Adventures in Spanish understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and interpretations
In this Policy the following terms shall have the following meanings:
“Account”means an account required to access and/or use certain areas and features of Our Site;
“Cookie”means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]
“Our Site”means this website, www.adventuresinspanish.co.uk;
“UK and EU Cookie Law”means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]
“We/Us/Our”means Adventures in Spanish [, a sole trader registered in England, whose registered address is 64 Fairburn Ave. Crewe. Cheshire. CW2 7SY.
2. Information About Us
- Our Site, AdventuresinSpanish.co.uk, is [owned and] operated by Kelly Thornhill,
- [Our data protection officer is Kelly Thornhill who can be contacted at firstname.lastname@example.org
3. Scope - What Does This Policy Cover?
4. What Data Do We Collect?
- [date of birth;]
- [business/company name]
- [job title;]
- [contact information such as email addresses and telephone numbers;]
- [demographic information such as post code, preferences and interests;]
- [financial information such as credit / debit card numbers;]
- [IP address (automatically collected);]
- [web browser type and version (automatically collected);]
- [operating system (automatically collected);]
- [a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);]
One category of data which we do process occasionally is that of sensitive data. Under this title, physical disabilities and neuro-diversity diagnoses (such as dyslexia, autism ADSD etc) and mental illness are shared with me by students and parents confidentially by way of email. This data helps us tailor our lessons and support for the individual student and is not shared outside the email communications in which it is contained. On the ending of our contractual arrangements, these sensitive emails will be deleted.
5. How We Collect Your Personal Data
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- subscribe to our email update newsletter;
- register for a course or lessons;
- request resources or marketing be sent to you; or
- give us feedback.
Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics provider Google based in OR outside the EU
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU
- Advertising networks [such as Facebook, Twitter LinkedIn and YouTube based inside OR outside the EU; and search information providers [such as Google based inside OR outside the EU
6. How Do We Use Your Data?
- All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 7, below.
- We use your data to provide the best possible service to you. This includes:
- [Supplying Our services to you;]
- [Personalising and tailoring Our services for you;]
- [Responding to communications from you;]
- [Supplying you with email, newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the unsubscribe link in emails sent to you]
- [Market research;]
- [Analysing your use of Our Site [and gathering feedback] to enable Us to continually improve Our Site and your user experience;]
- In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the [products and] services We can provide you without your consent for Us to be able to use such data.
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
- Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
7. How and Where Do We Store Your Data?
- We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.
- Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements
- Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
- Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
8. Do We Share Your Data?
- We may contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:
Edmodo, Quizlet, PayPal, Zoom, MailChimp, GoogleDrive
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
- In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
- We currently do not record lessons and when our contractual obligations are over, the contacts from third party accounts are deleted. However, if recording is requested by the student and we consent, the recording will be shared with the student. We will not keep a copy of it.
- The email system we use is MailChimp and they are compliant with the new GDPR legislation as you can see here.
9. Data Security
We – ARE PUTTING – in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
10. What Happens If Our Business Changes Hands?
- In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
11. How Can You Control Your Data?
When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails.).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
You may access Our Site without providing any data at all. [However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.]
- You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.
13. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at email@example.com, or using the contact details below in section 14.
14. What Cookies Do We Use and What For?
15. Summary of Your Rights under GDPR
Under the GDPR, you have:
- the right to request access to, deletion of or correction of, your personal data held by Us;
- the right to complain to a supervisory authority;
- be informed of what data processing is taking place;
- the right to restrict processing;
- the right to data portability;
- object to processing of your personal data;
- rights with respect to automated decision-making and profiling (see section 14 below).
16. Automated Decision-Making and Profiling
16.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
16.2 The right described in section 16.1 does not apply in the following circumstances:
- The decision is necessary for the entry into, or performance of, a contract between the You and Us;
- The decision is authorised by law; or
- You have given you explicit consent.
- Where We use your personal data for profiling purposes, the following shall apply:
- Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- Appropriate mathematical or statistical procedures will be used;
- Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
17. Contacting Us