Enjoy’s Privacy and Cookies Policy
1.1 We are committed to safeguarding the privacy of our website visitors, clients and tutors.
1.2 In this policy, “we”, “us” and “our” refer to Enjoy Education Ltd. For more information about us, see Section 13. For the purposes of this policy we are acting as a data controller with respect to your personal data; in other words, unless we tell you otherwise, we determine the purposes and means of the processing of your personal data.
1.3 This policy aims to give you information on how we collect and process your personal data through your use of this website and more generally, including any data you may provide through this website when you make enquiries or where you engage us to provide any services for you.
1.5 This document was based on a template from Docular (https://docular.net).
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process.
2.2 We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you.
2.3 We may process your website user account data (“account data”). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website.
2.4 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.5 We may process data about your use of our website and services (“usage data”). The usage data may include your internet protocol (IP) address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
2.6 We may process data about your bank account and payment card details (“financial data”) that you send to us so that we may receive or send payments from or to you.
2.7 We may process data about your preferences in receiving marketing from us and our third parties and your communication preferences (“marketing and communications data”) so that we know what restrictions you wish to apply to the sharing of your data for marketing purposes.
2.9 We do not collect what is referred to in data protection law as “special categories of personal data” about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
3. How we collect your personal data
3.1 We use different methods to collect data from and about you and in this Section 3 we have set out some of those methods.
3.2 Direct interactions – You may give us your contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for or enquire about our services, create an account on our website, subscribe to our service or publications, request marketing to be sent to you, enter a competition, promotion or survey, or give us feedback or contact us.
3.3 Automated technologies or interactions- As you interact with our website, we will automatically collect communication and usage data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see section 6 below for further details.
4. Purposes of processing and legal bases
4.1 We will only use your personal data when the law allows us to. In this Section, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations – We may process your personal data for the purposes of operating our website, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4.3 Relationships and communications – We may process contact data, transaction data and communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, WhatsApp, post, and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, clients, tutors and other customers, the maintenance of relationships, and the proper administration of our website, services and business.
4.4 Direct marketing – We may process contact data for the purposes of creating, targeting and sending direct marketing communications by email, post, social media and / or telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our clients, tutors and service users. You can opt out of direct marketing at any time by unsubscribing from our newsletter or getting in touch with our team.
4.5 Research and analysis – We may process usage data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business.
4.6 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business and support our tutors and clients in accordance with this policy.
4.7 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.8 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4.9 Failure to provide personal data – Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
5. Providing your personal data to others
5.1 We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and obtaining professional advice.
5.3 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.5 We do not transfer your personal data outside the UK unless you ask us to.
5.6 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. Data security
6.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
6.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
7.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
7.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
8.5 We use Functional cookies to enhance your experience. A mixture of first and third-party cookies may be used to remember your preferences, for example your location or preferred language.
9. Managing cookies
9.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
9.2 Blocking all cookies will have a negative impact upon the usability of many websites.
9.3 If you block cookies, you will not be able to use all the features on our website.
10. Your rights
10.1 In this Section 10, we have listed the rights that you have under data protection law.
10.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
10.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
10.4 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. Alternatively, we could refuse to comply with your request in these circumstances.
10.5 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.
10.6 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below. We try to respond to all legitimate requests within one month. Occasionally it could 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 and keep you updated.
11.1 We keep this policy under regular review and may update it from time to time by publishing a new version on our website.
11.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
11.3 We may notify you of changes to this policy by email.
11.4 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
12. Third-Party Links
13. Our details
13.1 This website is owned and operated by Enjoy Education.
13.2 We are registered in England and Wales under registration number 5942726, and our registered office is at 1 Relton Mews, Knightsbridge, London, SW7 1ET.
13.3 Our principal place of business is at 1 Relton Mews, Knightsbridge, London, SW7 1ET.
13.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website;
(d) by email, using firstname.lastname@example.org; or
(e) by Whatsapp, on the contact number published on our website