LINGUISTS DIRECTORY – PRIVACY AND COOKIES POLICY

 Last updated March 2022.

This is the privacy policy of LD Pro Ltd, a company registered in England and Wales under company number 12828475 whose registered office is at 6 Coldhams North, Huntingdon, England, PE29 1UB (“we” or “us”).

Your privacy is important to us. This policy sets out information on the personal data we collect about you, and your rights in respect of this data.

This policy applies whether you visit our website available at linguistdirectory.com/ (“website”), either as a guest or a registered user (together referred to as “services”).

Our website may contain links to third party websites that are not covered by this policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

This policy contains the following information:

  • Information about us
  • Information on what we may collect
  • How we store your personal data
  • How we disclose your information
  • When you interact with our website – Information on cookies
  • Your rights regarding your personal data
  • What happens when we link to other websites?
  • The changes we may make to this policy.

Information about us

We respect your right to privacy and will only process personal information about you in accordance with applicable data protection laws.

We comply with UK Data Protection Act 2018. If any of these laws are replaced or superseded, we will also comply with that.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (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.

Our data protection officer is Vladimir Keves and their details are:

What we may collect

Personal data, or personal information, is 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 when you engage with us. Whenever we collect personal data about you, we must have a legal ground (lawful basis) to do so. We must also observe the principles of data minimisation and only collect as much personal data as necessary, and retain that data for no longer than necessary.

  Type of data Purpose and Lawful Basis
Identity and contact information you provide to us when you: contact us; Submit a contact form for a Linguist; Submit a request for translation services; Complete the Legal aid price estimates calculator; or message us via the website using our ‘contact us’ form (Personal Data) Includes:

·        Name

·        Email address

 

The purpose of collecting this information is so that we can ensure your enquiry is dealt with in the appropriate way, such as by forwarding your enquiry to a Linguist or provide you with an estimate for translation services.

 

A copy of each request and enquiry is also sent to us as an admin copy, enabling us to monitor performance and assist with communications if necessary.

 

If you contact us with a customer service issue, we may use your name and email address to send you information about your matter or issue raised and we may also provide you with updates on changes to this policy or security information.

 

The lawful basis for collection of this information is that it is needed to perform our contract with you (i.e., to contact you as you have requested), it’s in our legitimate interest and that you have consented (i.e., by contacting us or requesting we contact you).

 

Identify and contact information you provide to us when you register for a Linguist account (Personal Data) Includes:

·        Name

·        Email address

·        Phone number

·        Home address

·        Photo ID, such as passport or driving licence

·        Proof of address

·        Proof of qualifications and accreditations

·        Information required for vetting, including a DBS, DBS, NPPV3 and CTC

We collect this information when you register for a Linguist account on our website and enables us to:

·        Approve your application to become a Linguist so that you can begin promoting your language services on the website; and

·        Contact you in respect of our services.

 

Our lawful basis for this is to perform our contract with you and you have provided your consent to the collection of this personal data.

 

Identify and contact information you provide to us when you register for a Teacher account (Personal Data and Banking Data) Includes:

·        Name

·        Email address

·        Phone number

·        Home address

·        Photo ID, such as passport or driving licence

·        Proof of address

·        Proof of qualifications and accreditations

·        Information required for vetting, including a DBS, DBS, NPPV3 and CTC (if available)

·        Your banking details, including account name, bank, sort code and account number

We collect this information when you register for a Teacher learner account on our website and enables us to:

·        Approve your application to become a Teacher so that you begin providing language lessons  to Students;

·        Contact you in respect of our services;

·        Pay you for the teaching services provided to Students.

 

Our lawful basis for this is to perform our contract with you and you have provided your consent to the collection of this personal data.

 

Identify and contact information you provide to us when you register for a Student account (Personal Data) Includes:

·        Name

·        Phone number

·        Email address

·        Home address

 

 

 

We collect this information when you register for a Student account on our website and enables us to:

·        Approve your application to become a Student so that you can begin taking language lessons; and

·        Contact you in respect of our services.

 

Our lawful basis for this is to perform our contract with you and you have provided your consent to the collection of this personal data.

 

Identity and contact information you provide to us when you register for a Paid Advertisement Subscription (Personal Data). Includes:

·        Your name

·        Email address

We collect this information when you register for a Paid Advertisement Subscription on our website and enables us to:

·        Approve your application to place a Paid Advertisement Subscription on the website; and

·        Contact you in respect of our services.

 

Our lawful basis for this is to perform our contract with you and you have provided your consent to the collection of this personal data.

 

Identify information when Students attend a lesson held by Zoom (or a similar video conferencing platform) (Personal Data) Includes:

·        Name

·        Your face and physical appearance as it appears on the screen.

 

Teachers conduct the lesson via Zoom (or a similar video conferencing platform) and are required to take a screenshot of the screen. The purpose is to show the number of Students in attendance. The lawful basis is it is in our legitimate interest to record the number of attendees and you have consented to this by attending the lessons, as stated in our terms and conditions, available here.
Information you provide to us when making payment (Payment Details) Includes:

·        Debit/credit card number

·        Name on the card

·        Expiry date

·        CVV number

The purpose of collecting this information is so that we can collect payment of our fees. The lawful basis for collection of this information is that it is needed to perform our contract with you (i.e., provide you with the services).

 

All payments are taken by a third party processor, currently Stripe. We do not ever see or keep a copy of your card details.

Identity and contact information you provide to us when you sign up to receive our marketing or promotional materials (Marketing and Communications Data) Includes:

·        Name

·        Email address

The purpose is to provide you with marketing and promotional material. The lawful basis for this is that you have provided your consent and it is in our legitimate interest to present relevant content, products, and services to you. You can withdraw your consent at any time by contacting us at info@linguistdirectory.com .

 

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 website

·        Other technology on the devices you use to access our website.

This data is automatically collected when you use our website. The purpose is to enable your access to our website. The lawful basis is this is necessary for us to perform our contract with you (i.e., to give you access to the service our website provides).
Cookies Data Like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our website. Please refer to the “Information on cookies” section below for information about cookies and how we use them and what kind. Cookies are small text files placed on your device when you visit our website and are used to make the users’ experience more efficient.

The lawful basis is this is necessary for us to perform our contract with you (i.e., to give you access to the service our website provides).

We also need this information to study how you use our website, in order to improve and develop the services we provide, and better inform our marketing strategies.

Marketing and Communications Data Includes your preferences in receiving marketing from us and our third parties and your communication preferences. The purpose is to enable direct marketing.

The lawful basis is that it is necessary for our legitimate interest to present relevant content, products, and services to you (only where you have provided your consent that we do so).

Analytics Includes third-party analytics services (such as Google Analytics) to evaluate your use of our website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this policy. The purpose is to enable direct marketing.

The lawful basis is that is it necessary for our legitimate interest to present relevant content, products, and services to you.

 When you interact with our website – Information on cookies

 We use cookies in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the Data Protection Legislation 2018.

Cookies are small text files placed on your device when you visit our website and are used to make the users’ experience more efficient. We are able to store cookies on your computer where they are necessary for the operation of our website however, for non-essential cookies we need your permission.

We use cookies to distinguish users and to improve our website. We analyse how you use our website, and we look at aggregate statistics about your usage, and how others use our website. We collect certain information from these cookies, and this includes information about your IP address, your location when you access our website, the date and time you access our website, the language you use and the type of browser you use.

We do not track individual users or use cookies to identify individuals. We use cookies to recognise you and your preferences, improve our website’s performance and collect analytical information for ourselves and our business partners. Without the knowledge gained we would not be able to provide the service we do.

These are the types of cookies we use:

  • ‘Session cookies’ allow us to track your actions during a single browsing session, but they do not remain on your device afterwards; and
  • ‘Persistent cookies’ remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our website.

Session and Persistent cookies can be either first or third party cookies. A first-party cookie is set by the website being visited; a third-party cookie is set by a different website. Both types of cookies may be used by us or our business partners.

The third-party cookies we use are:

  • Google Analytics – this is a web analytics service provided by Google, Inc. The cookies used by Google Analytics help us to analyse how users use our website and to count the number of people who use it. Google Analytics stores your IP address anonymously. Google does not associate your IP address with any personally identifiable information;
  • Facebook Ads (the Facebook pixel) – these cookies collect information about how visitors use our website. This data is collected anonymously and is used to help improve our website’s functionality; and
  • Google Ads – these cookies collect information about how visitors use our website. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our website’s functionality.

All of our cookies are categorised by the role they fulfil on our website:

  1. Strictly Necessary: these are essential to enable you to move around our website and use features such as secure services. Without these cookies such services could not be provided;
  2. Functionality: allow our website to remember your choices and to personalise certain features. These cookies may be anonymised and cannot track your browsing activity on other websites; and
  3. Performance: collect information as to how users use our website. These cookies do not collect information that identifies a visitor. The information collected is aggregated and used to improve our website.
  4. None of the cookies employed are classified as Behavioural Targeting.

We will always ask for your consent to use non-essential cookies. You are free to withhold consent to this, but it means that we might not be able to provide the full website experience to you, including some elements of video advertising.

If at any time you wish to disable cookies, you may do so through the settings on your browser, or whenever the pop-up appears on our website (each time you access our website).

We may process your data for compliance with a regulatory requirement or legal obligation to which we are subject to. Your data will only be processed if processing the data to comply with such obligation is a reasonable and appropriate way of achieving compliance.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does 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 policy.

How we store your personal data

We store all of your personal data on our servers in Slovakia within the EEA and are maintained by our hosting provider, currently Websupport s.r.o.

We may transfer your collected data to storage outside the European Economic Area (EEA) or the United Kingdom. It may be processed outside the EEA or the United Kingdom so that you may receive the services our website provides. If we do store or transfer data outside the EEA or the United Kingdom, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA or the United Kingdom. This means that sometimes we may need to use legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements.

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through our website.

Specifically, we use Google Cloud and Google Workspace to host all personal data collected.  Google’s cloud services employ industry standard security including encryption in transit and at rest and ISO/IEC27001/27017/27018/27701, SOC 1/2/3, PCI DSS, and FedRAMP certifications. For more information, please refer to: https://cloud.google.com/security/. We store website backups on Dropbox. Dropbox files at rest are encrypted using 256-bit Advanced Encryption Standard (AES) and data in transit is protected using Secure Sockets Layer (SSL)/Transport Layer Security (TLS). For more information, please refer here. It is important to note that personal data is encrypted between your device and any external host storage we use.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We will still be responsible for protection of your personal data, even where we have transferred it outside the EEA or the United Kingdom. We regularly review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

 How we disclose your information

We may disclose your information in the following cases:

  • If we want to sell our business, or our company, we can disclose it to the potential buyer;
  • We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006;
  • We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety, or rights; or
  • We can exchange information with others to protect against fraud or credit risks.

We may contract with third parties/subcontractors to supply our services to you on our behalf. These include freelancer copywriters to create pages on behalf of Linguists with a Pro Linguist Subscription cloud services used to send emails and technology providers that assist in providing our services to you. In addition, we use the services of MailChimp for the delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications. Please refer to Mail Chimp’s privacy policy for further information.

Your rights

When you provide us with personal data, you have certain legal rights, and these include:

  • To request access to, deletion of or correction of your personal data held by us at no cost to you;
  • To request that your personal data be transferred to another person (data portability);
  • To be informed of what data processing is taking place;
  • To restrict processing;
  • To object to processing of your personal data; and
  • To complain to a supervisory authority.

If you wish to access, rectify, erase, or transfer your personal data, please contact us at info@linguistdirectory.com .

Notice for California residents of privacy practices and rights

If you are a California resident, California law may provide you with additional rights regarding your personal data.

Your rights

 The California Consumer Privacy Act of 2020 (“CCPA”) gives you the following rights:

  • Right to know about the personal information we collect and share:
    • The CCPA gives you the right to request that we disclose the specific pieces of personal information we have collected about you;
    • Please see above for information on the data we collect on you, and how we process it; and
    • We do not sell your personal information. However, we do disclose your personal data to limited third parties, as described above
  • Right of deletion:
    • You have the right to request that we delete your personal information, subject to certain exceptions
  • If you wish to delete your personal data, please contact us at info@linguistdirectory.com . Please note that we may require certain information from you in order to verify your identity before proceeding with your request.

Disclosures about your personal information

 We collect the categories of personal information from you in connection with your use of our Website as described above.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights.

What happens when we link to other websites?

This policy only relates to our website and our coaching. We might have links on/within our website to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.

Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our website. We have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

The changes we may make to this policy

We can update this policy from time to time as laws change or as our website changes. If we make material changes to this policy, and we need your consent to those changes, we will contact you by email to do so.

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