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Privacy Policy


Guide Plus Privacy Policy and Notice


Last updated: September 29th 2021.



INTRODUCTION


Guide Education Limited (collectively, ‘Guide Education,’ ‘we,’ ‘our’ or ‘us’) has created an online learning platform and a variety of educational courses (collectively referred to as ‘Guide Plus’). Guide Plus online content is provided to individuals on a subscription basis (our ‘Services’).


This Privacy Policy applies to our website https://guideplus.co.uk/


and to any other websites or digital platforms created by us to deliver Guide Plus Services (collectively the ‘Websites’). Please note that this Privacy Policy does not cover any other websites or services operated by Guide Education.


Please read this Privacy Policy carefully together with our Terms and Conditions to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.


Personal Data


Guide Education is committed to ensuring the privacy of its customers, users, suppliers, employees and other stakeholders. It is important that you read this Privacy Policy carefully together with our Terms and Conditions to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.


Any Personal Data you enter into our Websites is stored securely on our servers or our partners servers.


By using our Website and Services you must be willing to be bound by the data practices described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, then we cannot make our Website and Services available to you and you should stop accessing and using them.


IMPORTANT INFORMATION AND WHO WE ARE


The data controller is Guide Education Limited a company registered in England and Wales under number 08571401 with its registered office at Bryn Llewelyn, High Street, Tywyn, Wales, LL36 9AD.


This Privacy Policy explains how we collect and use your Personal Data and is provided in accordance with our obligations under applicable privacy and data protection law, including the Data Protection Act 2018, the UK GDPR, and the Privacy and Electronic Communications Regulations 2003 (collectively the ‘Applicable Data Protection Legislation’).


For the purposes of this Privacy Policy, the term ‘Personal Data’ means any information which identifies you or which allows you to be identified when combined with other information. It does not include data where your identity has been removed (‘Anonymised Data’). For the purposes of Applicable Data Protection Law, Guide Education is a data controller processing personal data.


INFORMATION WE COLLECT AND HOW


Operation of Our Website and Services


When you use our Websites and Services, we may collect certain Personal Data, or personal information that can be used to identify you. Any data that does not enable you to be identified will not be considered Personal Data.


The information and Personal Data we collect includes the following categories:


Contact and Payment Information

- Your name;

- Your contact information including your email address;

- Your payment information; and

- Any correspondence that you send to us.


Device Information


When you use our Websites, we may automatically collect information on the type of device you use, operating system, resolution, application version, mobile device identifiers, language, time zone and IP address. For more information, please refer to the section on Cookies in this Privacy Policy.


Usage Information


We collect information automatically about your activity through the Websites, such as the date and time you use the Websites.


Location and Other Information


We may collect, with your consent, other information such as precise geolocation (latitude and longitude) using information including GPS, Bluetooth or Wi-Fi connections.


Information we obtain from third parties


We may receive information about you from our third party service providers, including Google Analytics, who collect this information through our Websites in accordance with their own privacy policies.


Aggregated Anonymised Data


The information we collect from you may be combined with information provided by others, but only in an anonymised format, to produce aggregated anonymised data sets for our internal commercial research purposes. We refer to this combined data as ‘Aggregated Data.’ Aggregated Data is not considered to be Personal Data as it does not reveal your identity.


Aggregated Data may be used for the operation of our Websites and Services, and to provide general statistics and analytics regarding use of our Services. We may also use such anonymised Aggregated Data and provide it to third parties for research purposes.

However, in the event that we combine or connect Aggregated Data with any of your Personal Data that enables you to be directly or indirectly identified, we will treat such data as Personal Data to be used in accordance with this Privacy Policy.


USE OF COOKIES AND GOOGLE ANALYTICS


Our Websites may use ‘cookies’ and similar technologies to enhance users’ experience when using the Websites. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. Our Websites use cookies and similar technologies to distinguish you from other users. This helps us to provide you with a good experience when you browse our Websites and allows us to improve our Websites. 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 the Websites may become inaccessible or not function properly.


We use Google Analytics. The information generated by the Google Analytics cookie (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our websites and/or services compiling reports on activity and providing other services relating to activity and internet usage.


Google may also transfer this information to third parties where required to do so by law, or where third parties process the information on Google’s behalf.

Strictly necessary cookies


The following cookies are referred to as ‘strictly necessary’ as they are essential for the operation of our Websites:


user_utm_source, user_utm_medium, user_utm_term, user_utm_content and user_utm_campaign


Please refer to the UTM parameters as documented inthis help guide.


user_referrer and referer


Both refer to the same item. It tracks the website where the customer comes from


affiliate


If you use an affiliate integration tool (Rewardful or Refersion), it will tell which affiliate should be connected to the web session/sale.


country_code


Code of the country from the end-user, used for VAT purposes


ip_address


The IP address of the end-user


agent


Data about the device and web browser versions used by the end-user


started_at


Timestamp for the beginning of the cookies web session


initialized


Cookies web session is initialized.


_uscreen2_session


This cookie is the token of the login session


JSESSIONID


The cookie stores a session identifier so that our infrastructure monitor can count the sessions for our web application. It is deleted when the browser closes.


Analytical cookies


_ga

_gat


These cookies are set by Google Analytics as part of its Analytics suite. These cookies monitor the performance of the Websites, for example in relation to visitor numbers, the duration of users’ sessions etc. For more information please refer to Google’s privacy policy: https://policies.google.com/privacy?hl=en


CHILDREN


We do not knowingly collect Personal Data from children, and our Websites and Services are not for use by anyone under the age of sixteen.


PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA


We may collect and use your personal information and Personal Data to operate our Websites and Services.


We will use your personal information for several purposes including the following:


- To open and manage your Guide Plus account;

- To process any payment due under your subscription;

- To provide our Services and Guide Plus content to you and for tailoring our Services to your requirements;

- For developing our Websites, Services, and Guide Plus content;

- To notify you of new products and services;

- To monitor your use of our Services;

- To respond to any communications from you;

- For market research purposes; and

- For marketing purposes in accordance with the Applicable Data Protection Law.


LEGAL BASES FOR USING YOUR PERSONAL DATA


The legal bases we rely upon to use your Personal Data to provide you with the Services is the contract we have with you, your consent and our legitimate interests, or where we need to comply with a legal or regulatory obligation. Please contact us if you require further details concerning the specific legal ground(s) we are relying on to process your Personal Data.


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 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.


We offer here non-exhaustive examples of the ways in which we use your Personal Data and the legal bases we may rely upon to do so:


- To provide our Services and access to our Websites to you, our legal basis for processing is the performance of a contract with you, which you entered into with us.

- To administer our Websites and Services (including troubleshooting, data analysis, testing, support, fraud, reporting and hosting of data), our legal basis for processing is the legitimate interests for running our business, and the provision of the Services.

- We may use your Personal Data if you apply for employment with us, processed under consent and then under contract if you become employed by us.

- We may also use your Personal Data to inform you of other products or services that we and/or our business partners provide. We may also contact you to conduct research about your opinion of our Websites and Services.


PURPOSES FOR WHICH WE WILL SHARE YOUR PERSONAL DATA


Sharing with our service providers and partners


We may share your Personal Data for certain purposes with our business partners or affiliates in accordance with Applicable Data Protection Law, as set out below:


- Financial service providers in order to process your subscription payments;

- IT service providers and system administrators;

- Data hosts and providers of programming or technical support;

- Professional advisers including lawyers, bankers, auditors, and business advisers;

- Third-party analytics partners to analyse website traffic and understand customer needs and trends or our third-party marketing service providers to help us to communicate with you.


For corporate transactions


We may transfer your Personal Data if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control.

When required by law

We may also share Personal Data if we are also under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.


To enforce legal rights


We may also share Personal Data: (i) If disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.


CROSS-BORDER DATA TRANSFERS


Sharing of Personal Data sometimes involves cross-border data transfers, including transfers outside of the EEA in accordance with the law. We only transfer Personal Data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this privacy policy and applicable law, for example under contractual provisions which have been deemed by either the UK Government or the European Commission to provide sufficient safeguards for Personal Data.


Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented.


DATA SECURITY


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.

All of your Personal Data and information will be securely stored in accordance with the Applicable Data Protection Legislation. We have put in place physical, electronic, and managerial procedures to securely store and safeguard your Personal Data and information that is uploaded to our Websites.


We limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. 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.


DATA RETENTION


We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will also retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.


Your Personal Data will be retained for at least five years. Your Personal Data will be reviewed regularly and at least once every year for relevance. Any Personal Data deemed no-longer relevant is deleted.


If we have taken steps to anonymise your personal data (so that it can no longer be associated with you) we may use this indefinitely for analytical, research and statistical purposes and to help us to improve our products and services.


YOUR RIGHTS


Your right to withdraw consent at any time


Whenever we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time. If you wish to withdraw your consent, please contact Guide Education using the contact details provided at the end of this privacy policy. This will not affect the lawfulness of any processing carried out before you withdraw, nor ongoing contractual or other obligations requiring us to process data for example due to a court ordered law enforcement request.


Your right to access the Personal Data we hold about you


You have the right to make a request to access your Personal Data (known as a “Data Subject Access Request” or “SAR”).


We aim to respond electronically to all SARs within one month. In circumstances where it may take us longer than one month to respond (for example if your request is particularly complex or if you have made a series of requests), we will notify you. We do not charge a fee for responding to a SAR. However, we may charge a reasonable fee if your SAR is manifestly unfounded or excessive.


Other rights


Right of rectification - You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.


Right to erasure – You have the right to ask us to erase your Personal Data in certain circumstances.


Right to restriction of processing – You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.


Right to object to processing – You have the right to object to the processing of your Personal Data in certain circumstances.


Right to data portability – You have the right to ask that we transfer your Personal Data to another organisation, or to you, in certain circumstances.


CHANGES TO THIS PRIVACY POLICY


We may occasionally update this Privacy Policy to reflect company and customer feedback and any changes in data protection regulations. We encourage you to periodically review this Privacy Policy to be informed of how we are protecting your information.


OPT-OUT & UNSUBSCRIBE


We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from us by contacting us or selecting the “Unsubscribe” option on their email.


CONTACT INFORMATION


Guide Education Limited welcomes your questions or comments regarding this Privacy Policy. If you believe that we have not adhered to this Privacy Policy, please contact us using the helpdesk contact form on our website here.


Guide Education Ltd.,

Bryn Llewelyn, High Street,

Tywyn,

Wales,

TW8 1DB,

United Kingdom.


Questions, comments and requests regarding this privacy policy are welcome and should be addressed to our address given above.


We ask that you try to resolve any issues with us first, although you have a right to lodge a complaint with the Information Commissioner's Office (ICO) at any time about our processing of your personal information.


The ICO is the UK regulator for data protection and upholds information rights. Guide Education Limited is registered with the ICO with registration number ZB224452.


Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF


Telephone: 0303 123 1113

Fax: 01625 524510