GlobalEnglish Corporation and its affiliates (collectively referred to as “GlobalEnglish” or the “Company”) are committed to protecting the privacy of individuals who interact with them, whether as visitors to the Company’s websites (“Visitors”) or as individuals who register to use GlobalEnglish’s learning solutions (referred to as “Users” or “Subscribers”).
Users may register individually on their own for our Services (which is referred to as a “B2C transaction”) or through our corporate accounts when the organizations and companies (referred to as “Customers”) subscribe to GlobalEnglish Software-as-a-Service solutions for their employees, contractors and representatives (a “B2B transaction). With respect to corporate accounts, in addition to User’s information, GlobalEnglish also collect a limited number of personal information of its business contacts in these corporate accounts (for example, the HR and Legal representative administering our contract with that organization).
All processing of Personal Data provided by you as a Visitor, User or Customer’s representatives in connection with your use of our Services and all Personal Data that may derive from the Personal Data you provide is governed by this GlobalEnglish Privacy Statement.
Personal Data is processed only in accordance with the applicable data privacy law and/or with your consent. In a B2B transaction, GlobalEnglish’s Processing of your Personal Data is subject to the instructions of its Customer, your employer.
In this Privacy Statement, the terms “You” or “Your” is used to refer to individuals, whether Users, Visitors or Customers’ representatives who interact with GlobalEnglish. “GlobalEnglish”, “Company”, “we”, “our” and “us” are terms used to refer to GlobalEnglish and its employees and subcontractors. The term “Services” includes (a) access to GlobalEnglish’s learning solutions, web services, offerings, content, tutorials, classes, coaching, training, email communications regarding those and events.
Data Controller and Contracting Parties
GlobalEnglish will be acting as the “Controller” of the Personal Data you provide directly to us via a “Contact Us” form, when creating an account, or via other contact methods.
If you reside in the European Union (“EU”), the European Economic Area (“EEA”) or Switzerland, GlobalEnglish France Sarl (“GlobalEnglish France”) shall be the controller of your Personal Data processed by GlobalEnglish and you will be deemed to enter into the User Agreement with GlobalEnglish France.
If you reside outside of the EU, EEA or Switzerland, GlobalEnglish Corporation (U.S. entity) will be the controller of your Personal Data and the User Agreement you will execute shall be deemed to have been entered with GlobalEnglish Corporation.
In a B2B transaction, GlobalEnglish will be acting as the “Processor” of your personal data transmitted by our Customer. Our Customer will be acting as Controller of your information. As Processor, we do not own, control, or direct the use of any data provided to us by our Customers and we can only act upon their instructions. As a User, you will be asked to sign a User Agreement with GlobalEnglish but will have to direct enquiries about your Personal Data to your employer, the Data Controller.
Why is GlobalEnglish Collecting Your Personal Data?
As a general principle, GlobalEnglish shall request you to provide certain Personal Data only to the extent necessary to:
(a) Provide its Services to you and if applicable, your employer, communicate with you and your employer as the case may be about the use of our Services, provide performance reports, personalize the help and instructions our customer support team provides to you, provide troubleshooting and generally assist you as you are embarking on this English learning journey with us. Some Personal Data need to be collected and processed prior to entering into a contract with you or your employer, as the case may be for the provision of Services. This would include business contact information and conversation or email exchange data between you, as a representative of the employer and our Salesforce or a representative of our Customer Success Management Team;
(b) Improve its Services by gathering metrics to better understand the needs of Users, requesting feedback from the Users through questionnaires, creating usage statistics, evaluating and updating its content, measuring the effectiveness of its Services, creating anonymized data sets and develop new products and Services which will, ultimately benefit you;
(c) Ensure compliance with its legal obligations, including, e.g. the export laws of the European Union and the United States applicable to its products, technologies, and Services and the specific requirements under U.S. laws to protect children’s privacy;
(d) Prevent and stop misuse of its Services, illegal activities, and fraud;
What GlobalEnglish Does Not do?
We do not share your Personal Data to third parties for their own marketing purposes.
Can you Choose Not to Disclose Personal Data or Opt out of Receiving Communications?
Your provision of Personal Data and your consent for us to process such Personal Data are entirely voluntary and you may choose not to provide us with any Personal Data.
We encourage you not to share sensitive information such as, e.g. health-related information, sexual life, criminal record, membership in a trade union or information about your religion and philosophical beliefs, when using our Services. You also should not post or share Personal Data that you would not want to be publicly available.
However, because certain Personal Data is critically needed for us to provide you with access to our English learning tools, process your order, respond to your questions about the Services and give you the customer support you need to fully enjoy our Services, GlobalEnglish will not be able to take any action without such Personal Data. Furthermore, once you have registered for our Services, we may need to communicate by phone or email with you to resolve a technical difficulty or need to send notices and other disclosures required by law. These communications are not marketing related but merely required for the relevant business relationship. We therefore need to process certain essential Personal Data and Users cannot opt out of these communications.
With regard to marketing-related types of communications (i.e. emails and phone calls), GlobalEnglish shall (a) where legally required first ask you to opt in to receive such communications and (b) provide you with the opportunity to opt out if you do not want to receive further marketing-related types of communications from us.
What Personal Data and Other Information Does GlobalEnglish Process and For What Purposes?
Whether you wish to obtain further information about our Services, individually register to take advantage of our services or are registered through your employer to use them, GlobalEnglish will need to collect and process certain information about you. We collect this information with your consent directly from you, from your employer and automatically through our website and services. This information includes:
(A) Usage Information
Like most Software-as-Service companies, we may collect certain technical information about your use of the website and mobile application 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 record usage data when you visit our website and use our Services, including our mobile application, when you view or click on content (e.g. a learning video), interact with learning activities, complete assessments, and so forth.
- We collect and record information about your usage and browsing activities. For example, we may collect your internet protocol (IP) address, operating system, browser type, the identity of your internet service provider (ISP), unique device identifier, the date and time of your visit, the number and duration of your page visits, the pages visited, how you were directed to the Website (URLs), what country your visit originates from, the number of clicks you make when you use the website or application. We collect and may store information that your web browser or mobile device provides to us in connection with your use of our Services.
We use the Usage Information to optimize your visit, make your browsing or user experience as effective as possible, and let you know about new learning content available or of interest for you and features that we think will interest you.
Our website does not allow third parties to gather information about you over time and across sites.
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.
(B) Users’ Personal Data in the form of account information and content
GlobalEnglish processes two categories of Personal Data pertaining to the Users of its Services: (1) Account information of the Users of its Services and (2) content provided by Users and GlobalEnglish’s Customer Success Management Team in the course of the provision of Services. Again, this Personal Data is collected with your consent and the consent of your employer in a B2B transaction and is necessary to provide the Services you seek from us.
(1) Account Information:
When you enquire about our services or create an account on our platform, we collect Personal Data that include both required and optional information such as:
Your login name, email address, password, country for all services.
For blended learning solutions such as Virtual Group, Focus, Coach, Executive Coach, Professional and future blended solutions that involve interactions with teachers: city, time zone, mobile and work phone number and skype (or similar communications technologies), employer’s name, preferred interface language.
First name, last name, Job title, manager’s email (if the feature is enabled at the request of your employer), study goals.
For those Users who purchase our Services privately or renew your subscriptions through web sites using their credit card, such B2C transactions are supported through PayPal or similar online payment systems, which process the transaction. GlobalEnglish does not collect or store your credit card information.
(2) Your Content:
When you use our Services, for example to take assessment exams, ask questions, complete activities as you progress through our English learning solutions, use our class scheduling services, request a translation or support in general, take advantage of our community-based services (as described below) to post on discussion boards and upload content on that particular social media tool, we use Personal Data you shared with us on registration to assist you.
We also track your learning progress by saving and processing placement test results, scores, voice recordings that help us provide feedback on pronunciation and vocabulary, performance improvement recommendations made by your teacher and other content you choose to upload, including survey data. Recording of Skype or telephone calls or chat session is always done with your knowledge and consent.
Some of our Services have social media 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. 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 employer’s organization, then you should not use the community-based Service.
(C) Business Contact information
GlobalEnglish keeps Personal Data of its business contacts such as the first and last name, professional address, job title, phone number and email address of its customers’ representatives administering service agreements and interacting with its Sales force and its Customer Success Management Team.
If you are one of our business contacts, this information is used to keep you up-to-date about our Services and products and inform you, where permitted according to local laws, about new products or Services and any Services and products similar to or related to products and Services which the corporate customer has already purchased in the past. We may also invite you to webinars and seminars or events and may reach out to you afterwards for feedback regarding improvements of the relevant webinar, seminar, event, product or Service. You may also receive marketing-related newsletters about our Services.
Please note that if you are interested in attending one of our events, GlobalEnglish may ask for information about your health for the purpose of identifying and attending to the needs of individuals who may have a disability or dietary requirements which GlobalEnglish wants to be respectful of and accommodate during the event. Any use of such information is based on the consent you grant. You are of course free not to provide such information but note that in this case, GlobalEnglish will not be able to take the necessary precautions to ensure your wellness during the event.
Links to other Websites
Our website may contain links to the websites of foreign entities (i.e. entities that are not part of the GlobalEnglish group of companies). GlobalEnglish is not responsible for the privacy practices or content of websites outside of the GlobalEnglish group of companies. We advise you to carefully read the privacy policies of these sites.
Where will your Personal Data be Stored and Processed?
GlobalEnglish’s cloud servers processing Personal Data are located in the EEA with Microsoft Azure and Amazon AWS which have both committed to comply with the GDPR requirements.
As a global company, GlobalEnglish Corporation has affiliates within and outside the EEA, each with employees in the Customer Success Management and Support Teams dedicated to provide you with the best learning experience, regardless of the time zone in which you live. For purposes of the Services, your Personal Data and usage information may be transferred to affiliates of GlobalEnglish in countries outside of the EEA, including countries found not to offer a level of protection of Personal Data comparable to the level of protection offered in the EU and Switzerland. Such transfer occurs under the EU Model Clauses or Standard Contractual Clauses according to the EU Commission Decision 87/2010/EC or any future replacement until GlobalEnglish adopts Binding Corporate Rules (“BCR”) and have them approved in the EU.
Who can view your Personal Data?
Only those administrators of the Services which have a need to access your Personal Data for the Purposes described above can view your Personal Data, subject to confidentiality obligations. Those are members of:
- The Customer Success Team
- The Customer Support Team
- The Account Operations Team
- The Teachers and Coaches Team
- The System Administrator
- The Sales Team for business contact information only
Sharing of Your Personal Data with Third Parties
We may provide your Personal Data and usage information as set forth below and where Users’ consent has been granted.
Third party service providers: (companies, distributors and independent subcontractors) to perform services on our behalf, including e-mail delivery, cloud servers (as described above), coaching sessions, translation in real time, customer service and data analysis. These sub-processors may access your Personal Data and usage information in the course of and for the sole purpose of, providing Services to you and if applicable, your employer under the relevant service agreement. All third party service providers, including those which have access to your business contact information, are under GlobalEnglish’s instructions and cannot use your Personal Data for other purposes than to meet GlobalEnglish’s instructions.
We require such third-party service providers to comply with the EU General Data Protection Regulation (GDPR), 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 use Data Processing Agreements and the EU Model Clauses.
Our choice of third party service providers 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 and meet GDPR requirements; however, no cloud provider and no transmission of data over the Internet can be guaranteed to be 100% secure.
Compliance with Our Services Agreement with Your Employer: If applicable, your Personal Data is also being shared with your organization account manager for the purpose of helping GlobalEnglish improve the learning experience for you.
Compliance with Legal requirements: We may disclose any information, including Personal Data, we deem necessary to comply with any applicable law, regulation, legal process (e.g. subpoenas and warrants) or governmental request. The customer (employer) and natural persons concerned will be notified of the disclosure, as much as possible ahead of the disclosure, provided this notification does not conflict with any applicable law, regulation, legal process or governmental request. GlobalEnglish shall make reasonable efforts to limit the disclosure of Personal Data to what is strictly necessary.
Protection of Our Rights: We may disclose any information where we believe it necessary to respond to claims asserted against us, to enforce our rights, for fraud prevention or to protect the safety and security of our website, our users or other persons and property.
How We Protect Your Personal Data
The security of your Personal Data is important to us. We use Secure Socket Layer (SSL) technology to secure user credentials while authenticating access to all Services, and when transmitting Personal Data. 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 Data 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 Data related to the account and profile 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.
However, no website, Internet transmission or security system is completely secure and impenetrable. 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 username and password. We urge you to take steps to keep your Personal Data safe by choosing a strong password and keeping it private and logging out of your user account and closing web browsers when you finish using our Services on a shared or unsecured device. 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.
Duration of Processing of Personal Data.
GlobalEnglish shall store your Personal Data:
(a) only for as long as required to fulfill the purposes set forth above;
(b) where we have a legitimate interest in processing your Personal Data to improve our Services until you object to our use of your Personal Data; or
(c) until you withdraw the consent you provided earlier to the Processing of your Personal Data.
In practice, this means that GlobalEnglish may retain your Personal Data and Usage Information for the duration of the provision of its Services to you and in general, for three (3) years thereafter. However, you can object and withdraw your initial consent in writing.
If you have been registered through your employer (our “Customer”) in a B2B transaction and no longer want GlobalEnglish to process your Personal Data, you must contact your employer first, as it is the Data Controller in charge of your Personal Data. We, as Data Processor, will work with your employer to address your request. You must ask your organization, our customer, to request deletion of any individual user information associated with its account.
Your employer, as Data Controller, may also request that GlobalEnglish acting in its capacity of Data Processor destroys or surrenders all Personal Data to it within thirty (30) days following the termination or expiration of the relevant service agreement, in which case we will follow the instructions of your employer and erase your Personal Data.
After the three years period, we reserve the right to permanently delete all Personal Data and other information related to all accounts.
However, when laws and regulations require GlobalEnglish to retain Personal Data for a longer period or where your Personal Data is required for GlobalEnglish to assert or defend against legal claims, GlobalEnglish shall retain your Personal Data until the end of the relevant mandatory retention period or until the claims in question have been settled.
Your Rights to Access and Update Your Personal Data
You can request from GlobalEnglish at any time information about which Personal Data we process about you and request correction or deletion of such Personal Data. 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.
As a User of our Services, you can also access your profile directly and make certain changes and edits yourself to certain Personal Data pertaining to your account and profile information. To the extent you have registered as a user of our Services through your employer, your employer, as Data Controller, may restrict certain access and editing capabilities.
However, please note that:
(a) GlobalEnglish can delete your Personal Data only if there is no statutory obligation or prevailing right of GlobalEnglish to retain it;
(b) Once your Personal Data is deleted, you will not be able to continue to use any of our Services with that user account;
(c) Users do not have the capability to edit or delete certain Personal Data, such as e.g. their scores or their answers on tests completed.
You can also request that GlobalEnglish restrict your Personal Data from further processing in any of the following events:
(a) You have reasonable ground to believe that the Personal Data is incorrect, in which case you may request that Processing of that Personal Data shall be suspended for as long as required to check the accuracy of the relevant Personal Data;
(b) You request that GlobalEnglish retain your Personal Data for future use of our Services, for example after you have left the employer through which you registered for our Services and would like to subscribe directly with us or continue using our Services while with your next employer.
Remember that if you registered for our services through your employer in a B2B transaction, you must make those requests to your employer. GlobalEnglish shall make reasonable efforts to work in collaboration with your employer to address your request and keep you updated on the status of the processing of your request.
Your California Privacy Rights
California law permits users who are California residents to request and obtain from us, once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for direct marketing purposes in the prior calendar year, as well as the types of Personal Data we disclosed to those parties. If you are a California resident and would like to request this information, please submit your request to email@example.com.
Your Right to Data Portability
You have the right to request a copy of your data at any time as long as your account has not been erased. Upon receiving your request, GlobalEnglish will provide you all the data directly related to the personal account of your choice, within a reasonable timeframe.
Your Right to Lodge a Complaint
If you believe that GlobalEnglish is not processing your Personal Data in accordance with its policies set out herein or applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country where you live.
Our Policies Concerning Children
Our Services are not intended for children under the age of 13 (14 for anyone living in Spain or South Korea) and we do not knowingly collect any Personal Data from anyone under such age or knowingly allow such person to register. Children under the age of 13 (or 14 in Spain and South Korea) should not use our Services at any time. In the event that we become aware that we have inadvertently gathered Personal Information from children under the age of 13 (or 14) without parental consent, 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 Users of the Services by sending a notice to the email address that you have provided in connection with your account and/or by placing a notice on our website. You should periodically check the Services for such notices, provided we have not arranged for your employer, when applicable, to notify their individual users of such changes. We will only use your Personal Data 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.
If you have any questions, comments or concerns regarding our Privacy Statement and/or practices, please send an email to firstname.lastname@example.org
Attn: Privacy Concerns/Data Protection Officer (“DPO”)
Address: 1875 South Grant Street, Suite 700
San Mateo, CA 94402
Last updated 24th May, 2018 v.1