Privacy Notice

INTRODUCTION

This privacy notice provides you with details of how I collect and process your personal data through your use of my site www.virtuallygerman.co.uk and www.talkingerman.co.uk.

If you need to email me about anything related to this privacy notice, you can email me at barbara@virtuallygerman.co.uk or you can write to me at 45 Chieveley Drive, Tunbridge Wells, Kent, TN2 5HQ.

From time to time we may email you to check that the personal data we hold for you is accurate and up to date.

Please email me at the above email address and let me know if how it any of your personal information has changed.

WHAT PERSONAL DATA WE COLLECT ABOUT YOU

We may collect the following data about you:

• Your name
• Your email address
• Your social media handle
• Your phone number
• Your address
• Your business name
• Any personal data you post on our website
• Your date of birth
• Your financial details
• Data about how you use our website
• Technical data 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
• Any other information that you directly provide to me whether through our contact form, over the phone, by email or otherwise, such as during a coaching session, when completing a survey or entering a competition
• Your marketing and communication preferences
• Photographs of you at events
• CV and application forms
• Credit information from third parties

HOW WE MAY USE YOUR DATA

We will use your data in order to:

• Enable me to perform a contract with you and process orders, respond to enquiries related to the order and deal with complaints
• Reply to any enquiries you make about our products or services
• Send you customer communications about enhancements to products or services you have bought
• Process financial transactions to enable you to purchase our goods our products or services
• Keep records of orders placed and communications in relation to such orders
• Keep records of communications
• Manage our business
• Send you marketing communications where we are allowed by law to do so
• Personalize your experience on our websites
• Monitor the use of our website and online services
• Ask you to complete surveys or invite you to enter into competitions or prize draws
• Deliver relevant website content and advertisements to you
• Analyse your use of our website and other online services
• Administer and protect our business and website
• Understand the effectiveness of our advertising
• Carry out credit checks
• Bring legal claims against you if you breach a contract or fail to make payment (we know you won’t….)
• Comply with any legal obligations we are subject to or as required by a government authority
• Obtain or maintain insurance policies
• Obtain professional advice

LAWFUL GROUND OF PROCESSING

Under the UK General Data Protection Data Regulations, I am only legally able to process your personal data if I have a lawful ground for doing so.

The lawful grounds of processing are:

• In relation to Prospect Data that I have obtained when you enquired about our products or services (whether that be through our website or otherwise) and that I process in order to reply to your enquiry and keep records of this, the processing is necessary in order to take steps at your request prior to entering into a contract and for legitimate interests in record keeping and to establish, pursue or defend legal claim
• In relation to Prospect Data that I have obtained when you signed up for any of our free resources and that I process in order to send you those free resources, reply to your communications about the resources and to keep relevant records, you have given consent to the processing for the purposes of me sending you the free resource and it is in my legitimate interests to reply to your communications and to keep records for my business.
• In relation to Customer Data that I have obtained in relation to you placing an order with me that I hold for the purpose of fulfilling that contract, informing you about updates to the product or service and keeping records of the contract, the processing is necessary for the performance of a contract to which you are subject and for legitimate interests in informing you about updates to the product or service, record keeping and to establish, pursue or defend legal claim as responsible business operations
• In relation to User Data that we have obtained through cookies on the website or other online services for the purposes of operating my website, ensuring relevant content is provided to you, ensuring the security of my website, maintaining back- ups of my website and/or databases and to enable publication and administration of my website, other online services and business, the processing is necessary for the purposes of legitimate interests which in this case are to enable me to properly administer my website and my business.
• In relation to Marketing Data that I have obtained when you told me your marketing preferences, when you consented to me sending you details of my products and services, for the purposes of sending you marketing communications, enabling you to partake in promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising, the processing is necessary for my legitimate interests which in this case are to study how customers and users use our products/services, to develop them, to grow my business and to decide my marketing strategy.
• In relation to Technical Data (that 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 my website, page views and navigation paths, details about the number of times you use my website, time zone settings and other technology on the devices you use to access my website), we process this data to analyse your use of my website and other online services, to administer and protect my business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of my advertising. Our lawful ground for this processing is my legitimate interests which in this case is to enable me to properly administer my website and my business and to grow my business and to decide my marketing strategy.
• In relation to your data that I process in order to comply with legal requirements or as required by a government authority, the processing is necessary for compliance with a legal obligation to which I am subject.
• In relation to keeping records, this processing is either necessary for compliance with a legal obligation that I am subject to or for my legitimate interests in responsible business operations or defending, pursuing or establishing a legal claim.
• In relation to obtaining professional advice and insurance, this processing is necessary for my legitimate interests in order to protect and grow my business.

In my capacity as a language coach you may freely give me Sensitive Data about you. Sensitive data refers to data that 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. Sensitive Data collected as part of my language coaching will be treated confidential.

I do not collect any information about criminal convictions and offences.

I do not carry out automated decision making or any type of automated profiling.

HOW WE COLLECT YOUR PERSONAL DATA

I may collect data about you by you providing the data directly to me (for example during language coaching sessions, by filling in forms on my site or by sending me emails). I may automatically collect certain data from you as you use my website by using cookies and similar technologies. Please see my cookie policy for more details about this at www.virtuallygerman.co.uk.

I may receive data from third parties such as analytics providers such as Google based outside the UK, advertising networks such as Facebook based outside the UK, such as search information providers such as Google based outside the UK, providers of technical, payment (PayPal based outside the UK) and delivery services, fraud detection agencies and data brokers or aggregators.

I may also receive data from publicly availably sources such as Companies House and the Electoral Register (or their equivalents) based inside or outside of the UK.

MARKETING COMMUNICATIONS  

Lawful ground of processing your personal data to send you marketing communications is either your consent or my legitimate interest (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, I may only send you email or text marketing communications if (i) you made a purchase or asked for information from me about my goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, I may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from me at any time.

Before I share your personal data with any third party for their own marketing purposes I will get your express consent.

You can ask me or third parties to stop sending you marketing messages at any time by emailing me at Barbara@virtuallygerman.co.uk. I also have unsubscribe buttons on the bottom of all of my emails.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

DISCLOSURES OF YOUR PERSONAL DATA

I may have to share your personal data with the parties set out below:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, accountants, auditors and insurers.
• Government bodies that require me to report processing activities or otherwise disclose your personal data.
• Market researchers and fraud prevention agencies.
• Third parties to whom I sell, transfer, or merge parts of my business or my assets.

I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions.

INTERNATIONAL TRANSFERS

I share your personal data within my group of companies which involves transferring your data outside the UK.

I am subject to the provisions of the UK General Data Protection Regulations that protect your personal data. Where I transfer your data to third parties outside of the UK, I will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

• I may transfer your personal data to countries that the United Kingdom authorities have approved as providing an adequate level of protection for personal data by; or
• If I use US-based providers that are part of a privacy framework (such as the successor to the US Privacy Shield), I may transfer data to them, as they have equivalent safeguards in place; or
• Where I use certain service providers who are established outside of the UK, I may use specific contracts or codes of conduct or certification mechanisms approved by the United Kingdom authorities which give personal data the same protection it has in the UK.

If none of the above safeguards is available, I may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

DATA SECURITY

I have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation.

I have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if I am legally required to.

DATA RETENTION

I will only retain your personal data for as long as necessary to fulfil the purposes I 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, I look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires me to keep basic information about my customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances I may anonymise your personal data for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under data protection laws you have rights 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.

You can see more about these rights at:

//ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email me at Barbara@virtuallygerman.co.uk.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up the response.

I try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, you will be notified.

If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues www.ico.org.uk. I would be grateful if you would contact me first if you do have a complaint so that we can try to resolve it.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.virtuallygerman.co.uk/policies/cookie-policy.