Privacy and Cookies Policy
This Privacy and Cookies Policy was last updated on 18 September 2019.
For the purpose of the applicable data protection legislation (meaning the Data Protection Act 2018 and the General Data Protection Regulation and any other legislation which implements it) (the Data Protection Legislation), the data controller is English Language Video Learning Limited of 37 Warren Street, London W1T 6AD, United Kingdom. References in this Privacy and Cookies Policy to we, our or us are references to English Language Video Learning Limited.
Our Privacy Commitments
Protecting your personal data is important to us. We will be clear and open with you on what personal data we collect and how we process it and we will only use the personal data that we collect about you in accordance with the Data Protection Legislation.
We take data security seriously, and so for as long as we maintain records of your personal data, we will endeavour to protect it with appropriate safety and security measures.
Personal data we collect and process
We collect and process the following personal data from or about you:
- personal data collected directly from you when you enter your details on our website, which may include contact details such as name, postal address, telephone numbers email addresses;
- personal data collected directly from you as a subscriber to our newsletter which may include contact details such as name, postal address, telephone numbers and email address;
- personal data received directly from you by email, telephone call or by business card at at a meeting;
- personal data collected automatically from the use by you of our website. This includes the data transmitted from your browser, such as your IP address, the date and time of the visit the pages accessed, the access status/HTTP status code, your browser, your operating system and interface, as well as the language and version of the browser software;
- personal data that we receive if you follow one of our social media accounts, which may include your name, account name, gender, general interests, location and age;
- personal data that we receive if you respond to or engage with any of our advertising on social media, which may include your name, account name, gender, general interests, location and age;
- personal data we collect about you from publicly available sources. This may include information available from social media (depending on your settings and the applicable privacy policies), including social media engagement metrics such as numbers of connections, followers and clicks;
- personal data we receive from other sources. We may receive further information about you if you use any of the services we provide from time to time. We work closely with third parties (including, for example, business partners, affiliates, service providers, identity verification providers) and may receive information about you from them. We may combine information we receive from these other sources with information you give to us and information we collect about you.
How we use your personal data and the legal basis for doing so
We use the personal data we hold about you to pursue our legitimate interests in providing and marketing our services to you, and in improving our website, services, and interactions with you and other users of our website and services, in the following ways:
- For the administration, operation and management of our website and services, and to communicate with you regarding the same by telephone, mail, email, text (SMS) message, instant messaging or other electronic means;
- For your use of our website and services and to communicate with you regarding the same by telephone, mail, email, text (SMS) message, instant messaging or other electronic means;
- To contact you with surveys and feedback requests (for example relating to services you used);
- To analyse the purchase history of our customers and the way our customers and users use our website;
- To verify your identity as part of our identity authentication process and to prevent, detect and prosecute fraud and crime and comply with legal or regulatory, requirements;
- To provide you with information about our services that you request from us;
- To provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
- To provide you with information about products or services we feel may interest you or be best for you;
- To notify you about changes to our services;
- Ensure that content from our website is presented in the most effective manner for you and your device;
- Aggregate it on an anonymous basis with other data for data analytical and reporting purposes;
- To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To build up a picture of your interests so that you don’t miss information relevant to you when you visit our website;
- To improve the service we offer you and to try and ensure that you get the best from our website and services in the short term, for example by providing you with relevant search results;
- To improve the service we offer you and to try and ensure that you get the best from our website and services over the longer term, for example by understanding how you and other users interact with our website or use our services;
- To allow you to participate in any interactive features of our service, when you choose to do so;
- As part of our efforts to keep our website safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising and marketing messages to you, including through newsletters and email correspondence;
- To make suggestions and recommendations (both through the website and other channels, such as email) to you and others about products or services that we think may interest you or them based on your and their usage patterns both on our website and in relation to our communications with you and them on other channels (such as email);
- For training and quality purposes;
- To check any instructions you give to us and for the purposes of investigating any complaint you may make, or as evidence in any dispute or anticipated disputes between you and us.
Where you have requested that we provide any of our services to you, or you otherwise make use of those services, we will process your personal data in order to perform our contract with you and provide those services to you.
In some cases we may also use the personal data we hold about you to comply with our legal obligations.
We may also send you direct marketing communications (for example, by email). We will ensure that we have your consent for this if the law requires us to do so. You can withdraw this consent and/or unsubscribe from receiving these communications at any time as described in the section on direct marketing below.
How we share your personal data with third parties
We will only share your personal data with third parties as stated below. We review all our relationships with third parties carefully so that we can be sure as possible that their practices match our own commitments to you relating to privacy and security. We also comply with the Data Protection Legislation in our dealings with these third parties to ensure that your personal data is appropriately protected.
We may share your personal data with any member of our group from time to time, which means our subsidiaries, our ultimate holding company and its subsidiaries.
Disclosure of your personal data to others may be necessary to ensure the smooth provision to you of our website and any services and information you request.
We may share your personal data with selected third parties including:
- Business partners, suppliers and sub-contractors for the provision of our website and services and the performance of any contract we enter into with you;
- Identity verification providers, to comply with legal or regulatory requirements;
- Analytics and search engine providers that assist us in the improvement and optimisation of our website;
- IT and software providers who supply us with our IT infrastructure for the provision of our website and services and administering our business (including our internal and external communications) and who also help us manage our customer and contact databases, customer relationships and marketing;
We may also disclose your personal data to third parties if:
- We sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- Our company or business or substantially all of its assets are acquired by a third party, in which case the personal data held by us will be one of the transferred assets; and
- We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with you; or to protect the rights, property, or safety of our business, our customers, or others.
Social media and third party websites
Our website may, from time to time, contain links to and from the websites of our business partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Using your personal data for direct marketing
We may send direct marketing communications to you, including by email, telephone or SMS or mail. We will ensure that we have your consent for this if the law requires us to do so.
Whenever you receive direct marketing from us we will also tell you how you can unsubscribe so that you no longer receive it. When we communicate with you via email you will also be given the opportunity to set or amend any marketing preferences that you have indicated to us. You can do this at any time by following the link in the footer of the last email you received from us (“Update your subscription preferences” or “Unsubscribe”).
You are also able at any time to withdraw any consent to receive marketing communications that you have given to us. You can do this by contacting us using the details the same details as specified above.
Please provide us with your full name, address and other contact details and, if a member, any applicable membership number, to enable us to find your records. Sometimes we may also need to contact you further to ask you for additional information so that we can comply with your request.
Where we store your personal data
Where we store your personal data ourselves it is stored on our secure servers in the UK. However, where we share your information with third parties this may involve transferring it outside the UK or a country outside the European Economic Area (EEA). This may include countries that do not have data protection laws which are as strong as those in the UK or the EEA. Where we do this we will take the steps required under the Data Protection Legislation to ensure that your information is appropriately protected. If you would like any further information about this, then please contact us using the details in the Contacting Us section below.
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 Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.
How long we keep your personal data
How long we keep your personal data will depend on the purpose for which we and any third parties use it. We and any applicable third parties that we share it with will only retain your information for as long as is necessary for the purposes set out in this Privacy and Cookies Policy and as is necessary to comply with our and their legal obligations. We do not keep more personal data than we need for the particular purpose.
We will maintain records of your personal data for as long as you remain:
- a registered and active subscriber to our mailing list;
- a registered user of our website or services;
- for as long as is necessary to provide our services to you.
Where we have provided you with a service we may also keep an archived record of your personal data for a period of up to 6 years after termination (unless a longer period is prescribed by law) for the purposes of responding to legal disputes and legal enquiries or investigations only, but will not use this data for any other purpose.
If you ask us to stop sending direct marketing communications to you (see the section on direct marketing, above), we will keep the minimum amount of information necessary (such as your name and email address) to ensure that we are able to adhere to your request.
Your rights in relation to your personal data
Under the Data Protection Legislation, you have certain rights in respect of the personal data we hold about you. This includes: right to update and correct that personal data, the right to request from us a copy of your personal data, the right to request restriction of the processing of that personal data, the right to request that we delete that personal data and the right to object to our continued processing of your personal data. You may also have the right to data portability. These rights are limited in some situations. For example, if we have a legal requirement or a compelling legitimate ground we may continue to process your data even where you request its deletion.
We may ask for further information from you or require you to provide us with appropriate identification before we comply with any request.
If you have a complaint about the way in which we use your personal information we would encourage you to contact us in the first instance but you also have the right to complain directly to the Information Commissioner (www.ico.gov.uk).
If you would like to exercise any of these rights then you can contact us using the contact information provided in the Contacting Us section, below.
The following types of cookies are used on our website:
- Strictly necessary cookies.
These are cookies that are required for the operation of the website. They include, for example, cookies that allow us to know certain browser information, system operating system, times and durations that the website has been visited, connection speed data and to store your cookie preferences for our website.
These cookies are not shared with third parties.
- Analytical/performance cookies.
They allow us to recognise and count the number of visitors and to see how visitors move around our website. This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily. It also helps us understand which pages and services people are interested in so that we can idecide how it is presented and what is offered.
None of the cookies provide any information which might disclose the identity of a specific person but they may potentially identify your operating system, your browser and your internet settings.
You may change the storing of cookies in your browser settings at any time by selecting the function “accept no cookies”. However, disabling essential cookies may result in you no longer be able to use the entire functionality of our website.
Google Analytics, a web analytics service provided by Google, Inc. (“Google”) also places cookies on your computer, to enable Google to provide us with activity reports relating to the website. Google uses this data only to provide us with information on how users use our website and does not associate your IP address with any other data held by Google. The information generated by Google cookies about your use of the platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. You may refuse these cookies by selecting the appropriate settings on your browser or by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
Changes to our Privacy and Cookies Policy
We will update this Privacy and Cookies Policy from time to time to reflect changes in our business or the law. All such changes will be posted to our website and if we consider it to be appropriate we will notify you of any material changes by e-mail.
If you would like to know what information we hold about you or if you have any other queries or complaints in relation to this Privacy and Cookies Policy our contact details are as follows: [email protected]