Privacy Policy

 St Neots English Centre Ltd (UK) Ltd believes strongly in protecting the privacy of everyone we have contact with and this notice sets out how we use your personal data.  To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).  This policy provides information on the types of data St Neots English Centre Ltd collects and processes about individuals. More specific privacy notices will be issued to the individual depending on the type of relationship you have with St Neots English Centre Ltd.


We, St Neots English Centre Ltd., with offices 3/5 Market Square, St Neots, Cambridgeshire, UK as the data controller ("St Neots English Centre "we," or "us"), explain in this Privacy and Cookie Policy (the “Policy”) how we collect, process and/or use information that we receive via our websites, emails we send, and mobile applications (collectively, the "Platform") that link to this Policy, as amended from time to time. This Policy describes how St Neots English Centre collects, processes, uses, shares and secures the personal information you provide. It also describes your choices regarding use, access, and correction of your personal information. For purposes of this Policy, personal information shall mean any information relating to an identified or identifiable natural person.


This Policy applies only to information we collect, process and use through the Platform. This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us.

  

St Neots English Centre Ltd holds a variety of data including (but not limited to):


· Personal and contact information, including special data such as health conditions

· Financial information

· Employment related information, both previous and current


Information We Collect


We collect information about you to provide our services. In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described below.


Information You Give Us


When you provide us with other personal information actively, we collect that information for processing and use in accordance with this Policy. Because we change our offerings and features from time to time, the options you have to provide us with personal information also may change, but here are some examples of situations in which you will have the opportunity to provide personal information to us:


Signing up for email alerts;


Completing a form related to one of our services;


Contacting us for information.


Depending on how you interact with our Platform, the personal information we collect from you may vary. For example, to subscribe to our blog we will ask only for an email address. In other circumstances, such as when you complete a form related to becoming a host family, we may ask you to provide other information, which may include your name, phone number, and/or postal address.


If you enter credit card information on the Platform in connection with a purchase, that information is sent directly from your browser to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.


Information We Collect Automatically


When you use the Platform, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with the Platform. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Platform.


Automated means of data collection include the following:


Cookies And Tracking Technologies. Technologies such as: cookies, web beacons, locally shared objects (sometimes called "flash cookies"), mobile identifiers and similar technologies ("Cookies") are used by St Neots English Centre and our partners (such analytics providers) We use Cookies to remember users’ settings as well as for authentication and analytics. These technologies may be used in analyzing trends, administering the Platform, tracking users’ movements around the Platform and to gather demographic information about our user base as a whole. You can control the use of Cookies at the individual browser level, but if you choose to disable Cookies, it may limit your use of certain features or functions on our website or service. For more information on Cookies, how we use them, the third parties we work with who use them, and how you can control them, please see the section entitled Cookie Policy and Ad Choices.


Log File Information. Log file information is automatically reported by your browser or mobile application each time you access a website on our Platform. For example, when you access a St Neots English Centre website, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.


Device Information. We collect information about the device you use to access the Platform, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. We may collect the device type and any other information you choose to provide, such as username, geolocation, or email address. We may also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.


How We Use Information/Purposes


We use the information we collect to provide our services, it is essential that we are able to collect and use the information as described in this Policy. So it is largely necessary for fulfilling the relationship we have with you, and, where that is not the case, we have a legitimate interest in using the information we collect, including personal information, for these purposes:


to hold contact details on record, so we can contact you about latest information, such as groups or classes 


to provide details to our in-coming students about their host families


to create aggregate and statistical data that does not identify you individually and that we can commercialize (for example, we use mobile device data and IP addresses to gather demographic information);


for other purposes that you separately authorise as you interact with St Neots English Centre.


When we collect any information that does not identify you as a specific natural person ("Non-Personal Information"), we are permitted to use and disclose this information for any purpose, notwithstanding anything to the contrary in this Policy, except where we are required to do otherwise by applicable law. Examples of Non-Personal Information include: physical location information; demographic information, including gender, dates of birth, Post Code codes, etc.; or any personal information that has been anonymized, aggregated or de-identified. If we combine any Non-Personal Information with your personal information (such as combining your Post code with your name), we will use and disclose such combined information as personal information in accordance with this policy. Similarly, if applicable law requires that we treat certain Non-Personal Information as personal information, we will use and disclose this information as personal information in accordance with this policy.


How We Share Information/Recipients


We only disclose your personal information to third parties as follows:


We may also share your information with St Neots English Centre Partners, namely any entity that directly or indirectly with the day-to-day function of our business. These instances and processing activities are outlined in the "How We Use Your Information" section above.

We share data with certain third parties in order for contracts to be fulfilled. On occasion these parties are outside the European Economic Area. In any instance of details being shared with a third-party further information will be provided in a specific privacy notice that relates to your relationship with St Neots English Centre Ltd.

 

We share data with certain third parties in order for contracts to be fulfilled. On occasion these parties are outside the European Economic Area. In any instance of details being shared with a third-party further information will be provided in a specific privacy notice that relates to your relationship with St Neots English Centre Ltd.


In reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer and its affiliates accepting the commitments made in this Policy and compliance with applicable law;


We will otherwise share personal information with your consent.


Cookie Policy and Ad Choices


This Cookie Policy describes how St Neots English Centre, Inc. ("we", "our", "us") uses Cookies and similar technologies. For more information on our general data privacy practices, please see the full Privacy Policy.


Cookies


Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. We use cookies, web beacons, locally shared objects (sometimes called "flash cookies"), mobile identifiers and similar technologies ("Cookies") to help us recognize you on the Platform, enhance your user experience, understand usage of the Platform, and show you relevant advertising. Cookies may also be set by other websites or services that run content on the page you're visiting.


What types of Cookies do we use?


We use two types of Cookies on the Platform: "session cookies" and "persistent cookies." Session Cookies are temporary Cookies that remain on your device until you leave the Platform. A persistent Cookie remains on your device for much longer until you manually delete it (how long the Cookie remains will depend on the duration or "lifetime" of the specific Cookie and your browser settings).


What are Cookies used for?


Cookies transmit information about you and your use of the Platform, such as your browser type, search preferences


We use Cookies for things like:

Authentication


We use Cookies to help us determine whether or not you've signed in to the Platform and to keep you signed in during visits as you access different pages.

Security


We use Cookies to enable and support security features, prevent fraud, and protect your data from unauthorised access.


Preferences and Features

We use Cookies to enable features, help us provide you with personalised content such as showing you your recent search activity.


Analytics and Performance

We use Cookies to analyze how our visitors use the Platform and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how our visitors reach our sites.


IP address or mobile device location information (to the extent you have enabled location tracking on your device);


Cookies (both on and off the Platform) which may include information from the Ad Partners we use to help deliver relevant ads to you.


How We Work with Third-Party Ad Partners


We work with third parties, such as Google Analytics, to provide analytics services that use the Cookies set on your device to measure the performance of advertising and track traffic to St Neots English Centre generally. We have also implemented Google Analytics Demographics and Interest Reporting, which categorizes Cookie information so that we and third-party service providers can better deliver advertisements that are relevant and useful to you on the Platform and various websites across the internet. In addition, a Cookie on some of our employer clients sites provides us with aggregate data about the number of applications submitted to those sites by users of Platform.


Opting Out of Cookies


St Neots English Centre Cookies. We use Cookies that are necessary for us to provide the services you use and you cannot opt out of these Cookies on the Platform. You are able to disable placement of some (but not all) Cookies by setting your browser to decline cookies, though this may worsen your user experience. Additionally, you can also control, manage and/or delete cookies via your browser settings. A useful resource for information about deleting and controlling cookies can be found at AboutCookies.org.


Ad Partner Cookies


You can opt out of tracking by Google Analytics and Google Analytics Demographics and Interest Reporting services by visiting Google Ads Settings or by downloading the Google Analytics Opt-Out Browser Add-on.

Please note: If ads or other features on the Platform are provided by third parties, those parties set and use their own Cookies that are subject to those third parties' privacy notices and policies. St Neots English Centre does not have access to, or control over, these Cookies. Also, if you respond to ads posted by third parties or submit information to third parties via the Platform, such third parties receive information about you subject to their privacy policies.


Do Not Track Signals


We do not currently respond to 'do not track' signals and similar settings or mechanisms. When you use the Platform, we try to provide a customized experience.


Other Important Privacy Information


EEA Resident Rights


If you are a resident of the European Economic Area, you have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the "Contact Details".


In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the "Contact Details".


You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.

Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.


We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We will respond to all requests within a reasonable timeframe. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.


How Long We Keep Your Personal Information


We keep your personal information only so long as we need it to provide the Platform to you and fulfill the purposes described in this Policy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can't identify you.


Your data and your rights

Individuals have rights relating to the data St Neots English Centre Ltd holds about them, these include:

· Right to be informed of the data we hold

· Right of access to data we hold on you

· Right for inaccuracies to be corrected

· Right to restriction of data processing

· Right to portability

· Right to erasure in certain circumstances

· Right to object to processing of data


Security Safeguards Security.


 We employ physical, electronic, and managerial measures to safeguard the information we collect online. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. 


Privacy of Minors


To access or use the Platform you must be at least 16 years of age or, if older, the age of majority in your jurisdiction, otherwise you may not use the Platform. If you become aware that a child has provided us with personal information without parental consent, please contact us here. If we become aware that a child has provided us with personal information without parental consent, we remove such information and terminate the child's account.

Data Controller

The information about you that we collect, process and/or use through the Platform is controlled by St Neots English Centre Ltd and the services it provides are hosted within the European Economic Area (EEA)

  

Protecting your data


St Neots English Centre Ltd is aware of the requirement to protect your data against accidental loss, disclosure, destruction or abuse. We have implemented steps to guard against this.


Contact us


If you have any questions about the Privacy Policy, the data we hold about you, or you wish to ensure that the data held about you is accurate and up to date please contact: