It is EMPIRE STATE ENGLISH’s policy to respect your privacy regarding any information we may collect from you or which you may provide to us, in the circumstances set out below.
We will only collect and use your Personal Data where:
- we have lawful grounds to do so, including to comply with our legal obligations;
- we are performing a contract with you for our services; and
- we have legitimate interests in using your Personal Data and your interests and fundamental rights do not override those interests.
For the purposes of the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”), we,
EMPIRE STATE ENGLISH, are the “data controller”. If you have any questions about this policy or about how we use your Personal Data, please contact us via our contact details at the end of this policy.
- Personal Data we collect via our website www.esenglish.org (the “Website”)
Personal Data that you provide to us
We only collect Personal Data where you choose to interact with us on the Website in the following ways:
|Activity||Types of Personal Data Collected|
|When you sign-up to receive updates on upcoming classes and events:||• Email address
• English level
• Whether you’re a local resident or an international student
|When you register for a class directly from us:
• Email address
• Phone number
• Any Personal Data which you provide to us on our Enrollment Agreement
• Payment method choice (payment details are held by our payment processor, not us)
|When you complete the inquiries form:||• Name
• Email address
• Phone number
• Any Personal Data which you provide to us in the free text box of the form
Data that we collect automatically
We automatically collect certain information when you visit our Website – such as the type of browser and operating system you are using, and the domain name of your Internet service provider. We do not link this information with any Personal Data.
- Use of your Personal Data
We will only use your Personal Data when the law allows us to. Most commonly, we use your
Personal Data to:
- process and manage your use of our website;
- respond to your questions, comments, and requests;
- where you have opted-in to receive marketing from us, deliver communications that are relevant to your preferences / may be of interest to you;
- improve our services and Website through analysis of information.
- Sharing of your Personal Data
We take your privacy seriously and will not share your Personal Data with others, except as permitted by applicable law or as set out below:
We share Personal Data as necessary with third parties who provide services or functions on our behalf and who require the information to provide those specific services to us. These third parties may include social media advertising platforms such as Facebook and Google Adwords for the purpose of custom audience generation and the development of targeting criteria for other audiences. These third parties may include our CRM (Customer Relationship Management) software, and our accounting software. Please note that we have appropriate data privacy safeguards in place with third parties with whom we share Personal Data as described above and who are providing services or functions on our behalf.
- Keeping your Personal Data secure
We have implemented security policies and technical measures to safeguard the Personal Data we collect. We maintain physical, electronic, and procedural safeguards that comply with applicable law, including the GDPR, to safeguard Personal Data from accidental loss, destruction or damage, and unauthorized access, use, and disclosure.
- Retention periods for use of your Personal Data
This Website is aimed at adults, and we do not knowingly collect any Personal Data relating to children aged under 15 years old. If you are under the age of 15, please do not provide us any of your Personal Data, including your email address.
- Access to and control over your Personal Data
You have legal rights under applicable law in relation to your Personal Data. You can ask the following questions, or take the following actions, at any time by contacting us via email [firstname.lastname@example.org] or via our postal address: 24 Aviation Road, Suite 100, Albany, NY 12205
- see what Personal Data we hold about you (if any), including why we are holding it and who it could be disclosed to;
- ask us to change/correct your Personal Data;
- ask us to delete your Personal Data;
- object to the processing of your Personal Data;
- ask us to restrict the processing of your Personal Data;
- withdraw any consents you have given us to the processing of your Personal Data; and
- express any concerns you have about third parties’ use of your Personal Data.
- Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to have an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
- Contact Us
Our full details are: EMPIRE STATE ENGLISH
Email for Privacy Questions: email@example.com
Postal Address: 24 Aviation Road, Suite 100, Albany, NY 12205