Last updated: September 29th 2021.
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’).
Any Personal Data you enter into our Websites is stored securely on our servers or our partners servers.
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.
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.
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.
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
If you use an affiliate integration tool (Rewardful or Refersion), it will tell which affiliate should be connected to the web session/sale.
Code of the country from the end-user, used for VAT purposes
The IP address of the end-user
Data about the device and web browser versions used by the end-user
Timestamp for the beginning of the cookies web session
Cookies web session is initialized.
This cookie is the token of the login session
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.
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
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.
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.
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 right to withdraw consent at any time
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.
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.
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.
Guide Education Ltd.,
Bryn Llewelyn, High Street,
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
Telephone: 0303 123 1113
Fax: 01625 524510