GlobalEnglish is committed to protecting the privacy of individuals who interact with us, whether as visitors to the Company’s Websites (“Visitors”), or as individuals who register to use our Services as defined below (“Customers” or “Subscribers”, hereinafter referred to as “you/your”). This Privacy Statement describes GlobalEnglish’s privacy practices in relation to the use of the services and the related applications and other services offered by GlobalEnglish (“Services”). All information gathered from you as a Visitor or Customer in connection with your use of our Services is governed by the GlobalEnglish Privacy Statement set forth herein (the “Privacy Statement”).
What Information Is Collected?
Whether you wish to obtain further information about our Services or register or are registered through your employer to use them, GlobalEnglish will need to collect from you certain information:
(A) Non-Personal Information.
Like most websites, we may collect certain technical information about your use of the Website when you visit us, and generally this is not information that could be used to identify you without reference to other information (collectively, “Usage Information”).
For example, we may collect your internet protocol (IP) address, operating system, browser type, the identity of your internet service provider (ISP), the number and duration of page visits, how you were directed to the Website, what country your visit originates from, and the number of clicks you make when you use the Website. This does not include demographic information about you.
(B) Personal Information.
We collect Personal Information, in general, through automated forms within the Services that may include your name, email address, location, contact information, native language, gender, birthday, your work preferences and information about your organization. We also collect, and may combine with Personal Information, either technical information about your machine or information about how you have used our performed on our Services. Specifically, you have the opportunity to submit personal information to us in a few ways:
(1) Registration. When you are registered to use any of our Services, we may collect your login name, real name, email, email preferences, country, native language, other known languages and English proficiency, study preferences, country of residence and manager’s email. Depending on which Services you are using, we may also collect additional contact information including city, time zone, phone number, and softphone ID (such as Skype ID).We may provide you the option to tell us your job title, gender and birthday, as well as submitting a photo of yourself and a short narrative profile. In general we collect these fields for all of our users unless your organization indicated that an item of information is not required. Some basic Registration Information may be collected when you initially register for GlobalEnglish Services, and additional information may be collected when you access these additional Services. (“Registration Information”).
(2) Support. By clicking the “Support” link from our Services’ interface to contact us for support/help, you cause our system to populate a support form that includes Registration Information plus information about your system’s configuration (“Support Information”).
(3) Downloads. You can download some of our assignments, materials, toolbars and certain Services applications to your machine to work offline. When you do so, we may collect and record information about your user preference settings, information about your mobile device, the time you spent on our site or in our application, the technical state you logged out from, and data about your activity with our downloaded content, including your viewing history If you choose to watch a video in any of our Services (“Download Information”).
(4) Translations. When you enter words into our product interfaces to request a translation, the phrase you enter is associated with your User ID and saved on our system (“Translation Information”).
(5) Usage. When you use our Services, for example to take assessment exams, ask questions, complete activities, or contribute to our community based Services experience, we collect and store your results, time spent, pages visited, links clicked and inputs on our systems (“Usage Information”). This may include specific questions you’ve posted on discussion boards or content you may have posted. It may also include your program preferences or placement test results, and can include your voice and speech phoneme data.
(6) “Community” based Services. Some of our Services have social tool-like functionality, so your interactions within these types of Services are generally visible to other users within the community, depending on your settings and groups you are part of, which may be administered by you or by your organization. Information may include Registration Information, though you must separately populate your community profile within the product. The Service will specifically request your gender and English proficiency level. Optional information includes pictures, documents, and media files you may choose to upload in order to collaborate, for example, when you comment or post content.
(C) Cookies & Do Not Track.
Depending on the GlobalEnglish site you are using and the country you are based in, cookies may be set on your computer or device by either:
- GlobalEnglish – to recognize and associate activity with your computer or device when it visits a GlobalEnglish site. GlobalEnglish cookies cannot be used to recognize or associate activity with your computer or device when it visits other, third party websites or online properties.
- Third Parties – to enable third party features or functionality to be provided on or through GlobalEnglish Properties or other online properties (e.g. advertising and analytics). The third parties that set these cookies may be able to recognize your computer or device both when it visits GlobalEnglish sites or other online properties that use the third party’s features and functionality
In some cases you may purchase our Services or renew your subscriptions through web sites using your credit card. Such transactions are supported through PayPal or similar online payment systems, which processes the transaction. GlobalEnglish does not collect or store your credit card information.
How We Use Information Collected from You
How We Use Your Personal Information
To provide you the best learning experience we can, we may allow our Services to access and process information (including Personal Information) collected through other Services or through the present Service in the following ways:
- REGISTRATION INFORMATION to access your account, store your preferences, provide you with personalized communications and services, and identify appropriate training tools for you. Depending on setting selections made by your employer, we may also reference your Registration Information in order to compile performance reports or usage statistics for your supervisor or account administrator.
- SUPPORT INFORMATION to answer your inquiries and provide you with technical support.
- DOWNLOAD INFORMATION to integrate your offline activity with your online profile and suggest appropriate training tools for you. Depending on setting selections made by your company, we may also reference your Download/Usage Information in order to compile performance reports or usage statistics for your supervisor or account administrator.
- TRANSLATION INFORMATION to track your progress and provide you with appropriate training tools to integrate your data with our other Services’ profiles, depending upon setting selections made by your organization. We may also reference your Download/Usage Information in order to compile performance reports or usage statistics for your supervisor or account administrator.
- USAGE INFORMATION to track your progress, make posts to the community upon your request, provide you with the most relevant training materials, and compile performance reports or usage statistics for your supervisor or account administrator. Any customization of our Services to train you occurs through automated means.
- ENHANCEMENT OF THE SERVICES USER EXPERIENCE to ensure that your experience of each of the Services is as seamless, efficient and enjoyable as possible – whether it is through your participation in any one of our Services including our community-based Services or coaching Services. The community based Services has certain social media-like functionality which allow other users within the community to identify you, and to share the information you choose to post to the community. Your post will be visible to the entirety of the group you select. We also use your IP Address in combination with Registration Information on an aggregated basis to analyze the pages viewed within our Services, but we only use it for the purpose of helping GlobalEnglish improve our community functionality and deliver appropriate training materials to you. We monitor the video viewing history we have compiled about users on an aggregated basis, to gather statistics of popular videos and number of views, but again, we only use it for the purpose of helping GlobalEnglish improve the Services and to deliver appropriate training materials to you. Your full community profile is visible to everyone who uses this Service. If you do not want information in your profile to be visible outside your Company, then you should not use the community based Service. For our coaching Services, Registration Information therein is shared with your assigned coach, the coaching coordination staff and pedagogical support unit for the purpose of providing coach services and attendance statistics. If applicable, it is also is shared with your organization account manager and GlobalEnglish administrator for the purpose of helping GlobalEnglish improve the coaching experience for you.
How We Use Your Usage Information
We track and reference your Usage Information, in aggregation with the Usage Information of other users, to better understand how effective our Website is and how visitors interact with it. Only GlobalEnglish has access to such analysis, which may be generated using third party software tools.
Usage Information collected from you is used for various purposes, such as:
- to improve our Services;
- to customize the user experience of the Services;
- to administer the Services; and
- to analyze trends, track user movement, and gather statistical information for aggregate use.
Sharing of Your Information
We will not share your Personal Information with third parties other than as provided in this Privacy Statement. We may share your Personal Information with third parties in one or more of the following ways:
We may share your Personal Information and Usage Information with any parent or subsidiaries, or other companies or entities which control, are controlled by or under common control with GlobalEnglish, including our existing international affiliate offices, in which case we will require such parties to honor this Privacy Statement with respect to such shared information.
Third Party Service Providers
We may provide your Personal Information and Usage Information to third party companies and distributors to perform services on our behalf, including marketing assistance, e-mail delivery, hosting services, cloud servers, coaching sessions, customer service and data analysis. We may use independent contractors to provide services on our behalf and they may access your Personal Information in the course of providing those services. We require such third party service providers to maintain the confidentiality of the information disclosed to them and to not use your Personal Information for any purpose other than to provide services to GlobalEnglish.
We store customer data, which may include your Personal Information, on public cloud servers. These servers are hosted by third party service providers in the United States. Our choice of provider is subject to change in our sole discretion and without updating this Privacy Statement. Our contracts with these providers guarantee that our information will remain confidential; however, no public cloud can be guaranteed to be 100% secure.
We use a third party tool to translate in real time. Some Usage Information may be visible to the operator of this tool but cannot be associated with a user.
Your email inquiries through the “Support” and “Contact Us” functions are routed and stored by a third party service provider. Our choice of provider is subject to change in our sole discretion and without updating this Privacy Statement.
Safety, Security and Compliance with Law
We may disclose any information, including Personal Information, we deem necessary to comply with any applicable law, regulation, legal process or governmental request, to enforce our rights or to protect the safety and security of our Website or other users. The customers and natural persons concerned will be notified of the disclosure, provided this notification does not conflict with any applicable law, regulation, legal process or governmental request.
In the event GlobalEnglish undergoes a business transition, such as a major investment transaction, merger, acquisition by another company, or sale of all or a portion of its assets, we may transfer your Personal Information to the actual or intended successor organization in such transaction or permit its examination by our counterparty, subject to confidentiality restrictions. If material changes to GlobalEnglish’s privacy practices will occur as a result of the business transition, GlobalEnglish will attempt to notify you via email and will post a notice on the Website alerting you to the business transition prior to transferring your Personal Information, provided we are at liberty to publicize a potential transaction.
Other Third Parties
How to Access and Update Your Personal Information
At any time, you may contact GlobalEnglish to request that we make changes to your Personal Information, or remove your personal information completely. If you request that we update or otherwise modify your information, we will amend your Personal Information within a reasonable time after your request. To inquire about which items of Personal Information GlobalEnglish possesses about you or to request its modification, please email us at firstname.lastname@example.org.
However, please note that, after your Personal Information is changed, GlobalEnglish will continue to store, use and disclose all Personal Information collected from you through the Services (including Personal Information which is no longer in active use due to its amendment in accordance with this Section) for certain purposes permitted or required by applicable laws, including as we deem necessary to comply with any applicable law, regulation, legal process or governmental request, to enforce our rights, or to protect the safety and security of our Services or other users. The customers and natural persons concerned will be notified of the storing, use and disclosure, provided this notification does not conflict with any applicable law, regulation, legal process or governmental request.
Resolution of Concerns
If you have questions or concerns about this Privacy Statement or how we handle personal information, please contact us at email@example.com or contact the address at the bottom of this Privacy Statement. If we are unable to satisfactorily address your concerns, you should contact the Data Protection Authority or other relevant organization in your area.
How We Secure Your Information
We use Secure Socket Layer (SSL) technology to secure user credentials while authenticating access to all Services. Any data transmitted between production systems is done via secure VPN/SSL/FTP channels.
GlobalEnglish has administrative and physical security measures to protect user’s Personal and Usage Information, online and offline. Our employees, contractors, and third party service providers are generally subject to restrictions which limit their use of information obtained from GlobalEnglish to the business purpose of the relationship for which we contract. GlobalEnglish also takes reasonable steps to protect information we collect from you to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction. All Personal Information (login and profile update information) is encrypted via SSL during transmission to GlobalEnglish over the internet.
The servers on which information is stored are kept in a controlled environment with limited access. While we take reasonable precautions to guard Personal Information we knowingly collect directly from you against possible security breaches of the Services, no website, Internet transmission or security system is impenetrable and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. In addition, we cannot guarantee that any passively-collected documents you store, or discussions which occur, on our systems are maintained at adequate levels of protection to meet specific needs or obligations you may have relating to that information.
Your account information and access to our service is accessible only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.
If our customers (and by extension the users associated with their account) choose to stop using our Services, we reserve the right to permanently delete all Personal Information and other information related to their account, provided we are not obliged by any applicable law, regulation, legal process or governmental request, or by any contract, or by any customers’ interest to retain this information. Our customers have the opportunity to ask us for a copy of the information we have for them and for their users within 30 days of departure. If the customer does not request this information within 30 days, we shall have no further contractual obligation to the customer with respect to information we have for them and we may permanently delete it. For active customers, however, we currently store Usage Information, Download Information, Translation Information and Registration Information from users indefinitely. You must ask your organization, our customer, to request deletion of any individual user information associated with its account.
Our Policies Concerning Children
Our Services are not intended for children under the age of 13 and we do not knowingly collect any Personal Information from such children. Children under the age of 13 should not use our Services at any time. In the event that we learn that we have inadvertently gathered Personal Information from children under the age of 13, we will use reasonable efforts to erase such information from our records.
Changes to Our Privacy Statement
If we decide to make material changes to our Privacy Statement, we will notify you and other users of the Services by sending a notice to the email address that you have provided in connection with your Services account and/or by placing a notice within our product interface. You should periodically check the Services for such notices, provided we have not arranged for our customers to notify their individual users of such changes. Regardless of any changes we make to our Privacy Statement, we will only use your Personal Information in accordance with the version of the Privacy Statement in place at the time you provided your information (including without limitation the opt-out provided herein), unless you later give your consent for us to do otherwise.
GlobalEnglish complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. GlobalEnglish has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification, please visit http://www.export.gov/safeharbor/.
Attn: Privacy Concerns/Legal Department
2000 Sierra Point Parkway, Suite 300
Brisbane, California 94005 USA
Last updated 27 November, 2014 v.3 PEPS11262014