Logie Language Centre

Privacy Policy


Logie Language Centre (we, us, our, the school) is committed to protecting and respecting your privacy. We take the privacy of all of our customers and other users seriously and take care to protect your personal information.

Our Privacy Policy governs any kind of processing where we are acting as a data controller or co-controller (including collection, use, transfer, storage and deletion) of personally identifiable information (any information that may be used to identify a physical person, and any other information associated therewith) about natural persons. This policy applies to our processing of data collected through any means, actively as well as passively from persons located anywhere in the world. We will use the information that you provide to us to deal with enquiries. Any question regarding our processing of personal data may be directed to info@logielanguages.com

This Privacy Policy, together with our website terms and conditions and any other document referred in it, governs the collection, storage and use of personal information collected by Logie Language Centre, via our website, authorised platforms and via any of our third-party language travel operators, language travel agencies as well as other third-party providers to Logie Language Centre.

By accessing or browsing this website, www.logielanguages.com, and by providing information to either Logie Language Centre directly or our third-party agents, you confirm that you have read, understood and agree to this Privacy Policy in its entirety. If you do not agree to this Privacy Policy in its entirety, you must not use this website or provide any personal information to Logie Language Centre or our third-party agents.

About Us

Logie Language Centre (trading name) is a company registered in Scotland (registration number SC516470), whose registered office is at 64 Murray Place, Stirling, Central, Scotland, FK8 2BX.

Logie Language Centre, 1 Logie Road (First Floor), FK9 5JU, Stirling, United Kingdom. Telephone: +44 (0) 1786 406648 Email: info@logielanguages.com

Principles

We will be clear in our dealings with you as to what information about you we will collect and how we will use it. We will use personal information only for the purposes for which it was originally collected and we will make sure we delete it securely where appropriate.

Our websites and social media platforms are accessible via the internet. This means that people around the world who access our websites and social media can see anything you post there, for example, comments about your stay with us.

We will obtain your permission before we post any images of you on social media platforms or for other Logie Language Centre purposes. We moderate all social media platforms and have the right to remove any posts which we deem offensive, inaccurate, derogatory or inappropriate for public consumption. You have the right to ask to have information or images posted on our social media platforms by Logie Language Centre to be removed.

Logie Language Centre collects different types of information about our users for six main reasons:

  • To provide personalised services unique to individual users
  • To help us to monitor and improve the services we offer
  • To keep customers up-to-date about the products and services they have purchased
  • To fulfil contracted services
  • Where permission is given by users, to market products and services to them
  • To provide a safe environment for students

We collect information on you and/or your children or dependents:

  • when you enrol for a course
  • when you complete our Welfare Form for all students on Young Learner programmes
  • when you complete Feedback Questionnaires at various stages of your stay with us
  • through cookies
  • when a third-party language travel operator or agency enrols you for a course
  • when you enter sales promotions and competitions

Type

We will not collect data beyond what is necessary to accomplish those purposes; we will minimise the amount of information we collect from you to what we need to deliver the services required.

We will collect and use your personal information only if we have sensible business reasons for doing so, such as managing a booking or gathering necessary information about a new member of staff, ETO or homestay. We will not use data for purposes other than that for which the data was collected, except as stated herein, or with prior consent.

Except when stated herein, we will not store data in identifiable form longer than is necessary to accomplish its purpose, or as is required by law.

When you access and browse our website (including when you submit personal information to us through data entry fields on the websites) and when you provide information to our third-party language travel operators or agencies which may be passed on to us, we may collect the following information from you:

  • name
  • age and sex
  • postal and email addresses
  • phone number
  • date of birth
  • photo
  • passport details (only when needed for visa and immigration purposes)
  • physical and mental health details (relevant to your stay with us only) including allergy details and dietary requirements.

Storage and Use

We (or third-party data processors acting on our behalf) may collect, store and use your personal information listed above for the following purposes:

  • to make this website available to you and to provide you with content which is tailored to your individual tastes
  • to complete any transactions you make through this website
  • to provide you with services that you request
  • where you have given us your express consent, to disclose your personal information to third parties
  • to carry out our obligations arising from any contracts entered into between you and us.

We will not disclose, sell or rent your personal information to any third party unless you have consented to this. If you do consent but later change your mind, you may contact us and we will cease any such activity.

However, if a third party acquires all (or substantially all) of our business and/or assets, we may disclose your personal information to that third party in connection with the acquisition. We may also disclose your personal information where we are required to do so by applicable law, by a governmental body or by a law enforcement agency.

Finally, we may also collect details about visitors to our websites or other users for the purposes of aggregate statistics, reporting or marketing, though this will not infringe your data protection rights.

We collect information on you:

  • When you apply to join a course or programme at the school.
  • When you contact us for information, via our website, by email, by phone, in person or via social media channels.
  • When you work with us in a commercial capacity (for example as an ETO or partner).
  • When you apply to be a homestay.
  • When you apply to work at Logie Language Centre, and when you are subsequently employed by Logie Language Centre.
  • When you sign up for lessons or to other services.
  • When you give us feedback about your experience of Logie Language Centre.
  • When you use our website.
  • If you post on our social media channels or on our website or blog.

Data Retention

Language Travel Operators or Agents Personal and Contact Information. We will hold data on our databases indefinitely unless asked to remove it.

Students

Booking Information We will hold data on our student database indefinitely unless asked to remove it or make it anonymous. Retaining this data is useful for Logie Language Centre when a repeat booking is made, though all relevant data is checked for accuracy at each time of booking.

Welfare Forms This data is removed 3 months after the student has finished the course.

Registration Forms This data is removed 3 months after the student has finished the course.

Group Leader Police Check Forms This data is removed 3 months after the leader has left.

Payment Details Destroyed or deleted once payment has been processed.

Feedback We reserve the right to produce statistical data from this information and we will ensure that the identity of the person submitting this is kept anonymous to the public unless consent has been given to the contrary. This data is made anonymous at the end of each calendar year.

Homestay Hosts Personal and Contact Information. We will hold data on our databases indefinitely unless asked to remove it.

Third Party Suppliers & Contractors Personal and Contact Information. We will hold data on our databases indefinitely unless asked to remove it.

Information About Children We do not, and will not, knowingly collect information from any unsupervised child under the age of 14. If you are under the age of 14, you may not use this website unless you have the consent of, and are supervised by a parent or guardian.

Transfers and International Transfers We may transfer personal information that we collect from you to third party data processors, or to members of our group of companies or our agents or affiliates in connection with the above purposes. Some of these entities may be located in countries that are outside of the European Economic Area.

Please be aware that countries which are outside the European Economic Area may not offer the same level of data protection as the United Kingdom, although our collection, storage, protection and use of your personal data will continue to be governed by this Privacy Policy. Our website may contain links to and from websites operated by individuals and companies over which we have no direct control. If you follow a link to any of these websites, please note that these websites have their own privacy and terms of use policies and that we do not accept any responsibility or liability for these policies. We advise you to check these policies before you submit any personal data to these websites.

Cookies Our website, like most websites, uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Cookies are stored on your hard drive and contain information about you which you have placed on our site. These cookies enable you to gain access to the website again without re-entering your information. The cookies also help us to monitor the site to enable us to improve it, upgrade it and understand how people are using the site.

Security Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you or third parties transfer over the internet to us.

You have the following rights:

  • the right to ask us to provide you with copies of personal information that we hold about you at any time
  • the right to ask us to update and correct any out-of-date or incorrect personal information that we hold about you
  • the right to withdraw your consent to any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.

If you wish to exercise any of the above rights, please write to us at: info@logielanguages.com

Third Party Sites

Our websites contain links to other websites operated by third parties. Please note that this Privacy Policy applies only to the personal information that we collect through this website and we cannot be responsible for personal information that third parties may collect, store and use through their website. You should always read the Privacy Policy of each website you visit carefully.

LEGAL BASES FOR PROCESSING YOUR DATA

The General Data Protection Regulation (GDPR) establishes 6 legal bases on which we can process your data: these are Consent, Contract, Legal Obligation, Vital Interests, Public Task and Legitimate Interests. For further information about these legal bases and fuller definitions, please refer to the ICO website.

We use different legal bases for processing your data depending on the purpose for collecting your data in the first instance:

1. Booking a course

For all data collected as part of the process of enquiring about, applying for and booking a course or for any other related service (e.g. homestay, airport transfer, social programme, insurance to cover you during your stay, or where you give us feedback about aspects of this provision, we process using Contract or Legitimate Interests, namely the fulfilment of the booking. This may include sharing personal data with our trusted partners such as Educational Tour Operators (ETOs), Government Agencies, Schools, insurance companies, homestay and other accommodation providers and activity and transport providers.

Where required by law to do so, we may also process your data under Legal Obligation.

Where we collect data about our clients’ health, this is managed under Consent. This data is shared internally and with transport and homestay providers only when necessary and appropriate.

2. Other services and uses of clients’ personal data

Any processing of customer data not directly related to the fulfilment of a booking, or related services, such as signing up for newsletters or free lessons on our website, or sending messages to you on behalf of third parties, is managed under Consent. From time to time, we may use elements of the data you supply to target the messages we send to you. For example, we may use your location to send you information about an event or opportunity happening in your area. During your stay, we may take photographs or videos of you, and the use and processing of these is also managed through Consent.

3. Logie Language Centre and commercial partners in the UK and overseas

For all data collected as part of managing our relationship with commercial partners, such as ETOs, Government Agencies and Schools, we process using Legitimate Interest and Legal Obligation, namely the maintenance of the commercial relationship. This may include the secure sharing of some of the personal data of employees of our commercial partners with professional colleagues in other schools or associations for the purposes of developing the commercial relationship.

Logie Language Centre and our ETOs and other commercial partners (for example schools, government and national sponsors) are Joint Controllers of personal data relating to the process of marketing and booking our commercial partners’ clients. We advise all clients to read our Privacy Policy, but also the Privacy Policy of the ETO or school to whom they give their data in their country.

When we transfer additional personal data, such as homestay information, to our commercial partners, this will be limited to data necessary for the performance of a contract made in the interests of the individual. Through our contract with them, we require all of our commercial partners overseas to confirm that they will process this data securely in line with the requirements of GDPR or the equivalent in their country.

4. Logie Language Centre staff and personal data

For all data collected as part of the process of employing and managing staff, we process using Contract, Legal Obligation and Legitimate Interests, namely the employment of the employee. This will include data required for HMRC, pensions, insurance (including staff health insurance cover).

When we take photographs or videos of staff, the use and processing of these for marketing purposes is managed through Consent

5. Logie Language Centre and homestay and accommodation providers

For all data collected as part of the process of recruiting and managing host family providers, we process using Legitimate Interest, namely the maintenance of the relationship with the homestay. We send personal data about our homestays to students and ETOs and other trusted partners so that they know where to go on arrival in the UK and also are able to make contact with their host family prior to arrival or if there is a problem. This may include photos and/or videos of our homestay providers.

Host families and other accommodation providers receive basic information about students who are going to stay with them. This is limited to the information required to process the accommodation booking, and Logie Language Centre remains the controller of this personal data and requires accommodation providers to dispose of it securely when it is no longer required for this purpose.

When we take photographs or videos of host family providers, the use and processing of these for marketing purposes is managed through Consent.

6. Defence of legal claims

We may process any of the personal data identified in this policy 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 Legitimate Interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

7. Insurance, managing risks and obtaining professional advice

We may process any of the personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is Legitimate Interest, namely the proper protection of our business against risks.

We will make it as easy as we can for you to opt out of unwanted processing under Consent, providing it does not restrict our ability to provide you with the primary service you have requested.

We collect data for a wide range of purposes. Data is managed to ensure that it is either erased from our system when it is no longer required for the purpose for which it was collected, retained for legal reasons, or pseudonymised and/or minimised and retained.

SPECIAL CATEGORY DATA/CRIMINAL RECORD DATA

We may request health data from potential students and employees. This data has special protection under the GDPR under the specific conditions listed in Article 9 (2) of the GDPR that processing is necessary either to protect the vital interests of the data subject, (or of another natural person where the data subject is physically or legally incapable of giving consent), or where processing is necessary for the purposes of preventive or occupational medicine or the assessment of the working capacity of an employee. We share health data about clients with trusted partners only when necessary and appropriate where we have consent to do so.

The school has safeguarding responsibilities and carries out PVG checks on all staff and other people who are likely to have direct supervisory responsibility for or unsupervised contact with young people under the age of 18. CHILDREN UNDER 18

We collect or store personal information about children under the age of 18 in the context of managing bookings and directly related products, and for safeguarding purposes. Permission is obtained directly from a legal adult guardian to collect this information through our Parental Consent Form. We also gain consent from parents for the use of photos or video taken during their child’s stay at Logie Language Centre through the Parental Consent Form.

WEBSITE PRIVACY

How we will use information collected by our website

We may use information held about you in the following ways:

  • To process a booking for one of our courses or products.
  • To manage an application to work for the school, or to be a host family.
  • To create a profile for you to help us provide a more personalised service which is suited to meet your preferences.
  • To ensure that content from our site is presented in the most effective manner for you and your computer.
  • To send you our newsletters or provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To allow you to participate in interactive features of our service, when you choose to do so.
  • To notify you about changes to our service.
  • Links from our website

SPECIAL CATEGORY DATA/CRIMINAL RECORD DATA

We may request health data from potential students and employees. This data has special protection under the GDPR under the specific conditions listed in Article 9 (2) of the GDPR that processing is necessary either to protect the vital interests of the data subject, (or of another natural person where the data subject is physically or legally incapable of giving consent), or where processing is necessary for the purposes of preventive or occupational medicine or the assessment of the working capacity of an employee. We share health data about clients with trusted partners only when necessary and appropriate where we have consent to do so.

The school has safeguarding responsibilities and carries out PVG checks on all staff and other people who are likely to have direct supervisory responsibility for or unsupervised contact with young people under the age of 18.

CHILDREN UNDER 18

We collect or store personal information about children under the age of 18 in the context of managing bookings and directly related products, and for safeguarding purposes. Permission is obtained directly from a legal adult guardian to collect this information through our Parental Consent Form.

We also gain consent from parents for the use of photos or video taken during their child’s stay at Logie Language Centre through the Parental Consent Form.

WEBSITE PRIVACY

How we will use information collected by our website

We may use information held about you in the following ways:

  • To process a booking for one of our courses or products.
  • To manage an application to work for the school, or to be a host family.
  • To create a profile for you to help us provide a more personalised service which is suited to meet your preferences.
  • To ensure that content from our site is presented in the most effective manner for you and your computer.
  • To send you our newsletters or provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To allow you to participate in interactive features of our service, when you choose to do so.
  • To notify you about changes to our service.
  • Links from our website

PERSONAL INFORMATION AND YOUR RIGHTS

You have the right to rectify, erase or restrict the processing of your data subject to the exceptions outlined in this policy. You also have the right to withdraw consent to the processing of information for which you have previously given consent. You can contact us at any time to have these details removed from our database or to update this information, subject to satisfactory proof of your identity. You can read more about your individual rights on the ICO website. Logie Language Centre’s registration number with the Information Commissioner’s Office is ZA149941 https://ico.org.uk/concerns / Tel: +44 303 123 1113

You may also request access to the data we hold on you. Provision of such information will be subject to:

a) The payment of a fee (currently fixed at £10)

b) The supply of appropriate evidence of your identity.

We may withhold personal information that you request to the extent permitted by the law.

To make any of these requests relating to your personal data, please contact us at: info@logielanguages.com

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on our website in this document. Please check from time to time to ensure that you are aware of any changes to our Privacy Policy. If we are required to by law, we will obtain your consent to make these changes. Your continued relationship with us will be deemed to signify your acceptance to any changes to our Privacy Policy.

STAFF AND PRIVACY

Any wilful breach of this policy by staff will be regarded as a disciplinary offence and will be dealt with under the school’s formal disciplinary procedures.

Privacy Policy last updated 25 October 2018