PRIVACY POLICY – ICU English

Detailed information on Data Protection regarding the processing of student data

Who is the Data Controller for your data?

Identity:                         ICU English Limited

Company Number:     07611746

ICO Reference:             ZA145544 
Postal Address:            362 Essex Road, Islington, London N1 3PD, United Kingdom

Telephone No:             +44 20 7288 9020

E-mail:                            [email protected]
Data Protection Officer: Salih YILMAZ

Contact DPO:                [email protected]

 

Why do we need to process your personal data?

At ICU ENGLISH, we process the information provided by the people who sign up to the ICU English platform so that they can access the platform, and we can manage their training activity correctly, as well as invoicing and receiving payment for the contracted services.

In addition, in cases where the person grants his/her consent, we will use the data to send promotions and personalised commercial information about ICU English by e-mail.

You are hereby informed that ICU ENGLISH also uses algorithms that enable automated decision-making for the following purposes:

• Sending commercial e-mails based on use of the ICU English platform and demographic variables
• Automatic marking of exercises and exams
• Adapting the courses automatically, depending on the user and their use of the platform
• Automatically assigning a level to the student based on the results of the knowledge test
• Providing automated tutoring, which involves sending the student automated feedback based on his/her progress

 

How long will we keep your data?

The data provided will be kept as long as the interested party does not ask for it to be deleted, since we keep the level of English attained, along with other information, for the period required in order to maintain student files in accordance with the regulations applicable to academic records.

 

What is the legal basis for the processing of your data?

The legal basis for processing the data is the consent of the interested party, as well as the fulfilment of a contract for the provision of services in the case of persons signed up to our courses.

The prospective offer of products and services is based on the requested consent, and the withdrawal of this consent will not in any case affect the provision of the requested service.

The processing of personal data for the purposes of direct marketing is understood to be based on legitimate interest, and the interested party may, at any time and at no extra cost, oppose such processing, insofar as it is related to said direct marketing, regardless of whether it relates to initial or subsequent data processing.

 

Who will receive your data?

ICU ENGLISH contracts its virtual infrastructure on the basis of a “cloud computing” model through different providers located both inside and outside the EU. Providers from outside the EU comply with the “EU-US Privacy Shield” framework:

• Google LLC
• Amazon Web Services, Inc.

Also, ICU ENGLISH manages the collection of payments through payment management services, such as PayPal and Stripe. Student data may be sent to these platforms for the purpose of managing payment for the contracted services.

Finally, the data of students who decide to take official exams may be communicated to the institutions offering those exams, such as Cambridge Assessment and PeopleCert

No other communication of data is foreseen, unless it is required to comply with legal obligations.

 

What are your rights when you provide us with your data?

Everyone has the right to receive confirmation about whether or not we, at ICU ENGLISH, are processing personal data relating to them.

Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, request deletion thereof when, among other reasons, the data is no longer required for the purposes for which it was collected.

In certain circumstances, the interested parties may request limitation of the processing of their data, in which case we will only keep said data for the initiation or defence of claims.

In certain circumstances and for reasons relating to their particular situation, interested parties may object to the processing of their data. ICU ENGLISH will cease to process the data, except for legitimate reasons for the initiation or defence of possible claims.

Based on the right of portability, interested parties have the right to obtain the personal data related to them in a commonly-used, structured, machine-readable format and to transfer the data to another controller.

 

 

How can you exercise your rights?

In writing, attaching a photocopy of your Identity Document or equivalent identification document, addressed to ICU ENGLISH, 362 Essex Road, Islington, London N1 3PD United Kingdom

 

What complaint procedures are available?

If you think that your rights have not been properly considered, you have the right to file a claim with the UK Information Commissioner’s Office.