We respect you, our customer, and understand that you are concerned about privacy. We would like to share with you what kind of information we collect, how it is handled, and with whom it may be shared.
We are committed to being transparent on how we collect, use and protect your personal information. The data controller is Simply Languages Ltd (referred to in this policy as "we", "us" or "our"). We want you to be confident that the personal information you give us is safe and secure with us, and understand how we use it to offer you a better and more personalised experience on our Site.
the personal information we collect;
how and why we collect and use your personal information;
why we process your personal information;
when and why we will disclose your personal information to other organisations;
the rights and choices you have when it comes to your personal information;
the steps we take to ensure your information is kept secure and confidential;
how long we will hold your information for; and
how to contact us.
Some of these links are affiliate links. These are links which take you directly or indirectly to another product or service provider. If we receive a fee or commission as a consequence of you clicking through to its site or purchasing a product from it we will openly disclose this fact. When we endorse an affiliate we have tested their product ourselves so that our recommendations are always genuine.
2. Personal information we collect
When you register for SimplyGerman.online's newsletter you must provide us with your email address, your first name, and your current level of German.
When you register to use our German Academy, you may provide us with:
Your personal details, including without limitation your name and title, postal and billing addresses, email addresses, credit card or PayPal details, date of birth.
When you register to become a client on SimplyGerman.com or SimplyLanguages.com, you may provide us with:
Your personal details, including without limitation your and your company's name, your title and your job title, your and your company's postal and billing addresses, email addresses, phone numbers.
When you register as a participant in our Forum you may provide us with your email address and IP address.
When you visit our Site we may collect information about your online browsing behaviour and any devices you have used to access our Site (including your IP address, browser type and mobile device identifiers)
3. How we collect and use your personal information
3.1. SimplyGerman.online newsletter
We collect your email address, your first name, and your current level of German when you register to receive SimplyGerman.online's newsletter. We use this to send you the newsletter at the right level of German for you and to address you in a personalised manner inside the newsletter. This is usually weekly, but on occasion we may send a special edition when we have something really important to share with you.
3.2. The German Academy
We may collect your personal information such as your name and title, postal and billing addresses, email addresses, credit card or PayPal details, and date of birth. We use this to address you in a personalised manner, to bill you for our services, to email you relevant information such as how to access the Academy, your progress inside the Academy, new material available, renewal dates and costs, and other necessary or highly relevant information. We also use this information to protect ourselves from fraud and to ensure that all our clients are of the legally required age appropriate for the content of the German Academy.
3.3. Clients of SimplyGerman.com or SimplyLanguages.com
We need to collect certain personal information from you when you become a client of our language tuition services such as your and your company's name, your title and your job title, your or your company's postal and billing addresses, email addresses, and phone numbers. We use this information to address you in a personalised manner; to email, phone, or text you to arrange lessons with you, to customise the content of your lessons to the specific requirements of your job, and to bill you or your company for our services.
We collect and use your email and IP address to enable you to post on our Forum. We use your email address to send you your password to enable you to log in to our Forum and to send you email notices if you have elected to receive them. We also use your email and IP addresses for admin, troubleshooting and investigatory purposes.
3.5. Internal reporting, insight and analysis
We may also use the personal information referred to in this section 3 to generate aggregated, anonymised data for the purposes of internal reporting, insight and analysis, enabling us to improve and personalise our Site, the products we offer and search results for our Site. Where necessary this exercise may be carried out on our behalf by a third party – please see section 5 below.
We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law (see section 10 below).
4. Why do we process your personal information?
We will only collect and use your personal information (as described in sections 2 and 3) in accordance with data protection laws. Our grounds for processing your personal information are that you have asked us to provide our products and services for you, such as our newsletter or German Academy.
Furthermore, we may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under European privacy laws there is a concept of "legitimate interests" as a justification for processing your personal information.
Our legitimate interests for processing your personal information are:
4.1 to enable you to access and use the Site and our services;
4.2 to communicate with you about your use of our services. For example, sending you a confirmation email, or updates on new content available inside the German Academy.
4.3 to send you information on new products and services available from us
4.4 Affiliates: We may also occasionally send you information about affiliated products or services, genuinely tested and endorsed by us. If we receive a fee or commission as a consequence of you purchasing their product we will openly disclose this fact. These kinds of emails will be very occasional only.
These affiliates will never be given any of your personal information. So they will never be abled to contact you, you would have to contact them through the information we provide in our emails.
4.5 to improve our Site. We may use your personal information to undertake demographic segmentation and generate profiling information to help us understand what you might be interested in and for market research. We are always working to make a better Site for you and using your personal information in this way helps us to do this.
From May 2018, you will have a right to object to our use of your personal information for these legitimate interests, including a right to object to profiling by us (see section 6 below).
5. Disclosure of your personal information to other organisations
The personal information that we collect when you use our Site is confidential. We may disclose your personal information to a third party in the following circumstances:
5.1. Our service providers
5.1.1. Wix.com and WordPress who host our Sites, provide templates for our Site pages, as well as apps we use on our Site (which are designed internally by their own teams, or externally by other providers).
5.1.2. Mailchimp, our email provider and newsletter distributor.
5.1.3. Xero, our accountancy, bookkeeping, and invoicing system. This system will hold your name, address, email address, billing information, payment history on file.
Our technical partners will not be permitted to use your personal information for their own marketing purposes unless you have consented to receive marketing from them on another site, as we won't ask for your permission to do this on our Site.
5.2. If required or permitted to do so by law
5.3. If required to do so by any court, the Financial Conduct Authority or any other applicable regulatory, compliance, governmental or law enforcement agency
5.4. If necessary in connection with legal proceedings or potential legal proceedings;
5.6. If offending Forum users' actions appear to amount to a crime we will report them to their ISP or to the authorities.
6. How you can change permissions
All emails or other forms of communication directly from us to you will include clear instructions on how to unsubscribe. Plus, if you don't want to be contacted by us anymore you can email SimplyGerman@SimplyGerman.online or info@SimplyGerman.com or
Section 7 below also sets out your other information rights.
7. Your information rights and responsibilities
7.1. You already have certain rights under existing data protection legislation, including a right to request a copy of the personal information we hold on you, if you request it in writing. From 25 May 2018 you will have the following rights:
7.1.1. Right to correct:the right to have your personal information rectified if it is inaccurate or incomplete;
7.1.2. Right to erase:the right to request that we delete or remove your personal information from our systems;
7.1.3. Right to restrict our use of your information:the right to 'block' us from using your personal information or limit the way in which we can use it;
7.1.4. Right to data portability:the right to request that we move, copy or transfer your personal information;
7.1.5. Right to object:the right to object to our use of your personal information including where we use it for our legitimate interests, or where we use your personal information to carry out profiling to inform our market research and user demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we're continuing to process your personal information.
We will use reasonable efforts consistent with our legal duty to provide you with your rights in accordance with data protection legislation.
7.3. If you're not satisfied with the way any complaint you make in relation to your personal information is handled by us then you may be able to refer your complaint to the relevant data protection regulator. In the UK, this is the Information Commissioner's Office.
Please visit www.allaboutcookies.org for more information about cookies and specifically, how to disable them http://www.aboutcookies.org/how-to-delete-cookies/
8.4. The majority of web browsers automatically enable cookies as a default setting. To stop cookies being stored on your computer in future, you'll need to alter the settings of your internet browser. You can find instructions on how to do this at AboutCookies.org.
For Google Analytics cookies you can also stop Google from collecting your information by downloading and installing the Google Analytics Opt-out Browser Add-on.
9. Keeping your personal information secure
9.1. The vast majority of the personal information we hold about you is stored in the Cloud by our various service providers such as Wix, WordPress, MailChimp, Xero, Dropbox, and Evernote. As such, the personal information we collect from you may be transferred to and stored in countries outside of the European Economic Area ("EEA"). Different countries have different data protection and security laws and some of these do not offer the same level of protection as the UK.
9.2. We do our best to keep the information you disclose to us secure. However, we can't guarantee its security. By using our Site you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.
10. How long do we keep your personal information?
11. How to contact us
Our Data Protection Officer is Simply Languages Ltd's Director of Studies.
If you have any queries relating to our use of your personal information or any other related data protection questions, please email SimplyGerman@SimplyGerman.online or info@SimplyGerman.com or info@SimplyLanguages.com, or write to the Data Protection Officer at Simply Languages Ltd, 268 Norwood Road, London SE27 9AJ, England, UK.
Effective as of 22 April 2018