What is Personal Data?
Personal data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not personal data. This includes, for example, the number of users of a website.
Responsible for data processing
Responsible for data processing is:
[Insert Business Address]
Phone: +44 020 4541 6677
General information on data processing
a) international data transfer
In the course of our business and website operations, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside the UK and the EEA. Where we transfer data outside the UK or the EEA, we make sure to use the necessary and appropriate safeguards to ensure that the security of your personal data is maintained and guaranteed. In particular those include standard contractual clauses, binding corporate rules and data processing agreements. If you have any questions relating to our third-party providers, please refer to their relevant Privacy Policies or contact us for further details.
b) the legal bases of processing
All personal data that we obtain from you via the website will be processed for the purposes described in more detail below. This is done within the framework of the DPA and the GDPR or with your consent. In particular, we process personal data only when processing is permitted and if:
- you have given your consent,
- the data is necessary for the fulfilment of a contract / pre-contractual measures,
- the data is necessary for the fulfilment of a legal obligation or
- the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.
c)your data subject rights
The following rights are available to you as a data subject:
- the right to information,
- the right to rectification,
- the right to erasure,
- the right to restriction of data processing,
- the right to data portability,
- the right to object to data processing,
- the right to revoke any consent you have given, and
- the right to lodge a complaint with the competent supervisory authority.
Please contact us at any time with questions and suggestions regarding data protection and/or to enforce your rights, using firstname.lastname@example.org.
d) exercising your rights
If you wish to access your personal data or exercise any of the rights listed above, you should apply in writing, providing evidence of your identity. Any communication from us in relation to your rights as detailed above will be provided free of charge. However, in case of requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request.
e) Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please contact us.
f) the competent supervisory authority
The Information Commissioner`s Office (ICO) is the relevant authority in the UK. The ICO is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK (www.ico.org.uk). If you believe that the processing of your personal data is not lawful, you can lodge a complaint with a data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach any Supervisory Authority.
g) storage and retention of your data
We process and store your personal data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period (in particular commercial and tax law) exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
We use State-of-the-art internet technologies to ensure the security of your data. For secure storage of your data, the systems are protected by firewalls that prevent unauthorised access from outside. In addition, technical and organisational security measures are used to protect the personal data you have provided against accidental or intentional manipulation, loss, destruction, or access by unauthorised persons.
Processing of Automatically Collected Data
To provide our website, we use the services of IONOS who process the below-mentioned data and all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.
b) Collection of access data and log files
We, rather IONOS on our behalf, also collects data on every access to our website. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website.
d) Content Management System (CMS)
We use the Content Management System (CMS) of WordPress a service provided by Automattic Inc, to publish and maintain the created and edited Content and texts on our website. This means that all content and texts submitted to us by users for publication is transferred to WordPress. In addition to texts, this also includes, for example your data in our forms. The legal basis for this processing is our legitimate interest.
e) Google Fonts
We use Google Fonts on our website to display external fonts. This is a service provided by Google Inc. To enable the display of certain fonts on our website, a connection to the Google server in the USA is established when our website is accessed. The connection to Google established when you call up our website enables Google to determine which website sent your request and to which IP address the display of the font is to be transmitted.
f) Google Contact Form 7
We use the WooCommerce service developed and operated by Automattic Inc, WooCommerce creates a device ID based on your device data, which can be used to recognise your access device (e.g., PC, tablet or laptop) when you visit my shop again. WooCommerce may also sets a cookie for this purpose. The cookie contains the device ID, but no personal usage or transaction data about you. This means that your access device can be recognised without identifying you by name and linking it to your device ID. This represents a legitimate interest.
Personal data and children
Our services are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal data from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact.
Online presences in social media
Concerns and Contact
Data processing when you submit it to our website and when you use our services
When you contact us through our website or use our services, some data is collected and processed by us or on our behalf by our selected third-party providers.
a) Contacting us
If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfil the contract and/or to fulfil our pre-contractual obligations and/or our overriding legitimate interest in processing your request.
We also offer to contact us via the messaging service WhatsApp. If you contact us via WhatsApp on the occasion of a specific transaction, we store and use the mobile phone number you use on WhatsApp and – if provided – your first and last name in accordance with the provision of a contractual or pre-contractual measure to process and respond to your request.
b) User account
In order to provide you with the greatest possible convenience, we offer you the permanent storage of your personal data in a password-protected user account/user account. The creation of a user account is voluntary. If you create a user account, the processing of your data collected here is based on the provision of the contract. In addition to the data requested when placing an order, you must enter a password of your choice to set up a user account. This password is used together with your e-mail address to access your user account. Please treat your personal access data confidentially and in particular do not make them accessible to unauthorised third parties. Please note that you will automatically remain logged in after leaving our website unless you actively log out. You have the option to delete your user account at any time. The deletion of your data takes place automatically after the expiry of the retention obligations applicable to us under commercial and tax law.
c) Data management and customer support
For optimal customer support, we use first name, last name, e-mail address, and the data related to your contract with us. Your data may be stored on our website and or our customer relationship management system (“CRM system”). This data processing is based on our legitimate interest in providing our customer service.
d) Contract processing when using our services
We process the data of our tutors and registered users, in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information. The legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your Consent.
e) Financial Information
To make a purchase, you may need to provide a valid payment method (e.g., credit or debit card). Your payment information will be collected and processed by our authorised payment vendor Stripe. We do not directly collect or store credit or debit card numbers ourselves in the ordinary course of processing transactions. Accordingly, the data is processed on the basis of our contractual relationship.
f) Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. Furthermore, based on our business interests, we store information on tutors, and other business partners, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
g) Tutorials, lessons and Online Meetings
We use Zoom, Skype or Google meets or other similar services to conduct online meetings and various types of data are processed when using an online platform for meetings. The scope of the data depends on the information you provide before or during the online meeting. The legal basis for this is our legitimate interest in effective customer communication and, insofar as it concerns an enquiry to enter into or fulfil a contract, also contract.
h) Join The Team
If you apply to join our team, we process the information we receive from you as part of the application process. In addition to your contact details, information about your education, qualifications, work experience and skills is particularly relevant to us.
Your data will initially be processed solely for the purpose of carrying out the application process. If your application is successful, it will become part of your personnel file and will be used to carry out and terminate your employment and will be deleted in accordance with the rules applicable to personnel files. If we are unable to offer you employment, we will continue to process your data for up to six months after sending the rejection in order to defend ourselves against any legal claims, in particular alleged discrimination in the application process.
The legal basis for processing data during the application process contract and, and your consent, for example by sending us information that is not necessary for the application process. The legal basis for data processing after a rejection is our legitimate interest.
As a rule, we do not require any special categories of personal data within the meaning of Art. 9 GDPR for the application process. We ask you not to provide us with any such information from the outset. If such information is relevant to the application process, we process it together with your other data. Your data will not be used by us for automated decision-making or profiling, nor will it be passed on to third parties. Your data will be processed by us or on our behalf.
You are not obliged to provide us with personal data. However, we can only assess your suitability for the respective position under consideration if we receive information in particular about your education, work experience and skills, and we cannot include you in the application process without providing your contact details.
Sharing of personal data
We will not disclose or otherwise distribute your personal data to third parties unless this:
- is necessary for the performance of our services,
- you have consented to the disclosure,
- or the disclosure of data is permitted by relevant legal provisions.
However, we are entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors within the framework of the DPA and GDPR. External service providers support us, for example, in the technical operation and support of the website, data management, the provision and performance of services, marketing, as well as the implementation and fulfilment of reporting obligations.
The service providers commissioned by us however will process your data exclusively in accordance with our instructions and we remain in accordance with the DPA and GDPR responsible for the protection of your data. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organisational measures, and additional controls by us.
We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfil our legitimate interests.
Automated decision-making including profiling does not take place.
Direct marketing in the context of a customer relationship
Insofar as you have also given us your separate consent to process your data for consulting, marketing, and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.