For the purpose of data protection legislation, the data controller is Smart Effective Learning and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
Full name of legal entity: James Granahan trading as Smart Effective Learning
Email address: email@example.com
Postal address: 34 Burnaby Mill Greystones, Co. Wicklow, Ireland
It is very important that the information we hold about you is accurate and up to date. If at any time your personal information changes, please let us know by emailing us at firstname.lastname@example.org.
What Information Do We Collect From You?
We collect and process the following data about you:
- Information you give us: This is information about you that you give us by filling in forms on our site or by corresponding with us by email or otherwise. It includes any communication that you send to us whether that be through contact or opt-in forms on our website, through email, text, social media messaging, social media posting or any other communication that you send us. The information you give us may include your name, address, email address, age, location and financial information in the event of a purchase. Please let us know if any of this information changes so we can keep our records up to date.
- Information we collect from your use of our site: With regard to each of your visits to our site we will automatically collect the following information:
- Technical information, such as the Internet protocol (IP) address used to connect your device to the Internet.
- The location where you connected to our service
- Your internet service provider (ISP).
- What type of device you are using to access our service
- Other online services information such as your login activity data, details about your browser and length of visit to pages on our website, page views and website navigation paths, details about the number of times you have used our website, your time zone settings and other information about the devices you use to access our website. The source of this data is our analytics tracking system.
- Information we collect throughout our relationship with you: This is information relating to products (free or paid) that you download or purchase from us.
- Marketing Information: This includes data about your preferences in receiving marketing from us and your communication preferences.
Note: We may use information you give us, information we collect from your use of our site, information we collect throughout our relationship with you, and marketing information to:
- Deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements)
- Measure or understand the effectiveness of the advertising we serve you
Our lawful ground for processing this information is our legitimate interests which are to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Why Do We Collect This Information?
We use this information in the following ways:
- Information you give to us or which we receive from other sources: We process this data for the purposes of communication with you, for record keeping and administration, and for the establishment, pursuance or defence of legal claims. Our lawful ground for processing this information is our legitimate interests, which in this case are to reply to communications sent to us by you, to keep accurate records and to establish, pursue or defend legal claims. We use this information:
- In order to take steps necessary to assess whether we can enter into a contract with you and in order to perform our contract with you. This includes carrying out our obligations to you and providing you with our, or a third party’s products and services;
- For the purpose of improving our service to you, to ensure that content from our site is presented in the most effective manner for you and for your device;
- To deal with any legal queries relating to your use of our service;
- To provide you with service communications so that we can perform our obligations to you. These may be sent by email. These will include notifications about changes to our service, event details and information about products that you have signed up to;
- To provide you with marketing communications including, with your permission, information about other goods and services we offer that are similar to those that you have already purchased or enquired about; or
- In our or a third party’s legitimate interests of keeping customers up to date with goods and services, increasing awareness of ourselves and third parties within the market, making promotional offers and generating new business, building and maintaining loyalty or market share.
- Information we collect from your use of the site: We process this data to analyse your use of our website and other online services, to administer and protect our business and website and to deliver relevant and interesting website content and advertisements to you, as well as to understand the effectiveness of our advertising and marketing strategies. Our lawful ground for processing this information is our legitimate interests which in this case are to properly administer our website and our business, to grow our business and to make decisions about our marketing strategies. We use this information for the following purposes:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you and for your device;
- As part of our efforts to keep our site safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
- Information we collect throughout our relationship. We process this data to supply the goods and/or services you have purchased from us or our affiliates and to keep records of such transactions. Our lawful ground for processing this data is the fulfilment of a contract between you and us and/or taking steps to enter into such a contract, at your request.
- Marketing Information: We process this data to enable you to participate in our promotions, competitions, prize draws and free give-aways, as well as to deliver relevant website content and advertisements to you and measure or understand the effectiveness of these advertising and marketing strategies. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services and website, to develop them, to grow our business and to make decisions about our marketing strategies.
How Do We Use Your Data For Marketing Communications?
Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if:
- You purchased or asked for information from us about our goods or services
- You agreed to receive marketing communications and you have not opted out of receiving these communications since.
We will not share your personal data with any third party for their own marketing purposes without first obtaining your express consent.
- You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any of our marketing messages or emails, or by emailing us at email@example.com at any time.
- If you opt out of receiving marketing communications this opt-out does not apply to personal data you have provided to us as a result of other transactions, such as purchases, event registrations etc.
How Long Do We Keep Hold Of Your Information?
We will keep information about you for a maximum of 6 years after the end of our relationship with you unless obligations to our regulators require otherwise or we are required to remove such data from our records.
In some circumstances we may anonymise your personal data for our research or statistical purposes, and in such cases we may use this information indefinitely without further notice to you.
Who Might We Share Your Information With?
We may have to share your personal data with the parties listed below:
- Service providers who provide IT and system administration services to us
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report on our processing activities.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets
- We require that all third parties to whom we transfer your data respect the security of your personal information and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
You agree that for the purposes set out in the ‘Why do we collect this information?’ section above, that we have the right to share your personal information with the aforementioned parties.
How Is Your Data Stored And Kept Secure?
At Smart Effective Learning we take your safety and security very seriously and we are committed to protecting your personal and financial information.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our services or products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access to your data.
We have in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to employees and partners who have a business need to access that data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any relevant regulator of any breaches if we are legally required to.
Transferring Your Data Outside Of The European Economic Area (EEA)
European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria due to the fact that countries outside of the EEA do not always offer the same levels of protection to your personal data.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
In such cases where it necessary for us to transfer your personal data out of the European Economic Area, we will do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data
- In cases where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give your personal data the same protection it has in Europe
- If we use US-based providers, we will use providers that are part of EU-US Privacy Shield, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
What Are Your Rights?
Where processing of your personal data is based on consent, you can withdraw that consent at any time.
You have the following rights. You can exercise these rights at any time by contacting us at the address above or by emailing firstname.lastname@example.org. You have the right:
- To ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes;
- To ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
- To request from us a copy of personal information held about you;
- To ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
- To ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate grounds for processing, the data is unlawfully processed or the data needs to be erased to comply with a legal obligation
- To ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing);
Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above.
You will not have to pay a fee to us to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee or refuse to comply with your request in these circumstances.
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 only disclosed to the person who has the right to receive it. We may also contact you to ask you for further information in relation to your request in order to assist us in providing you with a fast response.
We aim to respond to all legitimate requests within one month, however, occasionally it may take us longer than a month to fulfil your request if it is particularly complex or you have made a number of requests. In such a case, we will notify you.
In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority, at any time.
This enables us to understand your use of the site and track any patterns with regards how you are using the site. We use this information to help us to develop and improve our website as well as products and / or services in response to what you might need or want.
- Strictly necessary cookies – These are cookies that are essential to the operation of our website.
- Analytical/performance cookie – These cookies allow us to recognise and count the number of visitors to our website.
- Functionality cookies – These cookies are used to recognise you when you return to our website.
- Targeting Cookies – These cookies record your visit to our website, the pages you have visited and the links you have followed.
Cookies are used by nearly all websites and do not harm your system in any way.
Your consent applies to the domain: www.smarteffectivelearning.com.