Privacy Policy
Last updated April 27th 2021
All rights reserved.
LearnAdvancedEnglish.com is committed to protecting the privacy of all individuals of whom we hold personal information. Please read this page (“Privacy Policy”) which explains the protocols for how we collect, use and protect your personal information, and the choices you have regarding that data. This Privacy Policy applies to the use of all our services and our website (and web-based services) on which a link to this policy appears.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.
This policy is also written to satisfy and conform to the Data Protection Act 2018 and the General Data Protection Regulations (the "GDPR") – which, together, form the “Data Protection Legislation”.
To the extent we are required by law, we have notified the United Kingdom's Information Commissioner's Office that we will process your personal information in accordance with the Data Protection Legislation (as mentioned above).
Definitions
Service
The Service is the https://www.learnadvancedenglish.com website (the “website”, the “Service”, “we”, “us”, “LearnAdvancedEnglish.com”, or “our”).
Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes and the manner in which any personal information is to be processed.
For the purpose of this Privacy Policy, the data controller of your personal data is Jonathan Abery (“I”, “me”, “mine”, or “my”) – owner of Learn Advanced English.
Personal Data
Personal Data means information that can be used to identify a living individual.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”), or it may come into our possession some other way. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to create a user profile, to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you or important to our service to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
Usage Data
We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Data Subject (or “User”)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Cookies
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we may use:
- Session Cookies to operate our Service.
- Preference Cookies to remember your preferences and various settings.
- Security Cookies for security purposes
- By providing us with any information about yourself (including via the website), you understand that we will process your personal information in accordance with this Privacy Policy.
This Privacy Policy covers:
1) What personal information we collect about you and how we collect it
2) Our legal basis for collecting and using your personal information
3) How we will use your personal data
4) Personal information that we share with third parties
5) Automated Processing of your personal data, including Profiling
6) Data retention, data security and transfers of personal information outside of the European Economic Area (EEA)
7) Your rights - Accessing, erasing and updating your personal information
8) Behavioural remarketing
9) Non-Personal data
10) Anti-bullying policy
11) How to unsubscribe from any email alerts that you receive
12) Complaints and concerns
13) Changes to our Privacy Policy
14) Legal and Contact Information
1. What personal information we collect about you and how we collect it
1.1 We collect several different types of information for various purposes to provide and improve our Service to you. We collect personal information by which we can identify you when you contact us by phone, email, live chat or other means, or when you sign up to use any of our services. We also collect cookies and usage data.
1.2 In particular, we collect and use your personal, contact and user account information when you:
- Buy a membership
- Sign up for a free membership
- Subscribe to receive emails from us
- Every time you e-mail, call or use our ‘contact us’ or comment features;
1.3 On registration you will be asked to put in your email (username) and choose a password to use for access to the lessons and membership areas. You agree to keep your password confidential, and will immediately notify LearnAdvancedEnglish.com in the event that you believe that the password may have become known by a third party.
1.4 Your password is personal to you and must not be used by anyone other than you. You will be held responsible for any loss or damage resulting from use of your password by any third party.
1.5 We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you or important to our service to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us.
1.6 We use “Stripe.com” to process payments students make to us (to buy memberships or other products). We have access to the amounts you spend on our memberships and the dates you purchase them. However, we do not store, nor do we have access to payment card information that you will need to share with Stripe.com to process any payments to LearnAdvancedEnglish.com. It is their responsibility to obtain your consent for this information.
Stripe.com adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council (https://www.pcisecuritystandards.org), which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Should you have any questions about how Stripe.com uses your data, it is governed by their Privacy Policy and you should direct your questions to them. Their privacy policy can be found here: https://stripe.com/en-gb/privacy
1.7 This website uses cookies to improve your experience when visiting the website. Cookies are small files saved to your device that track, save and store information about your interactions with and usage of the website. This allows the website, through its server, to provide you with a tailored experience within this website.
If you don’t want cookies to be stored on your device, you should make the necessary changes to your device or the relevant browsers or apps. Please note that if you disable cookies, some services or website functionality may not be available.
1.8 We use the following cookies:
Essential cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, and to use online forms.
Analytical cookies. This website uses Google Analytics tracking software to better understand how you use it. This software will save a cookie to your device in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google's privacy policy here: https://policies.google.com/
Marketing cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences. These cookies also record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website, the advertising displayed on it and communications sent more relevant to your interests.
1.9 By continuing to use this site, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests, and further help us to improve the site.
Sometimes, in our lessons and elsewhere on the website, there will be links to other websites that are not operated by us. If you click on a third-party link, you will be directed to a third-party website. There will likely be cookies saved onto your device from these websites too. We strongly advise you to read the Privacy Policies of every website you visit.
You enter these websites by your own choice and at your own risk. We have no control over, and assume no responsibility, for the content, privacy policies or practices of any third party sites or services.
However, under GDPR legislation, no personal information is stored, saved or collected without your consent.
1.10 We do not knowingly collect personally identifiable information from anyone under the age of 18 (“Children”). If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
2. Our legal basis for collecting and using your personal information
2.1 Data Protection Legislation mandates that any personal information can only be used where there is a lawful basis to do so. At LearnAdvancedEnglish.com, we rely on one or more of the following grounds to legally collect and use your personal information:
- The data is necessary for the performance of the contract which we have with you (i.e. to provide our services to you);
- For payment processing purposes;
- We are using your personal information where it is in our legitimate interests to do so (and where it does not override your rights);
- We have a legal obligation to process your personal information;
- You have consented to the use of your personal information by us.
2.2 Where we rely on your consent to process any of your personal information, you may revoke your consent at any time. However, if we no longer have consent to your name and email, it will not be possible to continue services with LearnAdvancedEnglish.com and our relationship will be terminated at the renewal date of your contract. Any such revocation will not affect the lawfulness of any prior use of that personal information.
In the instance of Stripe.com, they have the obligation to set their own Lawful Basis for processing your financial information.
3. How we use your personal information
3.1 We will use your personal information to enable us to provide our services to you and enable you to use our website. We need your personal information for the following purposes to perform a contract, or enter into a contract, with you:
- To authenticate your identity and administer your LearnAdvancedEnglish.com membership and other services;
- To provide you with updates about developments on our website;
- To enable our data processors to provide you with our services – the software we subscribe to in order to run our services and our hosting provider’s server
- To provide customer support
- To gather analysis or valuable information to improve our services
- To monitor the usage of our services
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events that we offer – unless you have opted otherwise
- Any other reasonable practices.
3.2 We may use your personal information where we have a legitimate business interest to do so. These legitimate interest are:
- To personalise aspects of our services to you – it is used to make a user profile;
- To carry out market research or surveys about our products and services;
- For marketing and strategic development purposes, for example to identify trends usage;
- To enable our data processors (such as our group companies and hosting providers) to provide services (or components thereof) requested by you;
- For the proper keeping of business records;
- To analyse and create statistical reports based on the services we provide and our performance of those services.
3.3 We will use your personal information where we are legally obliged to do so, this includes:
- For financial reporting and auditing purposes;
- For anti-money laundering or fraud prevention, detection and reporting;
- To maintain records of actions taken on your account.
3.4 We will use your personal information where we have your consent to do so:
- To provide you direct marketing information related to information about the products and services we offer;
- To create User Profiles so you may have access to our services
3.5 It is your responsibility to ensure that any information submitted as part of the registration process to your LearnAdvancedEnglish.com membership is accurate and up to date.
4. Personal information that we share with third parties
4.1 In order to provide the services offered on our Site, we sometimes need to share your personal information with other companies. However, we will continue to be responsible for the usage and security of your personal information when this happens.
4.2 We may also share your personal information with third party processors or suppliers that we employ to provide services to us and/or support our offering to you (such as our hosting, database and marketing platform providers). These third parties may need to process your personal information on our behalf to provide our services. Where this is the case, we take great care to only appoint reliable third parties who can guarantee the security of your personal information and our business information. For example, we assess each third party for their compliance with relevant privacy laws and information security practices to ensure they are able to provide the level of security that we would expect (and is required under law) when processing personal information. Note that these third parties simply process personal information on behalf of LearnAdvancedEnglish.com and have no right to use, disclose or transfer your personal information in any other way. Please see below in relation to our policy for transfers of personal information outside the EEA.
4.3 Some of our 3rd parties processors and suppliers include the membership software that we subscribe to (“www.memberpress.com”); the classroom software that we subscribe to (“www.learndash.com”); and the financial processor we use (www.stripe.com). Your information will also necessarily be stored on our server by our hosting provider (currently https://www.ionos.co.uk/). As such, these servers might not be located in the UK.
4.4 We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
Please note: MemberPress.com does not collect, store or process any information about our students so, as such, a Data Processing Agreement (DPA) from MemberPress.com is not necessary;
“LearnDash the company does not have any access or control over [the content produced by its software] whatsoever” on www.learnadvancedenglish.com. A DPA with them is also unnecessary. https://www.learndash.com/gdpr/
We have a Data Processing Agreement (DPA) with www.Stripe.com.
4.5 In certain circumstances, we may be required by law to disclose your personal information for investigative, regulatory or other related purposes to third parties including, but not limited to, government bodies, law enforcement agencies, courts, banks or other financial institutions and data protection regulators.
We may disclose your Personal Data in the belief of good faith that such action is necessary:
- To comply with a legal obligation;
- To protect and defend the rights or property of LearnAdvancedEnglish.com;
- To prevent or investigate possible wrongdoing in connection with the Service and site;
- To protect the personal safety of users of the Service or the public;
- To protect against legal liability.
5. Automated Processing of your personal data, including Profiling
5.1 LearnAdvancedEnglish.com does not undertake any automated decision making, profiling or artificial intelligence on the data which is provided to us.
6. Data retention, data security and transfers of personal information outside of the European Economic Area (EEA)
6.1 We take steps to protect your personal information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We will only keep your personal information for as long as we reasonably require and for the activities we have detailed above. This means we will retain personal information for the duration of any contract we have with you, but also to the extent that we are legally obligated to retain it (such as for HMRC), or for resolving disputes, or, primarily, until erasure is requested by you.
6.2 We also retain data for the purposes of internal analysis – perhaps to strengthen security or improve services to the customers.
6.3 The security of your data is important to us, but please remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Although we will take commercially acceptable steps to protect your personal information, we cannot guarantee the security of your data transmitted via email and/or our website; any transmission is at your own risk.
7. Your rights - Accessing, erasing and updating your personal information
7.1 LearnAdvancedEnglish.com aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us (see section [10] below).
7.2 In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you. Whenever possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where LearnAdvancedEnglish.com relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
Please also note: We need certain basic information to create and maintain your User Profile. In all the above circumstances, if there is any information we process and store that you no longer wish us to have, it will no longer be possible for you to have a User Profile and your membership will be necessarily terminated (at the next renewal date). It cannot be transferred to be held by a third-party.
7.3 If your data has been provided to us by your employer, and you wish to enforce any of the rights in section [7.2] as defined by the Data Protection Legislation, you should contact your employer directly as we are unable to action such a request without their permission. Should you direct this request to us, we will share your request with them and we may not inform you of this before doing so.
Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner's Office regarding such issues. Further information about how to make a complaint can be obtained at www.ico.org.uk or by telephoning +44 (0)303 123 1113.
Or perhaps you might try your own country’s Data Protection Authority about our collection and use of your personal data.
8. Non-Personal data
8.1 When interacting with our website, especially by answering or asking questions in lessons, users will generate content that may be used elsewhere on the Learn Advanced English website, in email or any associated media, and at any time. For example, a student may answer a question in a lesson and the teacher may then repeat that answer with some comments of their own in a summary section, or an email, or a Learn Advanced English social media platform, etc.
8.2 Section (11) of our Terms and Conditions contains more information regarding "User-generated content intellectual property rights".
9. Anti-bullying policy
9.1 Our anti-bullying policy can be found in Section (6) of our Terms and Conditions.
10. Behavioural remarketing
10.1 LearnAdvancedEnglish.com uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.
Google AdWords
10.2 Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: https://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://www.google.com/intl/en/policies/privacy/
10.3 Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance: https://digitaladvertisingalliance.org. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA https://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada https://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe https://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
11. How to unsubscribe from any email alerts that you receive
11.1 If you have elected to receive information about our products or services, and would like, at any time, to unsubscribe from this service, please click on the "unsubscribe" link at the bottom of an email.
12. Complaints and concerns
12.1 During your time with LearnAdvancedEnglish.com, if you experience any other problems or things that bother you (besides technical issues), please address them to us via the “Contact us” page.
13. Changes to our Privacy Policy
13.1 LearnAdvancedEnglish.com may amend this Privacy Policy at any time. Before we make material changes to it we will provide a prominent notice on our website and/or via email warning when the changes will “become effective”. The current “effective date” for our Privacy Policy is printed at the top of the document.
You are advised to review the Privacy Policy periodically for any changes. By continuing to use our services and/or our website, you agree to the updated Privacy Policy. If you do not agree to any changes that we make, it is your right not to continue using our services (i.e. by cancelling your monthly subscription).
You can stop receiving our services at any time (which would terminate our agreement) simply by cancelling future payments on your “My Account” page.
If you are unable to do that due to technical faults, you can send us a written notice at contact@learnadvancedenglish.com.
Please note: The email you send us to cancel your account will need to be sent from the email address you used to register with us, as well as including your username.
14. Legal and Contact Information
14.1 The registered address of LearnAdvancedEnglish.com is:
Learn Advanced English
2 Fernhill Drive,
Stacksteads,
Lancashire.
England,
OL13 8JS
United Kingdom
14.2 We will use all reasonable efforts to answer any questions or resolve any concerns regarding your privacy promptly.
All comments, queries and requests relating to our use of your personal information are welcomed. If you would like to contact us, queries regarding Data Protection should be addressed to LearnAdvancedEnglish.com by emailing us at dp@learnadvancedenglish.com.