Details of your association with DBM International Education and Immigration LLC  (e.g. whether you are a current student or an administrative user) will also be provided to the Platform Provider.

In addition, the Platform Provider may:

• Collect technical information in order to optimise and improve the Service. This might include internet protocol addresses details of your browser, device or connection type. This information will not readily or directly identify any particular user and it is collected in order to monitor how the platform is used and to optimise the way that information is presented.

• Anonymise personal data and technical data, and combine this information with anonymised information about other users. The resulting information will not identify any particular person and will be used for various purposes including research, development and marketing of the platform.

 

 

4. WHEN WE COLLECT PERSONAL DATA

We collect personal data about individuals who register for or use the Service or communicate with us. This includes information:

• Provided to us by end users of the Service (for example, by filling in registration forms).

• Generated or collected during the use of the Service.

• Information within correspondence (such as email signatures and metadata).

 

 

5. WHY WE COLLECT PERSONAL DATA

Your personal data is used for a range of purposes, which are summarised in the table in paragraph 3. These include:

• The personal data needs to be used to enter into or perform contractual obligations with you (including under the End User Licence Agreement). This includes administering your account so you can access the Service and use course content.

• The information needs to be used for our legitimate interests (or those of a third party, including the Platform Provider). These will be specific lawful interests, such as keeping proper records, the administration of our business and to maintain and improve the Service. We will only use personal data on this basis if our use is not outweighed by your own rights and interests.

• In limited circumstances, personal data may be used on the basis of your consent. In these cases your consent will always be clearly requested. You are, of course, free to refuse consent and you will be informed as to what (if any) consequences this might have. You can also withdraw consent at any time.

 

 

6. WHO HAS ACCESS TO YOUR PERSONAL DATA

Personal data you provide will be kept private and confidential and only used as set out in this policy. Any personal data provided or generated by your use of the Service will be available to us and our employees and contractors will be able to access information to the extent necessary for us to use it for the purposes explained earlier in this policy (such as providing you with access to the Service).

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Course tutors, teachers and coaches will be provided with an end user’s name. End users may also choose to provide additional information during the course of interacting with these persons in connection with their learning.

Unless specifically set out in this policy, your personal data will not be disclosed or shared with other data controllers without a proper lawful basis in accordance with data protection laws. For example, where disclosure is legally required, or in the event of a business sale or other corporate transaction which may transfer control of the Service or the platform, or if the sharing of personal information is required by regulatory authorities in the event of an audit or investigation.

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Some of the third parties who provide services to us may have access to your personal data. This includes software providers (such as Microsoft), cloud service providers and IT support services. However, these third parties will only process personal data (which may include your information) for specified purposes and in accordance with strict instructions.

 

Third-party service providers (such as providers of technical support services) are required to provide guarantees that your personal data will be kept safe and will have to enter into a written contract which protects your personal data and prevents it from being used for any unauthorised purpose.

 

 

7. HOW LONG WE STORE PERSONAL DATA FOR

Personal data is stored for as long as is necessary for the purposes described in this policy (or for related compatible purposes such as complying with applicable legal, accounting, or record-keeping requirements).

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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 its unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you delete your account, or your licence to access the Service is terminated or expires then DBM International Education and Immigration LLC  may retain information about your course progress; however, the Platform Provider will typically erase all information relating to you and your studies from the Platform within 6 months.

 

 

8. HOW WE KEEP PERSONAL DATA SAFE

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, damaged or destroyed, altered or disclosed. This includes both physical security measures (such as keeping paper files in secure, access-controlled premises) and electronic security technology (such as sophisticated encryption protocols, digital back-ups and anti-virus protection).

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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 legal and contractual confidentiality obligations.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of a breach when we are legally required to do so.

 

 

9. INTERNATIONAL TRANSFERS

We normally only store personal data within the European Economic Area (EEA). However, some of the technology and support services we use are provided by international organisations and/or companies which are based outside the EEA. Before using such service providers, we take steps to make sure that any personal data they process is adequately protected and transferred in accordance with Data Protection Laws, usually by one or more of the following methods:

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• Ensuring the recipient is in a country which the EU Commission has deemed provides adequate protection for personal data.

• Implementing appropriate safeguards such as requiring the recipient to enter into Standard Contractual Clauses approved by the appropriate data protection supervisory authorities.

 

The only other time we will transfer data outside the EEA is if a derogation (i.e. an exception) under Data Protection Laws has been permitted and the transfer is either necessary and made for the purposes of that exception or with your explicit consent.

 

 

10. YOUR RIGHTS AS A DATA SUBJECT

Data Protection Laws provide you with certain rights in relation to your personal data. These are as follows:

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• The right to access your personal data. This enables you to receive a copy of the personal data we hold about you.

• The right to request correction or completion of personal data. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• The right to request erasure of your personal data. This enables you to ask us to delete or remove personal data (though this may not apply where we have a good, lawful reason to continue using the information in question). You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).

• The right to object to processing of your personal data. You can object to us processing personal data on the basis of our legitimate interests or for direct marketing.

• The right to restrict how your personal data is used. You can limit how we use your information (which means we’ll restrict how we use the data so that it’s stored securely and will typically only be accessed in case of a legal claim).

• The right to have a portable copy or transfer your personal data. We will provide you, or (where technically feasible) a third party, with a copy of your personal data in a structured, commonly used, machine-readable format. Note this only applies to automated information which we process on the basis of your consent or in order to perform a contract.

• The right to withdraw consent. If we are relying on consent to process your personal data, you have the right to withdraw that consent at any time.
   

Responding: We try to respond to all personal data requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. Please also bear in mind that there are exceptions to the rights above and some situations where they do not apply.

We may need to request additional information from you to help us confirm your identity. 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 to clarify your request.

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Fees for making a request: You will not normally have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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How to make a request: If you want to exercise any of the rights described above, please contact DBM International Education and Immigration LLC at administration2educationdbm.com.

 

You can also contact the Platform Provider direct using the contact details in the next section. You have the right to complain to a data protection supervisory authority (which, in the UK, is the ICO) if you are not satisfied with our response to a data protection request or if you think your personal data has been mishandled. If you are in the UK, please visit https://ico.org.uk for further information.

 

 

11. WHO CONTROLS INFORMATION WE COLLECT

The Service is provided by DBM International Education and Immigration LLC  and partners a provider of language learning and educational services which can be contacted at administration@educationdbm.com and is registered as a data controller with the UK Information Commissioner’s Office with registration number ZA530952.

 

For the purposes of applicable data protection and privacy laws DBM International Education and Immigration LLC  and, the Platform Provider will each be controllers of your personal data, meaning we each make decisions about how and why we use your personal data and each have responsibilities to keep your data safe and ensure your rights are protected. DBM International Education and Immigration LLC and the Platform Provider have entered into a detailed written data sharing agreement to ensure that your personal data is kept safe and your rights under Data Protection Laws are protected.

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