PLEASE READ THIS POLICY CAREFULLY BEFORE USING LINGO LTD SERVICES
Protecting your data, privacy and personal information is very important to Lingo LTD(" us", " our" or " we"). It is vitally important to us that our customers feel secure when using the Services.
When visiting Lingo LTD's website at http://www.lingo-education.com (our " Website") you will be asked to indicate your acknowledgment of, and where applicable your consent to, the practices described in this policy.
We may collect and process the following data about you.
Information that you provide to us.
You will be asked to provide us with your information when you:
- fill in forms on our Website, or correspond with us by phone, email or otherwise;
- register to use our Services, subscribe to our newsletter, promotional emails or other marketing materials;
- use the Services;
- report a problem with our Services; or
- complete any surveys we ask you to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).
The information you will be asked to provide to us for these purposes will include your first name, surname, email address, phone number, delivery address, or further information required to verify your identity.
Information we collect about you.
With regard to each of your visits to our Website we may automatically collect the following information; however, this information cannot be used to identify you:
- device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
- technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes;
How we use your information and justification of use.
Use of personal information under EU data protection laws must be justified under one of a number of legal "grounds" and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your information:
- Consent : where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);
- Contract performance : where your information is necessary to enter into or perform our contract with you;
- Legal obligation : where we need to use your information to comply with our legal obligations;
- Legitimate interests : where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and
- Legal claims : where your information if necessary for us to defend, prosecute or make a claim against you or a third party.
We use information held about you (and information about others that you have provided us with) in the following ways:
Email address, first name, surname, home address, product choices and customisation, phone call recordings and Website chat history. No marketing of third party products or services will be conducted without your consent.
We will not sell your personal data (or any other data you provide us with) to third-parties, however, we reserve the right to share any data, which has been anonymised and/or aggregated. You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymised data collected or created by us.
We may use information for marketing products and services to you in the following ways:
Newsletters and marketing emails relating to our own similar services and products. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. Legitimate interest (to market our products and services - you have the right to unsubscribe at any time).We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us.
Where we store your personal information
The personal data that we collect from you (including email addresses that form part of our prospective marketing database) is processed in the European Economic Area ("EEA") and stored on Cloud Servers.
Disclosure of your information
We may also disclose your personal information to third parties in the following circumstances:
Purpose of disclosure and third party(s) to which disclosure might be made:
If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets. Legitimate interest (to sell our business or assets); and where required by applicable law, consent (for sensitive personal data).
If Lingo LTD or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets. Legitimate interest (to sell our Company or assets); and where required by applicable law, consent (for sensitive personal data).
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Lingo LTD, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection. Legal obligation, vital interest.
Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or accurate information is provided and fraud is identified or suspected, details may be passed to fraud prevent agencies. Legitimate interest (to assist with the prevention of fraud and to assess your risk profile).
We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.Legal obligation (to cooperate with law enforcement and regulatory authorities).
How long we retain your personal data
We will hold the above information for as long as is necessary in order to provide you with the Services, deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body. Some personal data may need to be retained for longer than this to ensure Lingo LTD can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymised information may be retained) or securely destroyed.
Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at firstname.lastname@example.org
You have the following rights in relation to your personal data:
Right of Access
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, a copy of the personal data undergoing processing.
Right to Rectification
We will use reasonable endeavors to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.
Right to erasure / 'Right to be forgotten'
Asking us to delete all of your personal data will result in Lingo LTD deleting your personal data without undue delay (unless there is a legitimate and legal reason why Lingo LTD is unable to delete certain of your personal data, in which case we will inform you of this in writing).
Right to restriction of processing
You have the right to ask us to stop processing your personal data at any time.
Right to data portability
You have the right to request that Lingo LTD provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.
Right to complain
You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner's Office in the UK (see [www.ico.org.uk](http://www.ico.org.uk)). Although we encourage our customers to engage with us in the event they have any concerns or complaints. Lingo LTD will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.
Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use Lingo LTD's Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services.
Where you request Lingo LTD to rectify or erase your personal data or restrict any processing of such personal data, Lingo LTD may notify third parties to whom such personal data has been disclosed of such request.
Changes to this policy
For the purpose of the relevant data protection legislation, the data controller is Lingo LTD (company no. 09699336 ) with registered address at 20-22 Wenlock Road N1 7GU London, England.