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Privacy Policy
This is the general privacy policy for Instill Education Ltd., and for a range of services we offer through this website and our individual application pages (web pages).
Instill Education Ltd. is a group of language schools owned by OISE Limited.
At Instill Education Ltd we collect different types of information about our customers for four main reasons:
1. To provide personalised services unique to individual users;
2. To help us monitor and improve the services we offer; 3;
3. To keep customers up to date with the courses and services they have purchased or subscribed to;
4. To fulfil our contracted services.
Some of our courses may have their own specific privacy policy, because the courses we offer in that case are different. Please check this when you register or sign up and make sure you are aware of how your data will be treated.
To make this policy easier to read, here is a list of the sections it covers:
1. About us
2. Register as a subscriber
3. Other uses of your data
4. Updating your personal information
5. Who we share your information with
6. How we use cookies
7. About our advertising
8. Legal information and how to contact us
9. Changes to the Data Protection Policy
1. About us
1. Protecting your privacy and personal information is important to us. We ensure not only that we have appropriate security measures in place, but also that any other organisation or third party we work with to provide a service meets our same standards.
2. We will respect your privacy. You should receive our informational emails only from us. We will ensure that the boxes you must tick if you wish to receive marketing information are presented clearly and in a timely manner.
3. We will explain clearly at the time we ask for your information what we are collecting it for and how we will use it.
4. We will collect and use your personal information only if we have your permission, or if we have appropriate business reasons for doing so, such as having sufficient information to manage your course booking.
5. We will minimise the amount of information we collect from you to what we need to deliver the course and any ancillary services you have requested (e.g. accommodation, travel, private car services, etc.).
6. In our dealings with you we will make it clear to you what information we will collect from you and how we will use it.
7. We will use personal information only for the purpose for which it was originally collected and we will ensure that it is disposed of securely.
8. Our web pages are accessible via the Internet. Please remember that if you post any comments or links on any of our pages, anyone can read and access them.
9. If we, or our partners, transfer any information outside the European Economic Area (EEA), this will only be done with the relevant legal instruments or permissions in place.
What information do we collect about you and how do we use it?
We collect information about you:
– When you register for a course (including live streamed events).
– When you contact us to request information
– If you work with us for business purposes
– When you subscribe to a newsletter
– When you subscribe to a magazine, either in print or digital format
– When you download an application
– When you use web pages that make use of Cookies
– If you choose to disclose information when you participate in our social media channels
– When you fill in your details in questionnaires for research purposes, and
– When you participate in promotions and competitions.
Certain services we provide may involve us collecting additional information (your location, allergies, etc.), so that we can personalise the advice we give you. This may also apply to certain applications that you download or that we provide to you.
What legal basis do we use for processing your data?
We use different legal bases depending on the purpose of collecting your data in the first instance.
– For all data collected when you register for a course, or when you request information about courses, we process personal information using Legitimate Interest, i.e. you can access an extensive amount of information in exchange for providing your personal data, and we maintain a link where the balance of benefits is in your favour. Thus, you always have a choice in the handling of your data and can opt out at any time.
– In the event that you provide us with data during the purchase of a course, we will process your data under the Contract, such information being necessary for the fulfilment of the service. Any additional contact, such as informing you about another course with similar characteristics to the one you have chosen, is handled on the basis of Legitimate Interest.
– Any secondary processing of your data, such as sharing it with third parties involved for the duration of the course, such as host families, etc., is handled under Consent.
In accordance with the terms of current data protection legislation, we will always provide you, as far as possible, with an opt-out from unwanted processing, provided that this does not restrict our ability to provide you with the course and service you have requested.
Profiling
In certain circumstances we may use certain elements of the information you have provided to target the messages we send to you according to your interests. For example, we may use your location to send you information about an event taking place in the same country, or we may use your business type to send you relevant news.
No information is collected by entirely automated means and the rights and freedoms of the data subject are protected by appropriate measures.
i. How long do we keep your data?
Because we collect data for different purposes, we do not have a uniquely defined retention period. For each individual course and service we define a carefully evaluated period of time during which we retain your data.
After that time, the data is managed to ensure that it is a) deleted from our system, b) minimised and retained for legal reasons, or c) archived and kept on a global exclusion list that ensures that you do not receive unwanted messages from us.
2. Register as a subscriber
The minimum information we need from you to register you with Instill Education Ltd. is your name, phone number and email address. We will ask you further questions for the different services, including educational emails. Unless we tell you otherwise, you will be required to answer all questions for registration.
We will process the data collected in order to facilitate your registration on the basis of Legitimate Interest to deliver the course for which you have registered. We will also, on this basis, contact you from time to time to inform you about other relevant courses or services that we believe may be of interest to you. You always have the possibility to opt out of this at any time by contacting us at the number/email address at the end of paragraph 8.
3. Other uses of your data
With your permission, we may also send you emails from other parts of our organisation that we think may be of interest to you. At any time you can opt out of receiving these emails and unsubscribe.
We will never sell your data. We will only share your data with third parties in order to provide the course or service you requested.
Use of children’s data
We only collect or store personal information about children under the age of 16 in the context of booking a course. This applies to young people under the age of 16 where permission is obtained directly from an adult legal guardian to collect this information.
4. Updating your personal information
Under applicable data protection legislation, you have the right to amend, delete or restrict the processing of your data without undue delay.
You may also request access to the data we hold about you.
To do this, or to update your personal information, please contact our database manager at any time using the details given at the end of point 8.
5. Who we share data with
Your personal information may be shared with other schools within the Instill Education Ltd group. For example, where there is a direct cross over between courses and services.
We will not share your information with others for marketing purposes unless you have given us your consent. If we have your permission, we will only share your information with other schools within the Instill Education Ltd group.
We may access and disclose personal information in order to comply with relevant laws and governmental requests, operate the systems properly as well as to protect us and our users.
Any other organisation that accesses your information in the course of providing services on our behalf will be governed by strict contractual restrictions in order to ensure that they protect your information and comply with applicable data protection and privacy laws. We may also independently audit service providers to ensure that they comply with our standards.
We may also use service providers to help us operate these sites (or the services available on them), some of which may be based outside the EEA (European Economic Area) or in countries deemed appropriate by the ECDC (European Data Protection Supervisor).
6. Use of Cookies
We use Cookies for a number of reasons:
1. for statistical purposes to track how many users we have and how often they visit our websites. We collect information that lists which of our pages are visited most frequently, by which type of users and from which countries.
2. We use other organisations to collect anonymous user information, sometimes through Cookies and Web Beacons (information embedded in images that allow us to analyse how the website is being used, and the number of visitors).
3. Placing Cookies on your computer means that we can show you information that may be of interest to you, and allows us to monitor the number of times you see them and measure how effective the campaign has been.
4. We may use Flash Cookies to store your preferences for your player (e.g. volume, etc.). If we do not use them, you may not be able to view some video content.
5. You can disable Cookies, but if you do so, you may not be able to use all of the services on our websites and you may see more pop-ups and other advertising. This is because we will not be able to limit what you see through the use of Cookies. However, you will still be able to view our editorial content.
6. Any of our schools in Instill Education may use Cookies to suggest and deliver content that we think may be of interest to you.
For more information about Cookies and how to manage them, including how to disable them, please visit our Cookies page.
By using the sites you agree to the use of Cookies as described.
Google Analytics
We use Google Analytics on our pages for anonymous reporting of usage and for advertising on our pages. If you do not want Google Analytics to monitor your behaviour on our websites, please go to the following link:
https://tools.google.com/dlpage/gaoptout
7. About our advertising
We may share anonymous behavioural data with advertising partners. This may mean that when you visit other websites, you will be shown advertising based on your behaviour on one of Instill Education’s school websites.
We may also be able to show you advertising on our site based on your behaviour on other sites.
If you wish to opt out of online behavioural advertising, this does not mean that you will no longer receive advertising when you visit our websites, but it does mean that the advertising you see will not be personalised to your previous searches and visits.
We also sometimes use Google Adwords Remarketing and Similar Audiences, Linkedln Matched Audiences and Facebook Lookalike Audiences to advertise on third party websites (including the Google, Linkedln and Facebook advertising networks) to previous visitors to our site or users with similar interests. This may involve us advertising to previous visitors who have not completed a task on our site (for example, using the contact form to make an enquiry) or to users with interests like our previous visitors.
This could take the form of an advertisement on the Google search results page, on a page of the Google Display network or on Facebook and/or LinkedIn advertising networks. Third-party providers, including Google, LinkedIn and Facebook, use cookies to serve ads based on the user’s previous visits to the website. Of course, all data collected will be used in accordance with our own privacy policy and the privacy policy of the third party advertising networks.
If you do not wish to participate in Google Remarketing and Similar Audiences, you can change your Google Ads settings here: support.google.com/ads/
If you wish to opt out of online behavioural advertising, this does not mean that you will no longer receive advertising when you visit our websites, but it does mean that the advertising you see will not be tailored to your previous searches and visits. If you would like to learn more about this and how to opt out, please visit youronlinechoices.com or optout.networkadvertising.org (if accessing from the United States).
Advertising on mobile devices may require the collection and distribution of the unique device ID with companies that purchase advertising space on the mobile application.
8. Legal information and how to contact us
In accordance with applicable law, we have to say who is the ‘data controller’ for Instill Education Ltd. group products and services provided through our websites, our magazines, events and other products and services.
Instill Education Ltd. is the registered data controller under the Data Protection Act 1998. The data controller is the person responsible for the protection of the organisation’s information and in our case is Mr Nick Kenny.
If you would like access to, or a copy of the personal information we hold about you; to request a correction; if you have any questions about how we may use your data; to make a complaint or claim: please contact the data controller, Mr Kenny, by email at helpdesk@oise.com, or by telephone on +44 (0) 1865 258300.
Requests will be dealt with by the Data Administrator, and will be responded to within a reasonable period of time, not exceeding 30 days.
Information Commissioner’s Office https://ico.org.uk/ concerns/
Telephone: +44 303 123 1113
If you are dissatisfied with the way in which your request was handled, you have the right to lodge a complaint with the supervisory authority, details of which are provided below:
9. Changes to the Data Protection Policy
If we make changes to the Data Protection Policy, these will be recorded here. If these changes are significant, we may choose to email relevant individuals with relevant updates. If we are required by law to do so, we will obtain your consent to make such changes.
May 2018 – New company privacy policy creates