Privacy Policy
Introduction
Linguaphone Group Limited [trading as Direct English] (referred to below as “Linguaphone” or “we”) respects your privacy and is committed to protecting your personal data.
This privacy notice tells you how we look after your personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.
This privacy notice is set out so that you can click on links to jump to the specific areas set out below.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- GLOSSARY
Important information and who we are
This privacy notice aims to give you information on how Linguaphone collects and processes your personal data through your use of this website, including any data you may provide through this website when using any of our services or learning materials and content.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Linguaphone Group Limited is the controller and responsible for your personal data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Linguaphone Group Limited
The Data privacy manager
Email address: [privacy@linguaphonegroup.com]
Postal address: Liongate Enterprise Park, 80 Morden Road, Mitcham CR4 4PH
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 22 May 2018 and historic versions can be obtained by contacting us.
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until after that date as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Please also ensure that all data you submit is accurate at the time of submission.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, gender and country location.
- Contact Data includes email address, country location and telephone numbers.
- Financial Data includes bank account and payment card details.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, any data concerning your interests, preferences, feedback and responses which you submit via the website or any free text box including but not limited to any note or message you leave for us via the website.
- Usage Data includes information about how you use our website, products and services including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), pages and information you viewed or searched for, content downloaded from the website, page response times, download errors, length of visits to particular pages, page interaction information (such as scrolling, clicks and mouse-overs), the last page viewed on our website before leaving it and methods used to browse away from the page.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does notdirectly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Messages/Notes submitted by you on the website
You are entirely free to choose which, if any, information you wish to input and include in any message or note submitted by you on the website, although it must be accurate and not misleading, defamatory, denigratory, pornographic, illegal or offensive to others. You don’t have to provide any and it is your choice as to what information you do include. Please DO NOT post or add sensitive personal data referred to above as the Special Categories of Personal Data to your message or note.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you or in connection with services you have contracted or wish to contract for with us or one of our licensees or their sub-licensees and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or provide the services or information you have asked for. In this case, we may have to suspend or cancel a service you want to have from us but we will notify you if this is the case at the time.
How is your personal data collected
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity Date, Contact Data and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for information concerning our learning courses or services and/or our licensing arrangements;
- apply to become one of our master licensees or register an interest in doing so;
- create an account on our website;
- submit a message or note to us on or via the website in relation to services or licences you may be interested in finding out more about; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
- 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 the following parties:
analytics providers such as Google based outside the EU.
- Identity Data and Contact Data from publicly available databases such as Companies House in England and Wales.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you or in relation to the licensing of products, rights or services you have contracted for with us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data. We will not send third party direct marketing communications to you or share any of your data with third parties for this purpose without your consent. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please be aware that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new licensee or sub-licensee of our services, products and rights | (a) Identity
(b) Contact (c) Profile |
Performance of a contract with you |
| To process and deliver your orders for products and services
|
(a) Identity
(b) Contact (c) Financial |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to ensure that we are able to provide services and materials to you appropriately to ensure we are fulfilling orders placed by you as a licensee) |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Providing you with updates in relation to products/services falling within the scope of your license (c) Tracking referrals made by you of other third parties as licensees (d) Providing you with reports on franchise and licensing arrangements in your jurisdiction where you have requested these |
(a) Identity
(b) Contact (c) Profile |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to help market, develop and grow our business, to ensure proper operation of our licensee networks and to ensure you are appropriately credited for any introductions and referrals you make to us) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical (d) Usage |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation |
| To deliver relevant website content and recommendations to you and measure or understand the effectiveness of the recommendations we serve to you | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Technical |
Necessary for our legitimate interests (to study how users use our products/services and website, to develop them, to grow our business and to inform our operating and marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical
(b) Usage |
Necessary for our legitimate interests (to define types of licensees for our products and services, to keep our website updated and relevant, to enhance licensee resources and to develop our business and to inform our operating strategy) |
| To generate leads and prospects lists and databases with a view to using the same to market our licensing arrangements, services and products to you | (a) Identiy
(b) Contact (c) Profile (d) Usage (e) Technical |
Necessary for our legitimate interests (to create marketing leads and grow our business and to inform our operating and marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
