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PRIVACY POLICY

INTRODUCTION  

 

Welcome to Planet English’s Privacy Policy.

 

IQBar Limited respects your privacy and is committed to protecting your personal data. As our Planet English website provides resources for children we are particularly concerned about keeping children and their personal details safe. Hence, we do not offer our services directly to children and, in fact,  we do not permit children under sixteen (16) to register an account with us. This is so that a parent or other responsible adult can control the information collected from children on the website and ensure that no personal information is disclosed. The username you choose for your child on our site does not have to identify the child. Before any content is provided on our website, whether on an interactive forum or otherwise, please note that we require you or the supervising adult to first check the content and ensure that it is appropriate and does not contain identifying or contact details and complies with our Child Policy and Acceptable Use Policy.

 

This privacy policy will inform you as to how we look after personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. IMPORTANT INFORMATION AND WHO WE ARE

  2. THE DATA WE COLLECT ABOUT YOU

  3. HOW IS YOUR PERSONAL DATA COLLECTED?

  4. HOW WE USE YOUR PERSONAL DATA

  5. DISCLOSURES OF YOUR PERSONAL DATA

  6. INTERNATIONAL TRANSFERS

  7. DATA SECURITY

  8. DATA RETENTION

  9. YOUR LEGAL RIGHTS

  10. GLOSSARY

 

1. IMPORTANT INFORMATION AND WHO WE ARE 

 

PURPOSE OF THIS PRIVACY POLICY  

This privacy policy aims to give you information on how IQBar Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or purchase our services or goods from our online store or take part in a survey or forum. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER  

IQBar Limited is the controller and responsible for your personal data (referred to as "COMPANY", "we", "us" or "our" in this privacy policy). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights please contact the data privacy manager using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

  • Full name of legal entity: IQBar Limited, Company number 09950321;

  • Email address: planetenglish@iqbar.co.uk;

  • Postal address: 86-90 Paul Street, EC2A 4NE, London, United Kingdom;

  • Telephone number: (+44) 0151 662 03 13.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated March 2021. Historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications such as if you sign in using Google or Facebook. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

2. THE DATA WE COLLECT ABOUT YOU AND THE ACCOUNT USER

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you or the user which we have grouped together as follows:

 

  • Identity Data includes first names, last name, username or similar identifier, marital status, title, and gender;

  • Contact Data includes billing address, email address and telephone numbers;

  • Financial Data includes bank account and payment card details;

  • Transaction Data includes details about payments to and from you and other details of services or goods you have purchased from us;

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences;

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;

  • Profile Data includes the username and password used for your account, purchases or orders made by you, or the account user, demographics, feedback and survey responses;

  • Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not generally collect any Special Categories of Personal Data about you (this includes details about 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). We do not collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel the delivery of goods or services you have purchased but we will notify you if this is the case at the time.

 

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about our users, including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data, education history, demographics, profile photographs and any information you provide to us by filling in forms or surveys or by corresponding or otherwise interacting whether on the site or by post, phone, email or otherwise. This includes personal data you provide when you:

    • apply for our services;

    • purchase goods from our online store;

    • create an account on our website;

    • subscribe to our services or publications;

    • request marketing to be sent to you;

    • enter a competition, promotion or survey or forum, assessment or other interactive service on our site; or

    • give us feedback or contact us.

 

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

 

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

  • Where we need to perform the contract we are about to enter into or have entered into with you;

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

 

CHILDREN UNDER SIXTEEN (16): Note that we may collect information from users under the age of sixteen (16) just to better our services or to perform the contract with you. We cannot however control what your child chooses to share on our website. If you are the parent or the supervising adult and you are aware that your child has provided us with Personal Data without your permission, please contact us. If we become aware that we have collected Personal Data from anyone under the age of sixteen (16) , we will take steps to delete that information. We ask that you ensure that your child does not share any personal information or images on the website which could identify them (such as: their name, address or telephone number; the username for your child is a pseudonym and any image used on the child’s profile is an avatar and not a real image).

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We will never use your child’s personal data, save where we expressly state otherwise in these terms, and for the sole purpose of performing the contract.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

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Purpose/Activity
Type of Data
Lawful Basis for Processing
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical (b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity (b) Contact (c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To enable you or your child to partake in a competition or complete a survey or test.
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Providing your child with a personalised learning experience (d) submitting assignments (e) providing support (f) tailoring your child’s experience
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) deliver goods you have purchased from our online store
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To register you as a new customer
(a) Identity (b) Contact
Performance of a contract with you

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services or goods from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, registration, service experience or other transactions.

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. To exercise choices regarding cookies set through our website, as well as other types of online tracking and internet advertising see your individual internet settings. IQBar Limited endeavours to fully comply with relevant Cookies legislation (Privacy and Electronic Communications Regulations 2003 (PECR)). This means alerting users to use of cookies and obtaining consent to cookies being placed on their browser.

Application location choices. As detailed in the “Data we collect about you and the account user” section, above, we may collect information about your location if you enable location services through the settings in your electronic device, or, as required, with your consent. You can change the privacy settings of your device at any time to turn off the sharing of this location information with our sites. If you choose to turn off location services, this could affect certain features or services of our sites. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.

For more information about the cookies we use, please see our Cookie Policy.

CHANGE OF 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. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5. DISCLOSURES OF YOUR PERSONAL DATA

 

We do share information with the following categories of companies as an essential part of being able to provide our services to you:

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

Providers of technical and payment services, such as:

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6. INTERNATIONAL TRANSFERS  

 

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

7. 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. In addition, 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 a duty of confidentiality. 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.

 

8. DATA RETENTION

 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal Rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

9. YOUR LEGAL RIGHTS

 

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    • If you want us to establish the data's accuracy;

    • Where our use of the data is unlawful but you do not want us to erase it;

    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;

    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

10. GLOSSARY

 

LAWFUL BASIS

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

  • Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

 

THIRD PARTIES

INTERNAL THIRD PARTIES

We do not share your personal data with any other group companies.

EXTERNAL THIRD PARTIES

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

  • Epignosis UK Ltd (TalentLMS) provides our learning management system, see their privacy policy here https://www.talentlms.com/privacy.

  • Talent LMS share personal data with us for the purpose of enabling us to provide their learning management system, see their privacy policy here: https://www.talentlms.com/privacy. We monitor the TalentLMS Privacy Policy periodically in order to fully comply with all provisions regulated by data protection legislation, however, IQBar Limited cannot be held liable for policies external to IQBar Limited.

  • Printful Inc. IQBar Limited partner with a third-party provider, Printful® Inc. of 11025 Westlake Dr, Charlotte, North Carolina for the warehousing, shipment and fulfilment of all product purchases made through our sites. We encourage you to read the policies of this third-party logistical supplier when you purchase any goods from our online store. These policies can be found at https://www.printful.com/policies.

  • GetResponse is our secure and dynamic email distribution and engagement provider. Please ensure that you access their privacy policy here https://www.getresponse.com/legal/privacy. We furthermore encourage you to access their security information here https://www.getresponse.com/security

  • Convertful is a digital contributor to our site. It provides interactive features such as pop-ups, scroll boxes, floating bars, fullscreen welcome mats, embedded inline widgets and floating buttons. We encourage you to access their privacy policy here https://convertful.com/legal/privacy/

Planet English's Privacy Policy is fully supported by the Senior Management Team of IQBar Limited and the Planet English Team.

Planet English's Privacy Policy is monitored and reviewed annually.

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