DATA PROTECTION FOR CLIENTS of ENGLISH LIKE A NATIVE .COM & .CO.UK

1. GENERAL OVERVIEW
   1. This privacy policy aims to provide you with all the information you need to know regarding how your personal data is handled.  This policy outlines how we use the information we collect about you and how you can instruct us to limit the use of that information if you wish to do so.
   2. If you have any general queries about how your data is managed, please email: hello@englishlikeanative.co.uk
   3. Where you register your interest and commit to a course on englishlikeanative.co.uk or englishlikeanative.com, English Like A Native is the data controller of the data you provide directly to us via the website.
   4. This privacy policy relates to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’

2. Personal data collected or created
   1. Personal data is collected from you when you sign up to the newsletter, or purchase a product or service on the website: this will include (but not limited to):
      1.  Full name
      2.  Country of residence
      3.  Email address
      4.  Payment details in order to purchase access to courses or subscriptions
      5.  Your queries
      6.  Your progress through your course.
      7.  A record of correspondence between us 
      8.  Details of transactions you carry out through our site
      9.  Details of your visits to our site and the resources you use
      10.  Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers

3. Lawful basis for processing your data
   1. Where you have signed up to services offered by English Like A Native, your personal data will be collected, retained & processed, purely for the purpose of:
      1.  Responding to and keeping a record of your queries. 
      2.  Maintain a record of your course progress so that you can move through the course sequentially, knowing which lessons you have completed. 
      3.  Without access to your data as detailed above, English Like A Native will not be able to communicate with you and provide you any services.

4. 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:
   1. you have given consent to the processing of your personal data for one or more specific purposes;
   2. 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;
   3. processing is necessary for compliance with a legal obligation to which we are subject;
   4. processing is necessary to protect the vital interests of you or of another natural person;
   5. 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
   6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, 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.

5. We may use aggregate information and statistics for the purposes of monitoring website usage in order to help us develop the website and our services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.

6. What we do not do
   1. English Like A Native does not:
      1.  Sell your personal data to any third parties;

7. Retaining your data
   1. Your data is held for as long as is required in order to provide you with the services signed up to. For example, files generated as part of your courses are deleted from the website at the moment your user profile is deleted, as per your request. 

8. Our use of cookies and other information gathering technologies [All Cookies used by and on our website are used in accordance with current English and EU Cookie Law.]
   1. The site uses cookies or similar technology to collect information about your access to the site. 
   2. Our cookies will be used for:
      1.  essential session management
      2.  recognising if a visitor to the site is registered with us in any way (including logging information from your computer such as the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our site.)
      3.  Functionality and customising elements of the promotional layout and/or content of the pages of the site.
      4.  Performance and measurement so that we can improve the site
      5.  Improving the presentation of the site to you
      6.  Providing you with information about products and services that you request and that we think may interest you

9. How we use what we collect
   1. If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you.
   2. If you are a new customer, you will only be contacted if you agree to it.
   3. If you don’t want to be contacted for marketing purposes, please tick the relevant box that you will find on screen.

10. Data Storage and Security Measures undertaken
    1. Systems used by English Like A Native are password protected, which is periodically changed. All updates to software are completed as and when required to ensure the systems are protected with the latest virus and spyware available.
    2. We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and deal with payment.

11.  We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. These are the third parties that have access to your information:
    1. Stripe (for payment processing): https://stripe.com/
    2. PayPal (for payment processing): https://www.paypal.com/
    3. Upsell (for managing orders): https://www.upsellplugin.com/
    4. Active Campaign (for communication & marketing): https://www.activecampaign.com/

12. We are allowed to disclose your information in the following cases:
    1. If we want to sell our business, or our company, we can disclose it to the potential buyer.
    2. We can disclose it to other businesses in our group.
    3. We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
    4. We can exchange information with others to protect against fraud or credit risks.

13. By giving us your personal data, you agree to this arrangement.

14. Your legal rights and right to complain
    1. You have rights in connection with your personal data, including: to withdraw consent where you have given it, to be informed and have access to your information, to correct or complete inaccurate data, and in certain circumstances to restrict, request erasure, object to processing, or request portability of your information to another organisation.

15. Getting in touch or making a complaint
    1. If you want to get in touch for any reason regarding your data protection rights, please use write to us at hello@englishlikeanative.co.uk
    2. You have the right to make an official complaint about the way English Like A Native handles your personal data. In the first instance, please contact English Like A Native on the details above.

If you do not feel that your complaint has been suitably addressed, you can contact the data protection regulator, Information Commissioner’s Office (ICO).

You can get in touch with the ICO in any of the following ways:

By going to their website: www.ico.org.uk

By giving them a call on 0303 123 1113

or by writing to them. Their address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow SK9 5AF.

Last updated August 2020