Privacy policy
1. General provisions
1.1. This privacy policy (hereinafter – the Policy) regulates the main principles and rules regarding the collection, processing and storage of personal data carried out by DARIUS LUKAS PTE. LTC, registration No 201922226E, address of registration: 7 Temasek boulevard #12-07 Suntec Tower One, Singapore 38987 (hereinafter – we, Data administrator), and terms of operation of our website www.clubuldeenglezaonline.ro (hereinafter – the Website).
1.2. We aim to ensure that the users of our goods or services, visitors to the Website, candidates for employment and other persons whose personal data we process, would entirely trust our services and would be informed in a transparent manner of how we process their data. In this Policy you shall find information on how we collect and use (or would like to collect and use) your personal data.
1.3. In our business operations, we are guided by the following data processing principles:
1.3.1. Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject (principle of lawfulness, fairness and transparency);
1.3.2. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (principle of purpose limitation);
1.3.3. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (principle of data minimisation);
1.3.4. Personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (principle of accuracy);
1.3.5. Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required to safeguard the rights and freedoms of the data subject (principle of storage limitation);
1.3.6. Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (principle of integrity and confidentiality);
1.3.7. We are responsible for following, and for competence to demonstrate compliance with, the abovementioned principles (principle of accountability).
1.4. This Policy has been prepared in accordance to the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter – the GDPR). The notions used in this Policy shall be understood as defined in the GDPR.
2. Personal data collection, processing, storage
2.1. By providing your personal data, you agree to us processing it for purposes and by means and order laid out in the Policy and laws.
2.2. It is very important that you read the Policy carefully, because when you visit the Websites, purchase and use our services, apply for employment and submit personal data for other purposes, this Policy will be directly applicable to the collection, processing, and, in the cases provided for in the Policy, transition of your personal data to recipients.
2.3. If you do not agree with this Policy and the processing of personal data described therein, please do not visit the Websites and / or use our services
2.4. You are responsible for ensuring that the data you provide is precise, correct and detailed. The input of incorrect data is considered to be a violation of the Policy. If the data provided changes, you must immediately inform us about it. We shall under no circumstances be responsible for damages that may arise for you and (or) third parties if you provide incorrect and (or) undetailed personal data or did not request supplementation and (or) correction of data when they changed.
2.5. The entities to which we may disclose your personal data are described in each of the data processing activities laid down below.
2.6. Your personal data are obtained in the following ways:
2.6.1. When you provide the necessary data for purchasing goods and services;
2.6.2. When you use the data from the Website (material about the purchased product or other payable or free material, e-books);
2.6.3. When you take part in competitions or surveys;
2.6.4. From the user‘s account.
2.6.5. When you submit data in other ways agreed by the Parties on the Sata administrator‘s request or on your initiative.
3. Processing of personal data for the purpose of selecting candidates for employment
3.1. If you decide to contact us for recruitment, we will process personal data submitted by you as a candidate for recruitment purposes or for purposes of purchasing services from freelancers.
3.2. The legal basis for processing personal data is Article 6 (1) (a) (Your consent given by submitting your data) and (b) (processing in order to take steps prior to entering into a contract) of the GDPR.
3.3. We shall ensure that only the allowed personal data of you as the candidate is processed.
4. Processing of personal data for the provision of services and marketing purposes
4.1 We provide the English language teaching services and related products and therefore need to use your personal data for the following purposes related to the provision of services:
4.1.1. Credit card authorization to ensure payment. Legal basis for processing personal data for this purpose is Article 6 (1) (b) (performance of a contract or necessary steps prior to entering into a contract);
4.1.2. Administration of internet buyer (clients profile) account. The legal basis for processing personal data for this purpose is Article 6 (1) (b) (performance of a contract or necessary steps prior to entering into a contract);
4.1.3. Conclusion and execution of contracts on purchasing products or services. The legal basis for processing personal data for this purpose is Article 6 (1) (b) (performance of a contract or necessary steps prior to entering into a contract);
4.1.4. Conclusion and execution of collaboration contracts with suppliers. The legal basis for processing personal data for this purpose is Article 6 (1) (b) (performance of a contract or necessary steps prior to entering into a contract);
4.2. Where your personal data are necessary for us to perform the contract or to fulfil our legal obligations, the submission of personal data is necessary as we otherwise will not be able to provide you with our services.
4.3. For the purposes mentioned above, the following personal data received directly from clients or third parties – payment administration companies or banks – are processed (depending on the purpose, the personal data are processed within different extent):
4.3.1. Name;
4.3.2. Surname;
4.3.3. Date of birth (when requested);
4.3.4. Passport number (when requested);
4.3.5. Bank card type, number and expiry date;
4.3.6. Address of residence (when requested);
4.3.7. E-mail address;
4.3.8. Telephone number (when requested);
4.3.9. Information about the visit to the website;
4.3.10. Other information necessary for provision of specific services.
4.4. Personal data processed for these purposes may be made available to companies that provide IT services, acting as data processors.
4.5. For the purposes of provision of services, your data will be processed by e-mailing the information directly related with the purchased product or service, regarding their content, applied method, checking familiarization with the information or reminders, to the address provided by you.
4.6. Your personal data shall be processed for marketing purposes only on your consent. Personal data processing for marketing purposes shall be performed by e-mailing to you the information about the possibility of extended learning, other products offered by Data administrator, events of the teaching/learning community or invitations.
5. Processing of personal data for video monitoring purposes
5.1. Video monitoring is not carried out.
5.2. After purchasing some teaching products on the website, the real-time teaching session may be video monitored and used for students‘ information or for other educational, service promotion or other purposes pursued by the Data administrator. In all cases we shall apply for your advance consent about video monitoring and its use and immediately shall take into consideration your later refusal to use the recording and shall remove it.
6. Processing of personal data for debt management purposes
6.1 If you, as our contractual client, delay paying for our services, we may be forced to process the following personal data received from you for debt management purposes:
6.1.1. First name;
6.1.2. Last name;
6.1.3. Telephone number;
6.1.4. E-mail address;
6.1.5. Other data necessary in this context.
6.2. The legal basis for the processing of personal data is GDPR Article 6 (1) (f) - our legitimate interest in receiving payment for the services provided.
6.3. We may transfer your data we process for this purpose to third parties - courts, bailiffs, and we use companies that provide IT to services to us, acting as data processors, and lawyers.
7. Processing of personal data for accounting purpose
7.1. When you use our services, we process the following personal data for the accounting purposes:
7.1.1. First name;
7.1.2. Last name;
7.1.3. Address;
7.1.4. E-mail address;
7.1.5. Telephone number;
7.1.6. Data about means of payment, payment sum, time.
7.2. Legal basis for the processing of personal data are GDPR Article 6 (1) (b) - conclusion and execution of the contract, (c) - execution of legal accounting obligations applicable to us.
7.3. We do not transfer your data we process for this purpose to third parties, but for their processing we use companies that provide IT services to us as data processors.
8. Procedures and retention periods of personal data storage
8.1. By processing and storing your personal data We shall implement organizational and technical measures that would ensure protection of personal data from accidental or unlawful destruction, modification, disclosure and any other means of unlawful processing.
8.2.We apply different retention periods for storing personal data depending on the purpose for which your personal data are processed.
8.3.We apply the following retention periods for personal data storage:
|
Nr. |
Purpose of processing personal data |
Retention period |
|
Selection of candidates for employment |
Until the end of the screening period |
|
|
Personal data processing for the selling, service provision and marketing purposes |
Three (3) years after the last visit |
|
|
Accounting |
10 years from the date of issue of the accounting document |
|
|
Credit card authorization or confirmation to ensure payment |
One (1) year after receipt of the data |
|
|
Video montoring |
3 years after the recording |
|
|
Administration of clients‘ profiles |
3 years after the last visit |
|
|
Management of debts |
1 year from the date of the debt recovery |
|
|
Conclusion and execution of contracts on collaboration with employees and freelance suppliers |
|
8.4. Exceptions to the above-mentioned retention periods may be determined to the extent that such deviations do not violate the rights of you as the data subjects, comply with legal requirements and are properly documented.
8.5. In the event that your certain personal data will be required for the purpose of bringing, enforcing or defending legal claims, we will retain them to the extent that they are necessary to achieve such purposes in a judicial, administrative or extrajudicial procedure.
9. Your rights
9.1. You shall at any time have the right, by providing us a request, to access your personal data processed by us and to receive information on how your personal data is processed, to rectify your incorrect, incomplete or inaccurate personal data, and to ask to suspend, except for storage, personal data processing actions if the data is processed in violation of legal requirements.
9.2. You shall have the right at any time to press button „Unsubscribe“ at the bottom of the e-message. By this you will suspend personal data use for information and marketing purposes. If you have a payable account, the options of the received information may be chosen in your account.
9.3. To the extent that the processing of personal data is based on consent, you have the right to withdraw the consent at any time without affecting the legitimacy of consent-based data processing prior to the withdrawal of consent.
9.4. You can exercise your rights by submitting a written application by e-mail [email protected] or by posting off your request to the address of Data administrator.
10. Contact information and complaint submission
10.1. If you have any questions regarding the protection of personal data, please kindly contact us by e-mail [email protected].
10.2. If you are not satisfied with our response or think that we are processing your data in a way that does not comply with legal requirements, you have the right to file a complaint with the State Data Protection Inspectorate of the Republic of Lithuania as a supervisory authority or with personal data protection institution of your country.
11. Information about the use of cookies
11.1. When you visit the Websites, we desire to provide such content and functionality that would best suit your needs. To this end, cookies are used. Cookies are small-volume text files stored on your browser or device (personal computer, mobile phone, or tablet).
11.2. With cookies we aim to provide a more enjoyable experience for the persons browsing the Websites and to improve the Websites themselves.
11.3. The cookies used on the Website can be grouped into these types:
11.3.1. Cookies that are essential for the website's operation are designed to enable the site to perform its core functions. These cookies allow you to browse the website and use its preferred features; for example, to provide access to secure areas for a particular site; Functional cookies improve your experience on the website. For example, these cookies can store such information as your username when connecting to the website. These cookies can be used to provide services you request, for example, in order to request shipment collection and delivery services or to use services of the third party, for example, social media functions.
11.3.2. Activity (analytical) cookies collect anonymous information about how the visitors use the website. By providing information about visited areas, time spent on specific pages of the website and any problems you encounter, such as error messages, these cookies help us understand how visitors behave on the website. This information helps us to improve the website’s performance.
11.3.3. Marketing cookies are used for observation of visitors on different websites. Commercials are shown, which are relevant and attractive to individual users meaning that they are more valuable for publishers and advertisers of the third parties.
11.3.4. With the help of cookies, we use IP addresses of the Websites` visitors. IP address – computer identifier on internet protocol networks. They can be used to collect different statistical and demographic information for the Website administration and for network error diagnostics but are not used to determine your identity. By using cookies, we collect data on the use of services.
11.3.5. Detailed information on the use of cookies:
11.3.5.1. Functional cookies
|
Name |
Provider |
Purpose |
Expiry |
Type |
|
[SessionID#27] |
Pending |
3 years |
HTTP Cookie |
|
|
__cfduid |
www.anglukalbosklubas.com |
Used by the content network, Cloudflare, to identify trusted web traffic. |
29 days |
HTTP Cookie |
|
__paypal_storage__ |
Used in context with the PayPal payment-function on the website. The cookie is necessary for making a safe transaction through PayPal. |
Persistent |
HTML Local Storage |
|
|
__stripe_mid |
This cookie is necessary for making credit card transactions on the website. The service is provided by Stripe.com which allows online transactions without storing any credit card information. |
1 year |
HTTP Cookie |
|
|
__stripe_sid |
This cookie is necessary for making credit card transactions on the website. The service is provided by Stripe.com which allows online transactions without storing any credit card information. |
1 day |
HTTP Cookie |
|
|
_kjb_session |
Pending |
1 day |
HTTP Cookie |
|
|
akavpau_ppsd |
This cookie is provided by Paypal. The cookie is used in context with transactions on the website. The cookie is necessary for secure transactions. |
Session |
HTTP Cookie |
|
|
connect.sid |
The cookie is necessary for secure log-in and the detection of any spam or abuse of the website. |
Session |
HTTP Cookie |
|
|
CookieConsent |
Stores the user's cookie consent state for the current domain |
1 year |
HTTP Cookie |
|
|
https://q.stripe.com/ |
This cookie is necessary for making credit card transactions on the website. The service is provided by Stripe.com which allows online transactions without storing any credit card information. |
Session |
Pixel Tracker |
|
|
m |
Determines the device used to access the website. This allows the website to be formatted accordingly. |
10 years |
HTTP Cookie |
|
|
ts |
Used in context with the PayPal payment-function on the website. The cookie is necessary for making a safe transaction through PayPal. |
Session |
Pixel Tracker |
|
|
ts_c |
Used in context with the PayPal payment-function on the website. The cookie is necessary for making a safe transaction through PayPal. |
3 years |
HTTP Cookie |
|
|
undefined |
Pending |
Persistent |
HTML Local Storage |
|
|
vs_uniques_landing_page |
www.anglukalbosklubas.com |
Pending |
20 years |
HTTP Cookie |
|
vs_uniques_offer |
www.anglukalbosklubas.com |
Pending |
20 years |
HTTP Cookie |
|
wistia-video-progress-3pc10e1ds7 |
Pending |
Persistent |
HTML Local Storage |
|
|
wistia-video-progress-egnt95k8f8 |
Pending |
Persistent |
HTML Local Storage |
|
|
wistia-video-progress-ob1c8h4zzm |
Pending |
Persistent |
HTML Local Storage |
|
|
wistia-video-progress-swar4mdob1 |
Pending |
Persistent |
HTML Local Storage |
|
|
wistia-video-progress-ve4e31ozkq |
Pending |
Persistent |
HTML Local Storage |
- Analytical cookies
|
Name |
Provider |
Purpose |
Expiry |
Type |
|
_ga |
Registers a unique ID that is used to generate statistical data on how the visitor uses the website. |
2 years |
HTTP Cookie |
|
|
_gat |
Used by Google Analytics to throttle request rate |
1 day |
HTTP Cookie |
|
|
_gid |
Registers a unique ID that is used to generate statistical data on how the visitor uses the website. |
1 day |
HTTP Cookie |
|
|
loglevel |
Collects data on visitor interaction with the website's video-content - This data is used to make the website's video-content more relevant towards the visitor. |
Persistent |
HTML Local Storage |
|
|
wistia |
Used by the website to track the visitor's use of video-content - The cookie roots from Wistia, which provides video-software to websites. |
Persistent |
HTML Local Storage |
- Marketing cookies
|
Name |
Provider |
Purpose |
Expiry |
Type |
|
_fbp |
connect.facebook.net |
Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. |
3 months |
HTTP Cookie |
|
ads/ga-audiences |
Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behavior across websites. |
Session |
Pixel Tracker |
|
|
fr |
Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. |
3 months |
HTTP Cookie |
|
|
tr |
Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. |
Session |
Pixel Tracker |
11.6. You can delete or block cookies by selecting the appropriate settings in your browser that allow you to cancel all or some cookies. Each browser is different, so if you don't know how to change your cookie settings, you should find this information in its help menu. It should be noted that by using browser settings that block cookies (including essential cookies), you may experience problems using all or part of the Websites’ features.
12. Processing of personal data carried out by third parties
1.2.1. Under certain conditions we can disclose your information to other parties than described above:
1.2.1.1. In order not to violate the law or to respond to a mandatory claim in court proceedings (for example, upon receipt of a court request to provide data);
1.2.1.2. To confirm the legitimacy of our actions;
1.2.1.3. To protect our rights, assets or secure them;
1.2.1.4. In other cases, with your consent or legitimate request.
12.2. Any personal data you provide to us may be transferred to competent authorities in the cases expressly provided for by law.
12.3. The Website provides links to our accounts on social networks. By using third-party services such as visiting our Facebook social network account may be subject to third-party terms and conditions. It is therefore advisable to familiarize yourself with the terms they apply when using such third-party services:
12.3.1. On social networking service „Facebook“ the data policy is given at: https://www.facebook.com/policy.php;
12.3.2. On social networking service „LinkedIn“ the privacy policy (in English) is given at: https://www.linkedin.com/legal/privacy-policy;
12.3.3. On social networking service „Instagram“ the privacy policy (in English)is given at; https://help.instagram.com/155833707900388.
12.4. We would also like to draw your attention to the fact that the Website contains links to the websites of other persons, companies or organizations, and that we are not responsible for the content of such websites and/or the methods used by them to enforce their privacy policies, so, before submitting any information about yourself on another website, you should consult their terms and conditions, privacy policy and other information provided on the other website.
13. Final provisions
13.1. Legal relations related to this Policy shall be governed by GDPR and, in case of a dispute, by the law of the Republic of Lithuania.
13.2. We are not accountable for damages, including damages resulting from interference with usage of the Website, damage or loss of data arising from an act or omission by you or third parties acting on your behalf, including incorrect input of data, other mistakes, conscious malicious behaviour and other wrongful use of the Websites. We shall also not be held responsible for any interference of the Website log in and / or functioning and (or) resulting damage that arises from acts or omissions of third parties not associated with the User, including issues with electricity, web access, etc.
13.3. This Policy shall be reviewed and, if necessary, updated at least once every two years. Policy additions or changes shall take effect from the date of their publication on the Websites.
13.4. If you use the Website and our services after the Policy update, we will assume that you do not object and are familiar with the changes made.
13.5. Last modified: 04.03.2020.