HOW WE THINK ABOUT PRIVACY
This Policy applies to our collection, use and disclosure of your personal information. This Policy does not impose any limits on the collection, use or disclosure of business contact information and certain publicly-available information.
WHAT INFORMATION MIGHT BE COLLECTED
Information That We Collect Directly from You
We may collect some or all of the following information directly from you, depending on your interactions with us and our website and services:
- your name, age, gender and citizenship;
- your home address, home telephone number, mobile phone number, personal email address;
- the languages you speak;
- emergency contact information;
- products you have purchased or courses you have attended or completed (including their dates and locations) – though note that we do not retain or store payment card information;
- hours of instruction you have received;
- credentials you have received from us;
- surveys you have completed
- Other information available on the site
Information collected through our website and apps
We or our service providers that help us maintain and operate our website and mobile applications may also automatically collect the following information relating to your access to and use of our website and mobile applications through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; your type of computer or mobile device; pages you view; links you click; your IP address; the length of time you visit or use our site or mobile apps; and the referring URL, or the webpage that led you to our site.
We may use various technological methods to track the patterns of users accessing and using our website and mobile apps, including the following methods:
Web Beacons: Web beacons are small pieces of data that are embedded in images on the pages of websites. We may use these technical methods to analyze the traffic patterns on our site, such as the frequency with which our users visit various parts of our site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML emails that we send to determine whether you have opened those emails or clicked on links in the emails. The information from use of these technical methods may be collected in a form that is not personally identifying.
Click Stream Data: When you use, read, browse or download information from our website and apps, we or our service providers may also collect information such as the date, time and duration of a visit, information about your location, the pages accessed, the IP address of your computer, and any information downloaded.
Third-Party Content (e.g., social media links): Some of the content on our website and apps may include applications made available by third parties, which could include social media buttons or links that allow you to share content or links to our website and apps through the relevant third-party platforms. These third-party applications themselves may facilitate the collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third-party websites to understand their privacy practices and options they may make available to you in relation to their collection of your personal information.
HOW INFORMATION MAY BE USED
When collecting personal information, we will routinely state the purpose of collection. We collect, use and disclose your personal information that may be used for the following purposes:
- to provide and administer products and services you request, and to disclose the information for any purpose related to the provision of requested products and services;
- to authenticate your identity;
- to provide personal information to third-party suppliers of products and services (as discussed in more detail below);
- to manage or transfer our assets or liabilities, for example, in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products or services;
- to maintain accurate customer records;
- to protect us, yourself and others from fraud and error and to safeguard our business interests;
- to provide reports to credit bureaus;
- to collect debts owed to us;
- to comply with legal and regulatory requirements; and
- to distribute to third parties, including financial institutions, payment processors, landlords, lawyers, financial institutions and government licensing bodies for any of the above purposes.
The collections, uses and disclosures listed above are a reasonably necessary part of your relationship with us. We may also collect, use and disclose your personal information as follows:
- we may use your personal information to offer additional or alternate products and services to you and may add your personal information to customer lists for this purpose; and
- Although unlikely, we may share your personal information with suppliers and third parties so that they may offer their products or services to you.
We will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent.
Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.
LIMITS ON COLLECTION OF PERSONAL INFORMATION
We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect personal information as authorized by law.
LIMITS FOR USING, DISCLOSING AND RETAINING PERSONAL INFORMATION
Your personal information will only be used or disclosed for the purposes set out above and as authorized by law.
We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose.
OUR SERVICE PROVIDERS
We may retain agents, subcontractors or service providers from time to time in relation to our business or the products or services that we provide. If we require a service provider to deal with your personal information, we will take reasonable steps to ensure that the service provider adheres to privacy procedures and will keep your personal information confidential. We will not provide more information than is necessary to the service provider and will ensure that the information is returned or destroyed once the purpose for which it was given is filled.
Our service providers may be located outside of the USA, and you acknowledges that personal information may be processed and stored in foreign jurisdictions with different (and perhaps weaker) privacy laws, and that the governments, courts or law enforcement or regulatory agencies in those jurisdictions may be able to obtain disclosure of that personal information through the laws of the foreign jurisdiction.
We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete.
SAFEGUARDING PERSONAL INFORMATION
We protect the personal information in our custody or control by making reasonable physical, organizational and electronic security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
We will take reasonable measures, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services.
Note that confidentiality and security are not assured when information is transmitted through email or other wireless communication.