English One Privacy Policy
Our Commitment to Your Privacy
English One AG (“English
One”), Haldenstrasse 4, 6006 Lucerne, Switzerland, is committed to
protecting the privacy of our potential and existing customers. The English One
privacy policy (the “Privacy Policy”)
applies to all Personal Data (as defined below) processed by us, including Personal
Data collected or submitted through our websites, mobile applications or through our official social media pages
or through other channels online and offline as further described below (collectively
the “English One Products”).
If you cannot, or will not, provide us with the
personal information we reasonably require, we may be unable to provide you
with the information, goods or services you have
requested.
“Personal Data” is information or pieces of information that could allow you to be identified, such as for example:
· Name and contact details (e.g. postal and email address, telephone number)
· Account information (e.g. user name, profile picture or social media account ID)
· Country of residence
· Birth date
· Technical information, e.g. screen/user name, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data and location data
· Preferences (e.g. shopping habits, preferred educational courses)
· Company or school name and address
· Credit and debit card number
We collect Personal Data in a variety of ways:
· Directly from you: Information is collected directly from you, either by you providing the information directly to us or you acting in a manner that provides us with the information, for example:
o Offline: We collect Personal Data from you offline, for example when you contact customer service, enrol in a product or service or provide information to us in writing.
o Online: We collect your Personal Data through the English One Products, for example when you sign up for a newsletter or a brochure, enrol in a product or service. We also collect Personal Data:
§ Through your device. Provided that you have enabled that function on your device, we collect the physical location of it to provide you with personalized location-based services and content. Read more about such services under “How do we use Personal Data?”
· From our corporate affiliates, business partners or assistance providers. We may receive Personal Data from other parties in conjunction with your course/program, including:
o Our corporate affiliates, such as a local company that promotes the sales of our services and offers customer service in your country of residence and provides us with the Personal Data that is needed to come to an agreement with you on your order, or the school that provides some of the services that you have ordered, or the principal company responsible for the performance of the contract with you for any of English One’s offers.
o Business partners, such as local sales agents that promote the sales of our services in your country of residence.
· From other sources. We may receive your Personal Data from other sources, such as public databases; joint marketing partners such as marketing agencies or providers of software and services for digital marketing automation and analytics; social media platforms, including but not limited to; Facebook, Instagram, Snapchat, Musically, LinkedIn, Twitter, YouTube and messenger services such as WhatsApp or Facebook Messenger; from people with whom you are friends or otherwise connected with on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to your English One Products account, such Personal Data that you have registered in your profile, such as your email address, phone number, postal address, date of birth, name and user name will be shared with us. Furthermore, we use cookies to track members of social media networks.
·
If you browse our sites
We may also collect information about your use of our services through your browser to trace activity on our sites, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the English One Product you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit the English One Products, along with the time of the visit and the page(s) that were visited. These data are only stored and used together with other Personal Data that you have submitted if you have given your consent to do so.
·
Your
Personal Data will be processed by English One for the purposes of providing
you with the products and services that you have ordered, for customer service,
administrative services or as otherwise necessary to perform the contract
between you and us or as further described in this Privacy Policy.
· We may also use Personal Data:
o For statistical purposes, calculating usage levels, and helping diagnose server problems with the English One Products as well as to ensure that the English One Products function properly.
o To allow you to contact and be contacted by other users through the English One Products, as permitted by the applicable product.
o To allow you to participate on message boards, chat, profile pages and blogs and use other services enabling you to post information and materials.
o If you have given your consent:
§ To analyse and improve our offers by identifying usage trends, determining the effectiveness of our promotional campaigns and tailoring the English One Products experience and content based on your past activities on the English One Products.
§ To provide you with personalized location-based services and content through the use of your device’s physical location.
§ To market our products and services, including special promotions based on your interests. All such email communication will include a clear unsubscribe link.
·
We share your Personal Data
with our corporate affiliates, business partners and service providers both
within and outside the EEA/Switzerland:
o Our corporate affiliates are for example a local company that promotes the sales of our services and offers customer service in your country of residence, or the school that provides some of the services that you have ordered or the principal company that is responsible for the performance of the contract with you for any of English One’s offers.
o Business partners are for example local sales agents that promote the sales of our services in your country of residence.
o Service providers, such as providers of IT systems, for example for managing customer relations or payments, scheduling classes or storing learning results; or providers of software and services for digital marketing automation and analytics.
·
We
have put appropriate safeguards in place for transfers of your Personal Data
outside the EEA/Switzerland, including the standard data protection clauses
adopted by the European Commission, available at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915 and http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087. For more
information on standard data protection clauses in place, please see the
contact section below.
·
We
also share Personal Data as we believe to be necessary: (a) under applicable
law; (b) to comply with legal process; (c) to respond to requests from public
and government authorities including public and government authorities outside
your country of residence; (d) to enforce our terms and conditions or a
contract; (e) to protect our operations or those of any of our affiliates; (f)
to protect our rights, privacy, safety or property, and/or that of our
affiliates, you or others; and (g) to allow us to pursue available remedies or
limit the damages that we may sustain.
We base our right to collect and use your Personal Data on the need to do so in order to provide you with the services or products that you have ordered from us, or when there is a legitimate interest for us (i.e. the service provider) to use your Personal Data.
To the extent we use sensitive Personal Data, we base this on your explicit consent. Sensitive data can for example be information about health, ethnicity or religious beliefs, read more under “Sensitive data”.
We use appropriate organizational, technical and administrative measures to keep the Personal Data under our control accurate and up-to-date, as well as to protect the Personal Data against unauthorised or unlawful processing and the accidental loss, destruction or damage of the Personal Data.
If at any time you wish to stop receiving marketing communications from us you can use the unsubscribe feature in the marketing communication you received or let us know by using the contact information listed in the “Contact Us” section. In your request, please indicate that you wish to stop receiving marketing communications from us.
Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) as soon as reasonably practicable.
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the English One Product contain a link. The inclusion of a link on English One Products does not imply endorsement of the linked site by us or by our affiliates.
Additionally, we may provide you with access to third-party functionality that permits you to share your activities on English One Products to your social media account(s). Please note that any information that you provide by using this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this functionality.
We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been communicated.
We will keep limited parts of your Personal Data which are necessary for marketing purposes until you withdraw your consent, but in no event for longer than 10 years after your last completed service or delivery of product.
If you are under the age of 16, you should review this text together with your parent or guardian to make sure you both understand them. We are not responsible for checking your age but sometimes we still do verification checks. If we learn that you are under the age of 16 and that we have collected information about you without consent from your parent or guardian, we will delete the information as soon as possible and you will not be able to use English One Products.
We do not generally seek to collect any sensitive Personal Data. Sensitive Personal Data is data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or medical condition, criminal background or trade union membership. In certain situations, this might however be necessary (for example in order to provide you with the services and products you have ordered and in relation to your insurance). We will make sure that we receive your explicit consent to such processing and treat this information securely.
Our Privacy Policy may change from time to time. We will not significantly reduce your rights under this Privacy Policy without informing you. We will post any Privacy Policy changes on this page and, prior to implementing such changes, we will provide a more prominent notice. Where required by law, we will seek your prior consent to any change.
You have a right to contact us and without cost find out which information about you that is being used. You have a right to receive your Personal Data in a machine-readable format and you have a right to transfer your personal to another data controller.
You have the right to, at any time, withdraw your consent or object to us using your Personal Data for direct marketing purposes and you may at any time request that the use of your Personal Data is restricted or that we shall delete your Personal Data. Note however that a restriction or deletion could mean that we are not able to provide you with information, services or products as you have requested. Upon your request, we are also obliged to correct Personal Data about you that is incorrect, incomplete or misleading.
If you would like to have a copy of the information English One holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact us at the address English One AG, Haldenstrasse 4, 6006 Lucerne, Switzerland.
If you have
complaints about our handling of your Personal Data, you have a right to contact
the supervisory authority in the country where you live.