of any of our services to you.
- In the event that we sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets.
- If The Language Plan Limited, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not permit our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal information with our tutors appointed to service your requirements so that you and they can communicate with each other.
- Data Security
13.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
13.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Third-Party Links
Our site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy notice of every website you visit before you submit any personal data to them.
- How can I access the information that you hold about me?
- Under the GDPR you have the right to access information we hold about you (commonly known as a “data subject access request”) free of charge. If you would like a copy of this information, please email us at firstname.lastname@example.org
- What if I don’t want you to hold my information anymore?
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by marking your preferences on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com .
- Can I change the information you hold about me?
- Where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. To withdraw your consent, please contact us at firstname.lastname@example.org . Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
- Under certain circumstances you also have the right to:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
- Request access to the personal information that we hold about you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request erasure of your personal information where there is no good reason for us continuing to process it.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or a third party.
If you want to contact us with regards to the information we hold about you as above, please do so by emailing us at email@example.com . You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
- Time limit to respond to you
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- How do I contact you?
Questions, comments and requests regarding this Policy are welcomed and should be addressed to firstname.lastname@example.org
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.
This Policy was last revised on 23 March 2018