[last updated June 2018]
We take your privacy seriously and we have drafted this policy to let you know what information we collect about you, what we do with it, how we store it and what your rights are.
‘Personal information’ is information that directly identifies you, such as your name and email address, or data that could be used, on its own or in combination with other data, to identify you.
In general, we only use your personal information for the delivery of our services and to send you information about our services. We never sell or giveaway your personal information.
1. Staying Anonymous
You can browse our online services anonymously. However, if you request information or sign up for/purchase a subscription or free lesson, you will need to identify yourself and at that point we will start collecting your personal information. If you do not give personal information to us, it will affect our ability to provide you with requested information or to deliver our products or services.
2. Collecting personal information
At all times we aim to only collect the minimum information we need for the services we are providing. For example, if you sign up to a free lesson, we will collect and use your email address. As you would expect, the more involved you are with us, the more information about you we will collect.
The main way we collect information about you is when you give it to us and this can happen in a variety of ways.
We may process the following categories of personal information about you:
- Communication data: which includes any communication that you send to us. This might be when you request a free lesson, join our mailing list or when you contact us through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. If you sign in using social media, we receive (by your consent) additional information such as your profile picture and social profile ID. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data: which includes data you give to us when you purchase goods and/or services from us including any of our courses. This will include basic information about you and also the information we require for billing purposes such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details (last digits only). We use third party services for processing payments such as PayPal and Stripe and we do not receive or store your full card payment information. We process this data to supply the goods and/or services you have expressed an interest in or purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract and our legitimate business interest of keeping records for accounting purposes.
- User Data: which includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data: which includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We also use our own cookies for functions such as checking if you are logged in and which products you have access to. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- We may also use your personal information to carry out some automated decision making about you. For instance, our email manager may monitor which mails you open and use this information to automatically manage future emails you receive. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services and to grow our business.
3. Collecting information from third parties
As discussed above, we collect personal information about you when you give it to us and when it is collected by our website however we may also collect personal information that is given to us or available to us by a third party (for example, information that you have made available on a public platform like a discussion site).
We may receive data from third parties such as analytics providers and advertising networks like Google and Facebook.
This information forms part of the personal information described in this policy. We will not intentionally collect personal information that is unintentionally disclosed.
4. Collecting sensitive information
We do not intend to collect sensitive information about you and request you never disclose information about your health, racial or ethnic origin, political opinions, religious beliefs or sexual orientation on our website or any blog or social media account associated with our website or business. If you do post this information on any of our platforms (for instance you might accidently tell someone in a discussion that you ethnicity is Korean), we will not intentionally store this information on our file however it may be stored on the platform you posted it on and we have no control over such storage.
5. Children’s privacy
Our services are not designed to be used by minors under the age of 18 and we do not intend to collect information about such minors. If you have a child who you would like to use our services, you will need to set up an account in your own name and then supervise their access to your account. We will make reasonable endeavours to delete any details of users under the age of 18 years where a parent or guardian has notified us that any such details have been obtained. By providing us with your data, you warrant to us you are over the age of 18.
If you provide us with a review or testimonial, you give us your consent to use your name, likeness, web address, product you are reviewing and the date of service delivery to be displayed on our website or in our other marketing material, together with the content of the testimonial that you provide. If you provide your review or testimonial by YouTube clip, you also give your consent for us to use this. We may store and/or use your review for as long as the information is relevant to our business. We process this information based on your consent which you may withdraw.
7. Marketing Communications
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). Sometimes we may recommend sharing your information with a third party for their marketing purposes. Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. You can also email us as [email protected] to request your details be removed from our marketing list.
If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided for other transactions such as purchases.
8. Social Networking Services and links to other websites
You can connect with us via our social media pages for example on Facebook, YouTube and Twitter in accordance with our Rules of Conduct for Social Media. We may also provide links to other websites or use social networking services to communicate with the public about our work.
When you communicate with us using these services we may collect your personal information. The social networking service will also handle your personal information for its own purposes and have their own privacy policies. You should become familiar with the privacy policies of any service you use.
We use a range of tools provided by third parties including our website host, third party service providers and search engine browsers to collect or view access and traffic information for statistical, reporting and maintenance purposes. Third party providers have their own privacy policies. We also may also use tracking pixels, cookies and session tools to improve your experience when accessing our online services.
The data collected by cookies does not usually identify you but may be combined with other information to identify you. If we identify you using information from cookies, we may use that information to track how you use our online services and send you information more specific to your needs, or to invite you to purchase our services.
The kind of information that can be collected includes:
- device specific information such as mobile network information
- server logs including your IP address, the times you use our services and system activity
- location information including IP address, GPS, and Wi-Fi access points
- local storage availability
We use the information to help to track your use of our online services to improve your user experience and the quality of our services.
10. Use and disclosure of personal information
In summary, as a legitimate business interest, the personal information we collect about you is used:
- to verify your identity
- to enable you to use our services
- to process orders, subscriptions and enquiries
- to provide you with information about products and services that may interest you
- to provide you with personalised service or special opportunities
- to allow you to participate in interactive features of our online services
- to run competitions, prize draws, and promotions (if any)
- to facilitate our internal business operations
- to improve our products or services and in planning new products or services
- to conducting market research surveys in relation to our services
- to monitor compliance with our terms and conditions
With your consent or at your request we may:
- Share your contact information with third party organisations who offer products or services that may be of interest to you (if you agree to receive such information)
We may also disclose your information to:
- Other companies in our group who provide services to us.
- Payment third parties if there is a dispute over a payment. For example, if PayPal contacts us regarding a dispute over a payment, we will provide PayPal with user activity information such as IP address, course enrollment and activity linked to the IP address, billing details on our system etc to allow the payment dispute to be resolved.
- Professional advisers including accountants, lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing activities.
- Third parties where we are required to in accordance with the law and reserve the right to fully co-operate with any law enforcement authorities or court order requiring or requesting us to disclose the identity or other usage details of any user of our online services, or in accordance with a properly executed court order, or as otherwise required to do so by law.
11. Security and overseas recipients
We are committed to ensuring that your information is secure to industry standards however no system can be 100% secure and, provided we have acted in accordance with this policy, we are not responsible for loss you may suffer should your personal information be unlawfully accessed.
Using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. For example, our hosting and storage are managed by Digital Ocean who have their datacentres in The United States of America and certify to the EU-US security shield. Not all countries have the same level of privacy protection as the country within which you reside. You acknowledge and agree to our processing of personal data across international borders in this way. We will do our best to ensure your data is protected to a similar standard as set out in this policy by using third party providers with similar privacy protections.
We will also take reasonable steps to protect all personal information within our direct control from misuse, interference, loss, unauthorised access, unlawful or accidental destruction, modification or disclosure. To prevent unauthorised access or disclosure we use respected hosting services, firewall and other electronic security procedures and managerial procedures to safeguard and secure the information we collect from you.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
All hard copy records we keep are stored in Korea.
12. Opt-out/ unsubscribe
We will provide you with the opportunity to opt-in to receive information about our products or services. You can change your preferences at any time using the unsubscribe options in the emails you receive.
If you would like to delete your account with us you may do so by contacting us at [email protected] and requesting your account and non-transaction data be deleted. Please note that this will not delete all personal information from our system as we retain your information in other areas. For example, we will still retain your purchase history and transaction data.
If you continue to receive communications you have unsubscribed from, please contact us via email at [email protected] and we will remedy the problem.
13. Data retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, and if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for some time even after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
14. Third Party Links
Our website(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
16. Accessing and correcting your personal information – Your legal rights
Under data protection laws you have rights (depending on your country of origin) in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at [email protected] for assistance.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. For record keeping purposes, we will record and store all information exchanged during an exercise of your rights under this clause.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you request to have your information erased (also known as the right to be forgotten), we will, if appropriate, delete your personal information from our active business operating system. Your personal information will however continue to be stored within our backup(s) as we are unable to delete specific items from our backup. It will be deleted at the next scheduled backup deletion. We will keep a log of your request to be forgotten so that, should our backup be used to restore our operating system while your personal information is still stored, your personal information will again be removed from our active system upon restoration.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office in your country. For instance, in the UK contact the Information Commissioner Office at www.ico.org.uk. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.