We use your personal information in the following ways to fulfil our contractual obligations to you and for our legitimate business interest:
We collect and process personal information from you when you:
Enquiries: We collect information you provide when you make an enquiry to us by phone, email or the Contact Us web form on our website and in our responses and subsequent correspondence. This information may include your name, contact details, age, nationality, country of residence, and details of your enquiry.
Course Applications: If you apply for a course online we store the information you provide in your or your child’s application form and in correspondence. This may include any or all of the following:
Where someone else is helping a student under 18 we store their name, contact email address and relationship to the child.
We may store special categories of sensitive data such as race, ethnicity, religious beliefs or health where provided to us as relevant to your or your child’s studies.
Learning Support: We collect the name, date of birth and contact information of the person using the service, information about the type of advice they are seeking where provided, and our advice and correspondence. This may include special categories of data. We also collect the name and contact details of the person paying and the record of payment including date and amount.
University Advice Service: We collect the name, date of birth and contact information of the person using the service, the name and contact details of the person paying and the record of payment including date and amount.
Marketing: We collect your name and contact details when you subscribe to our mailing lists or our blog. Please contact us if you find that your child under 13 has subscribed to our blog or mailing list without your consent and we will remove their details.
Website content: Comment or content you may submit such as essays, assignments, competition entries, feedback and photographs that we may feature with your consent on our web site or blog.
When you use our online services such as visiting our website, completing our web forms, participating in our courses and subscribing to our blog or mailing list, we collect technical information. This may include:
Our web site features embedded YouTube content and links that allow you to share our content with social media platforms such as Instagram, YouTube, Facebook, Pinterest and Twitter. We do not have any control over how third party sites collect data, and if you choose to follow these links please read the privacy notices of the sites you link to.
We may disclose your personal information to other data controllers and with our trusted suppliers in order to provide our services to you.
To order books: We provide the contact details needed to our book suppliers in order to fulfil our contract to provide course books. Our book suppliers and couriers are the data controller of information provided to them. They provide further information about how they process your personal information in their privacy policies:
To provide our services: We work with third-party companies who support our website for payment processing, accounting, marketing and other services which may require them to access information about you. If a service provider needs to access our client’s personal information to perform services on our behalf, they do so under our instructions. We do not share your information with third parties for their own purposes.
We may disclose your personal information:
• If we are under a duty to do so to comply with any legal obligation; • In order to enforce or apply our terms and other agreements; • To protect our rights or property; • To protect the safety of our clients including with healthcare, social and welfare advisors and with central and local government.
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
• Where we have your consent; • Where necessary to perform a contract with you; • When it is our legal duty; • Where processing your personal information is in our legitimate interest as long as this is not overridden by your rights and your information is processed in a way that you would reasonably expect. Our legitimate interest is that that the processing is necessary for us to provide the information or services that you have requested or purchased and to improve or promote them.
Sensitive personal information such as religion, race, ethnicity, political beliefs or health information such as learning abilities is classed as Special Category Data under the GDPR. Our legal basis for processing it is our legitimate interest which is to provide you with advice and guidance in relation to a course application or during a course of studies, or in order to use our Learning Support service where you have provided this information. Your interest is that you have provided this information for this limited purpose. We may only process this information if you have also given us your consent. We ask that you only provide such information on course applications and during the course of studies where you give us consent to collect it. We are only able to work with others who are helping a student with their studies where we have consent to share this information with them. Where provided to purchase a Learning Support service consultation we will seek your consent to store this information during the consultation and will seek your consent to share it if you are a student or the parent of a student and you wish us to share the information within the staff team.
Withdrawing your consent: Where you have given us your consent to use your personal data, you have the right to withdraw your consent at any time by writing to us at the email address below. You may withdraw your consent to marketing emails by using the unsubscribe link provided in every email or by contacting us at the email address below and we must always comply with your request.
Access to your data: Please contact us at the email address below if you want us to tell you about any data we hold about you or to request a copy by making a Subject Access Request.
Correcting your data: Please contact us at the email address below if your data is incorrect, out of date or incomplete and we will take reasonable steps to correct it.
Restricting use of your data: You have the right to object to our use of your personal information where we are relying on our legitimate interest to process it. If you object we must stop processing it unless we believe we have a legitimate overriding reason to do so. You have the right to ask us to delete your personal information. We may need to keep your data due to a legal obligation but may be able to restrict the use of your data so that it may only be used for legitimate reasons such as legal claims. In this situation, we would not use or share your information in other ways while it is restricted. If you want to object to how we use your data, or ask us to delete it or restrict how we use it, please contact us at the email address below.
Portability: Where we are processing information that you have provided to us with your consent or to fulfil a contract with you, you have the right to ask us for a copy to be sent to you or another organisation in a format that can be easily reused. Please contact us to request this at the email address below.
We retain personal information we have collected for as long as necessary to fulfil the purposes of providing the services you have purchased and for our legitimate business needs to respond to any questions or complaints and to maintain our business records as required by law. When we no longer have a legitimate business need to process your personal information, we will delete or anonymise it. If this is not possible (for example, because your personal information has been stored in backup archives) we will prevent any further processing and store it securely until deletion is possible. Our learning management system partner Instructure will keep all student and parent observer information they have processed for as long as we have an account with them and you may request a copy of this at any time, it may be deleted on request. Each data controller with whom we work will keep information according to their own retention schedules. You can check their privacy policies at the links provided above.
We may transfer personal data that we collect from you to our third-party data processors in countries that are outside the European Economic Area (EEA) such as the USA or New Zealand. Your data will be stored securely and under the same protection as data processed within the EEA.
We will review this policy to make any changes required to comply with legal or other requirements and will publish all changes on our website. This policy applies from 22nd May 2018.
If you have any complaints regarding this policy notice or requests for further information, please write to us by email and we will work with you to resolve, quickly and fairly any complaint you may have. You may also phone us or write to us. If you have any complaints that we are not able to answer or if you have any concerns about the way that your data is being handled you should contact the Data Privacy Supervisory Authority for the country in which you reside.
For the UK this is the Information Commissioner’s Office:
Phone: 0303 123 1113 Website: Information Commissioner’s Office
Email: firstname.lastname@example.org Phone: 0800 622 6599 (UK) / Int: +44 (0) 1865 988 307 Address: Wolsey Hall Oxford International Ltd, Midland House, West Way, Oxford, OX2 0PH, Registered in England No. 9270091