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PRIVACY & COOKIES POLICY

  1. Introduction

1.1    I am committed to safeguarding the privacy of this website visitors, service users, individual customers and customer personnel.

1.2    This policy applies where I am acting as a data controller and I determine the purposes and means of the processing of that personal data.

1.3    This website incorporates privacy controls which affect how I will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data. You can access the privacy controls via accspanish.com.

1.4    I use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, I will ask you to consent to my use of cookies when you first visit my website.

1.5    In this policy, “I”, “me” and “my” refer to Ana Costa, founder of ACC Spanish. For more information about us, see Section 17.

  1. The personal data that I collect

2.1    In this Section 2 I have set out the general categories of personal data that I process.

2.2    I may process data enabling me to get in touch with you (“contact data“). The contact data may include your full name and email address. 

2.3   I may process your personal data that are provided in the course of the use of my services and generated by my services in the course of such use (“service data“). The service data may include full name and surname, age, profession, location, and teaching preferences for the sake of personalising services.

2.4    I may process information relating to transactions, including purchases of goods and/or services, that you enter into with me and/or through my website (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details.

2.5    I may process information contained in or relating to any communication that you send to me or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. This website will generate the metadata associated with communications made using the website contact forms.

2.6    I may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

2.7    Please do not supply any other person’s personal data to me.

  1. Purposes of processing and legal bases

3.1    In this Section 3, I have set out the purposes for which I may process personal data and the legal bases of the processing.

3.2    Operations – I may process your personal data for the purposes of operating this website, the processing and fulfilment of orders, providing my services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is my legitimate interests, namely the proper administration of my website, services and business.

3.3    Publications – I may process account data, profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is your consent.

3.4    Relationships and communications – I may process contact data, customer relationship data, transaction data and/or communication data for the purposes of managing my relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email or telephone, providing support services and complaint handling. The legal basis for this processing is my legitimate interests, namely communications with my website visitors, service users, individual customers and customer personnel, the maintenance of my relationships, enabling the use of my services, and the proper administration of my website, services and business.

3.5    Personalisation – I may process service data and/or usage data for the purposes of personalising the content and advertisements that you see on this website and through my services to ensure that you only see material that is relevant to you. The legal basis for this processing is your consent.

3.6    Direct marketing – I may process contact data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email for marketing-related purposes. The legal basis for this processing is consent.

3.7    Research and analysis – I may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of this website and services, as well as researching and analysing other interactions with my business. The legal basis for this processing is consent.

3.8    Record keeping – I may process your personal data for the purposes of creating and maintaining our databases, back-up copies of my databases and my business records generally. The legal basis for this processing is my legitimate interests, namely ensuring thatI have access to all the information we need to properly and efficiently run my business in accordance with this policy.

3.9    Security – I may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is my legitimate interests, namely the protection of my website, services and business, and the protection of others.

3.10  Insurance and risk management – I may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is my legitimate interests, namely the proper protection of my business against risks.

3.11  Legal claims – I may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is my legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.12  Legal compliance and vital interests – I may also process your personal data where such processing is necessary for compliance with a legal obligation to which I am subject or in order to protect your vital interests or the vital interests of another natural person.

  1. Automated decision-making

4.1    I will use your personal data for the purposes of automated decision-making in relation to content and directing marketing, including profiling.

4.2    This automated decision-making will involve processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s personal preferences, interests, reliability, and behavior.

4.3    The significance and possible consequences of this automated decision-making are segmented direct marketing and targeted social media content.

  1. Providing your personal data to others

5.1    Contact, service, communication, and usage data will be stored on the servers of my email marketing tool (Active Campaign) and hosting services providers (Site Ground). 

5.2    Financial transactions relating to this website and services are handled by my payment services providers, Paypal. I will share transaction data with my payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.paypal.com/uk/webapps/mpp/ua/privacy-full.

5.3    In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person. I may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

  1. Retaining and deleting personal data

6.1    This Section 6 sets out my data retention policies and procedures, which are designed to help ensure that I comply with my legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    I will retain your personal data until the interested party expresses the wish for the data controller to eliminate the data by email or contact form. This data includes contact, service, communication, and usage data. The purpose of keeping this personal data is stated in section 3. Transaction data will only be kept for compliance with legal obligation as a sole trader. After the appropriate legal process, it will no longer stored.

6.4    If you grant to me a licence to publish any of your personal data, I may continue to retain and publish that personal data after the end of the relevant retention period specified in this Section 6 in accordance with the applicable licence terms, subject to your data subject rights.

6.5    Notwithstanding the other provisions of this Section 6, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Security of personal data

7.1    I will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2    I will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

7.3    The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.

7.4    Data relating to your enquiries and financial transactions that is sent from your web browser to my web server, or from my web server to your web browser, will be protected using encryption technology.

7.5    You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

  1. Your rights

8.1    In this Section 8, I have listed the rights that you have under data protection law.

8.2    Your principal rights under data protection law are:

(a)    the right to access – you can ask for copies of your personal data;

(b)    the right to rectification – you can ask me to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure – you can ask me to erase your personal data;

(d)    the right to restrict processing – you can ask me to restrict the processing of your personal data;

(e)    the right to object to processing – you can object to the processing of your personal data;

(f)    the right to data portability – you can ask that I transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority – you can complain about my processing of your personal data; and

(h)    the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

8.4    You may exercise any of your rights in relation to your personal data by written notice to me, using the contact details set out below.

  1. Third party websites

9.1    My website includes hyperlinks to, and details of, third party websites.

9.2    In general I have no control over, and are not responsible for, the privacy policies and practices of third parties.

  1. Personal data of children

10.1  My website and services are targeted at persons over the age of 16.

10.2  If I have reason to believe that we hold personal data of a person under that age in our databases, I will delete that personal data.

  1. Updating information

11.1  Please let me know by email (hola@accspanish.com) if the personal information that we hold about you needs to be corrected or updated by email. 

  1. About cookies

12.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

12.2  Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.3  Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

  1. Cookies that I use

13.1  I use cookies for the following purposes:

(a)    personalisation – we use cookies to store information about your preferences and to personalise our website for you;

(b)    security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(c)    advertising – we use cookies to help us to display advertisements that will be relevant to you;

(d)    analysis – we use cookies to help us to analyse the use and performance of our website and services; and

(e)    cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

  1. Cookies used by our service providers

14.1  My service providers use cookies and those cookies may be stored on your computer when you visit this website.

14.2  I use Google Analytics. Google Analytics gathers information about the use of this website by means of cookies. The information gathered is used to create reports about the use of this website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

14.3  I publish Google AdSense advertisements on this website. The advertisements may be personalised to reflect your interests. To help determine your interests Google and its partners use cookies. The cookies are used to track your previous visits to this website and your visits to other websites. You can opt out of Google’s personalised advertising by visiting https://www.google.com/settings/ads and you can opt out of third party cookies use for personalised advertising by visiting http://www.aboutads.info. You can review Google’s privacy policy at https://policies.google.com/privacy.

14.4  I use a Facebook pixel on thiswebsite. Using the pixel, Facebook collects information about the users and use of this website. The information is used to personalise Facebook advertisements and to analyse the use of this website. To find out more about the Facebook pixel and about Facebook’s use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook’s use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.

  1. Managing cookies

15.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647 (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

15.2  Blocking all cookies will have a negative impact upon the usability of many websites.

15.3  If you block cookies, you will not be able to use all the features on this website.

  1. Amendments

16.1  I may update this policy from time to time by publishing a new version on this website.

16.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

16.3  I will notify you of significant changes to this policy by email.

  1. ACC Spanish details

17.1  This website is owned and operated by Ana Costa.

17.2  The principal place of business is at Ulsterville Avenue, BT9 7AT, Belfast, Northern Ireland.

17.3  You can contact Ana, founder of ACC Spanish:

(a)    using the website contact form;

(b)    by email (hola@accspanish.com)

17.2  ACC Spanish is registered in Northern Ireland under registration number [number].

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