1. About this Privacy Policy and our role

www.guidedelearning.com and www.gelielts.com websites (the “Websites” and each a “Website“) and GEL e-learning portals (GEL IELTS prep, GEL Distance Learning and GELnet (our “Portals” and each a “Portal”)) are operated by Guided e-Learning Ltd (“GEL”, “we”, “us” or “our”).

We are a company registered in England and Wales, with company number 05843373. Our registered address is 2nd Floor 32 Brixton Road, London, SW9 6BU.

We take the privacy of our users and visitors to our Website very seriously and we are committed to protecting your personal information. This policy explains how we collect and use any information about you. If you have any questions please contact support@guidedelearning.com.

We are a data controller in respect of any personal data collected by us through our Website, for example when you visit our Website or interact with us for example by completing our online “Contact Us” form, or by emailing, calling or writing to us. We will also be data controller in relation to any data collected and provided to us by any independent learners, who purchase access to one of our publically available Portals.

We also provide bespoke online services to schools. If you are using a Portal dedicated to a specific school (a “School Portal”), whether as a student, teacher or administrator, any personal information about you and generated in connection with your use of such School Portal will be processed by us on behalf of your school. This means that we will be processing it as a data processor for the school, and on your school’s instructions. We will return all such information to your school (or delete it, if your school requires this) when your account expires or is deactivated by your school.

2. The types of information we collect and what we use it for

Information we collect:

When you visit our Website or use one of our Portals, we will collect certain technical information about your visit, including your IP address, for administrative and statistical purposes and to help us improve our Website/Portals. You can find more information about the technical information we collect and how we do so in our Cookies Policy.

We also collect anonymised statistical data for analytical purposes, to give us information about the general usage and pathways through or Website and Platforms.

Information we receive from your school:

If your school arranged for you to use their School Portal, we will receive certain information about you from your school, in order to set up your account. The amount of information will depend on the arrangement we have with your school, but we will normally require your full name, student ID and email, nationality, date of birth/age, telephone number and address (home address and in the UK, if relevant). There may be other pieces of information that we may receive from your school, relating to your course and performance. All this information is necessary for us to provide the best and most effective learning experience, integrated with the school’s requirements, and to help your school in the course administration.

If you are a teacher or administrator, your school will provide us with your full name and email address in order to set up your account on the relevant School Portal(s).

Information you provide to us:

If you are registering to use one of our Portals which is not a School Portal (i.e. it is available to students other than those registered at a specific shool), we will collect certain personal information from you, such as your name, age, date of birth, nationality, passport or ID number, address, e-mail address and phone number, financial or credit card information, and any other data you enter onto the Portal. We may also receive certain personal information from you when you contact us by phone or email. We will need this information to set up and administer your account.

Each time you use one of our Portals (including a School Portal) and use its functionalities, we will store all such information and data on our secure servers. If you are a student, the data stored by us will contain information about your usage of your account, including your interactions with other users (for example teachers or other students). It is necessary for us to store such information, so that each time you log in to your account, you have access to your past activities and progress results. If you are using a School Portal, your school will have access to your progress reports.

If you are a teacher, your account will contain information about you, such as your profile information, your past and planned activities, for example tutorials conducted with students, comments made in discussion forums etc., reports written etc.

For administrators, the information collected and stored by the Portal will be limited to the information about the school, full name, email address and log of activities performed within the School Portal, and will be used by us to manage and administer the account.

Please note that your school (if applicable) and other users may also be able to access the information you make publicly available on the Portal, including any written or audio recordings material submitted by you via the Portal.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

3. Lawful processing

We are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. The following are applicable, depending on the context:

Consent

Where you have provided your consent for our use of your personal information in a certain way, for example where we ask for your consent to send you our newsletter.

Legal obligation

In certain, very rare circumstances, we may be required to process your personal information in order to comply with a legal obligation to which we are subject.

Contractual relationship

If you are a student using one of our publically available Portals (i.e. not a School Portal), we will process your personal information in order to perform our contract with you, i.e. to provide you access to and use of our Portal.

Legitimate interests

We rely on this basis where applicable law allows us to collect and use personal information for our legitimate interests and the use of your personal information is fair, balanced, and does not unduly impact your rights. For instance, it is in our legitimate interest to process personal data of any person who contacts us with an enquiry, in order to respond to such enquiry.

4. Communications

We may, on occasion, collect additional personal information from surveys and competitions, which you will be under no obligation to fill in or return to us. The details you provide will enable us to provide information about our company to you and to contact you by email or text. We will only provide this when you indicate that you wish to receive further information from us on a regular basis.

We like to hear your views to help us improve our service. From time to time we may contact you by email or through our Portal to ask your opinions. If you do not want to be contacted for this purpose, please let us know using our contact details below.

5. Sharing your personal data

We will never pass your personal data to anyone else, except for any successors in title to our business and associated group companies or to suppliers that may process data on our behalf as part of providing a service to you – e.g. to process a payment transaction. We may also need to share your personal information for auditing purposes, if we are under any legal obligations or in connection with any legal proceedings, in order to establish, exercise or defend our legal rights.

If you are using a School Portal, the school, relevant teachers and administrators for the school will have access to some of the information available on your account.

We will not sell your name, address, email address or other personal information about you.

6. International transfers

We are aware that certain countries outside the UK or European Economic Area (EEA) have a lower standard of protection for personal information, including security protections. As a result, we do not currently transfer and store any personal data outside the EEA. If in the future we decide to use suppliers based outside the EEA or who would require transfer of personal data outside the EEA, we will do so only if we can be satisfied that the recipient implements appropriate safeguards (as required by UK data protection laws) designed to protect your personal information.

7. Keeping your data secure

We take the security of your personal data seriously. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

Any payment transaction will be encrypted.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us (see our contact details below).

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

8. How long do we keep your personal information?

If you are using a School Portal, we will retain your personal information for as long as your school requires us to retain it, and we will return or delete it upon your school’s request.

If you are using a publically available Portal, we will keep your personal data for as long as you are signed-up to use and access the Portal. If you fail to access the Portal for a period of 1 year and your subscription or access has expired, we will consider whether it is appropriate to delete your personal information from our records, but we may keep certain information for a longer period of time, if it is necessary for example to show that you have purchased services from us.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer our customer, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

9. Your rights

If you have an account with us, it is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us.

Under certain circumstances, by law, you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information (often referred to as “the right to be forgotten”). This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

• Object to the processing of your personal information 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. You also have the right to object if we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.

• Request the transfer of your personal information to another party.

If you are using a School Portal, you should contact your school if you wish to exercise any of the above rights.

If you are using a publically available Portal and would like to exercise any of the above rights, please:

• email, call or write to us (see our contact details below);

• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill). This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and

• let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.

10. Contacting us or the ICO

Please contact us if you have any questions about this privacy policy or the information we hold about you.

You can email us: support@guidedelearning.com

You can write to us at our registered office:- 2nd Floor 32 Brixton Road, London, SW9 6BU

You can also contact the Information Commissioner’s Office on 0303 123 1113.

11. Changes to the privacy policy

We may change this privacy policy from time to time. This privacy policy was last updated on 21 May 2018.

Our cookie policy

1. What are cookies and tracking technologies?

A cookie is a text file containing a small amount of data downloaded to your computer when you visit our Portal and/or our Website. The vast majority of websites use cookies. Cookies can be useful because they help us select the content of our website and recognise you as a user. Some cookies are essential to enable you to move around our Portal and/or our Website and use its features. A list of all the cookies that we use can be found in our cookie list.

2. The cookies we use now and how to delete them

When you access our Portal and/or our Website you will receive a message advising you that we use cookies. This was necessary in order to display the web pages to you. If you continue to use our Portal and/or our Website, further cookies will be placed on your computer. If you do not want us to place cookies on your computer then you can opt out in multiple ways:

• setting your browser to reject all cookies;

• to only allow “trusted” sites to set them; or

• to accept only those cookies from those websites which you are currently on.

Please remember if you opt out of cookies, our Website and/or our Portal may not be fully functional for you.

For further information please see the website: allaboutcookies.org.

3. Our classification of cookies

1. 1. We classify our cookies in the following ways:

Strictly Necessary

These cookies are essential to enable you to move you around the Portal and/or the Website and use its features, such as accessing secure areas.

Performance

These cookies collect information about how you use our Portal and/or our Website, for instance, which pages you go to most often and if you get error messages from those pages. We only use these cookies to improve how our Portal and/or our Website work.

Functionality

These cookies allow us to remember the choices you make (such as your user name) and provide enhanced features.

4. Our Cookies

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5. Our technology partners

We work with the following companies in maintaining and improving our web pages.

We use Google Analytics to better understand how our customers navigate to and through our web pages, how long customers spend visiting our content items and how often they return to visit our Portal and/or our Website. Google’s privacy policy may be found here:
Privacy Policy

We work with Facebook to promote our products. Facebook’s policies may be found here: Facebook Policies.

We use Cloudflare to improve the performance and security of our servers. Cloudflare’s privacy policy may be found here: Security Policy