Effective Date: 01 September 2019
Imagine English Limited (“We”) are committed to protecting and respecting your privacy.
For the purpose of the Data Protection Act 1998 (“the Act”), the data controller is Imagine English Limited, registered in England and Wales (08411107).
Lombard Chambers, 1st Floor, Ormond Street, Liverpool L3 9NA
Imagine English Limited reserves the right to amend this policy from time to time by updating this page and you are advised to review this page from time to time to ensure you continue to be happy with the terms of this policy.
This policy only applies to our websites, systems and processes. If you leave our site via a link or otherwise, you will be subject to the policy of that website provider. We have no control over that policy or the terms of the website and you should check their policy before continuing to access the site.
What we collect
We may collect and process the following data about you, you may supply this personally or we may collect this information from anyone acting on your behalf, such as parents or agents:
Information that you provide by filling in our electronic forms. This includes information provided at the time of registering to use our site, subscribing to our service or requesting further services.
Information that you provide by completing any paper application form or information request in including copies of written or printed documents you supply to support your application.
Information that you provide when you enter into prize draws or competitions which Imagine English Limited organises.
Communication we have with you which you provide when you get in touch with us.
Other information relevant to customer surveys and/or offers.
Details of your visits to our website including, but not limited to, traffic data, location data, weblogs, operating system, browser usage, the resources that you access and other communication data.
Where we store and use your personal data
The data that we collect from you will be primarily stored in our own secure data centres in the European Economic Area (“EEA”), it may also be shared between the group companies and staff as appropriate and as necessary to meet the needs of our business and to deliver you service.
The data may also be transferred to, and stored at, destinations outside the EEA. It may also be processed by staff operating outside the EEA who work for us, one of our subsidiary companies or for one of our suppliers or agents.
We will use the personal information you have provided for:
- Providing services and goods to you or your companies.
- Internal record keeping e.g. to raise your invoice and to process your orders.
- In order to improve our products and services.
- Sending you communications by post, telephone or electronic means in order to inform you of other products, services or events related to Imagine English Limited, which may include e-mails containing relevant news or competitions from our sponsors.
- Asking you to participate in surveys and market research.
How long we keep your data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.
Disclosure of your information
We may disclose your personal information to third parties:
If appropriate we will also share your personal data with companies and organisations for the purposes of regulatory or inspection compliance, fraud protection and credit risk reduction.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation to do so.
We do not and will not sell, rent or trade your personal information. We will only disclose your personal information to third parties in the ways set out in this policy and, in particular, as set out below, and in accordance with your local data protection laws.
We may disclose your personal information to overseas recipients. We will ensure that any such international transfers are either necessary for the performance of a contract between you and the overseas recipient or are made subject to appropriate or suitable safeguards as required by your local data protection laws.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or e-mail us as soon as possible, at the address written at the end of this policy.
Our websites use SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar. If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.
We are committed to ensuring that your information is as secure as possible. In order to prevent unauthorised access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect online. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
In order to maintain quality of service for customers and provide a better user experience, the following websites collect certain information about visitors to its website using cookies:
A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information back from the browser and help us to provide him/her with the best possible experience.
We use our cookies to help us:
- Make our website work as you’d expect.
- Remember your settings during and between visits.
- Improve the speed/security of the site.
- Allow you to share pages with social networking services like Facebook.
- Continuously improve our website for you.
- Make our marketing more efficient.
- Remember if we have already asked you certain questions (for example if you declined to take a survey).
- Collect any personally identifiable information (without your express permission).
- Pass data to advertising networks.
- Pass personally identifiable data to third parties.
- Google is used for Google Map integration and Google Analytics. To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.
- YouTube powers some of the videos on our site. https://www.youtube.com/intl/en-GB/about/policies/ – community-guidelines
We do not associate the data which we gather from these sites with any personally identifying information from any other source. If we do want to collect personally identifiable data through our websites, we will tell you. We will make it clear when we collect personal data and will explain what we intend to do with it.
You can learn more about all the cookies we use below.
You will be asked again in no later than 365 days about your cookie preferences since the last time you were asked.
Turning cookies off
You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of our website and a large proportion of other websites around the world as cookies are a standard part of most modern websites.
To learn how to change your setting of cookies, please visit https://www.aboutcookies.org.
Please note that, if you adjust the cookie settings for our websites (listed above), this may prevent you from taking full advantage of our site afterwards.
Third party functions
Our sites, like most websites, include functionality provided by third parties. A common example is an embedded YouTube video. Disabling these cookies may mean that the functions offered by these third parties will no longer work.
This site uses the Google Maps map service via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.
The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Article 6 (1) (f) GDPR.
Further information about handling user data, can be found in the data protection declaration of Google at https://policies.google.com/privacy .
Web beacons, which are also known as clear GIFs, web bugs or pixel tags, are often used in combination with cookies which may be included in the sites’ web pages and e-mail messages. At organisation name, Web beacons allow us to count users who have visited certain pages and to generate statistics about how our site is used. They are not used to access personally identifiable information.
How do I opt out of online behavioural advertising?
There are a number of sites which can help you opt out of online behavioural advertising from the third-party advertising agencies that operate online behavioural advertising for website publishers.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website.
For that reason we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Access to Information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
Post: Data Protection Officer
Imagine English Ltd, Lombard Chambers, 1st Floor, Ormond Street, Liverpool L3 9NA, UK