Privacy Policy

Introduction

Splendid Learning (referred to as ‘we’ or ‘us’ below) receives and stores information about you, either directly on our own server, or indirectly through companies we use for their services. This privacy policy will outline what information this is, where it is stored, on what legal basis we store it, how you can check what information we have access to about you and how you can ask for removal if appropriate. We use the information that you provide in order to respond to your requests, provide our services and communicate with you. We only collect the information we need to carry out these services. We strive to ensure we are justified in the information we collect, that the information we keep is appropriate and necessary for the services we offer and that it is accurate. We focus at all times on making sure we don’t ask for any information that is not necessary for the functioning of our website and services. We have organised this Privacy Policy into the following sections

• Users of the free resources on our website (splendid-speaking.com)
• Subscribers to our pay-for products and services
• Newsletter and email communication
• General Privacy Conditions – All Users

Each section details important information regarding the use and disclosure of your data in conjunction with the service you have chosen to use. Each section explains on what legal basis under GDPR we have stored your information. For an overview of what these are, visit the ICO website here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/

1) Users of the free resources on our website (splendid-speaking.com)

1.1 Cookies Like many other sites on the web, this site uses small files called ‘cookies’ to help provide you with services and functionality and to help us develop the website further. Some cookies are essential to the functioning of some of our services and others are non-essential. See 1.3/1.4/1.5/1.6 below for an explanation of the legal basis under which we store non-personal and personal information through cookies and how you can manage this data where appropriate. You can find more information about cookies at: 
www.allaboutcookies.org and www.youronlinechoices.eu 
for a video about cookies visit 
www.google.co.uk/goodtoknow/data-on-the-web/cookies
 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Below are links to the ‘Help’ pages of major browsers which explain how you can do this. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site or any other websites that you visit. Internet Explorer | Firefox | Chrome | Safari OS X | Opera | Safari iOS | Windows Mobile 1.2 Server Logs When you use our website, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs collect information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser. The legal basis we collect and store this data in our server logs is for ‘legitimate interest’, namely for the purpose of detecting and preventing fraud and unauthorized system access, and ensuring the security of our systems. 1.3 Analytics Splendid Learning uses Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookies about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For information about Google Analytics and the type of cookies it sets, visit this page on the Google website: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage\” The legal basis under which we store the personal information listed above is ‘Consent’. On your first visit to the site a message will appear at the bottom of the page alerting you to our use of cookies for this and other purposes. Should you wish to continue using the Splendid Speaking website but not have your visits tracked, you can install the Google ‘Opt Out’ browser extension, which can be downloaded here: https://tools.google.com/dlpage/gaoptout For further information about Google and how it collects and stores your data, see the Google Privacy Policy: https://policies.google.com/privacy?hl=en\ 1.4 Google Adsense Some sections of the Flo-Joe website may contain advertisements served by Google. Google, as a third party vendor, uses cookies to serve ads on flo-joe.co.uk/flo-joe.com. Google’s use of the DART cookie enables it to serve ads to splendid-speaking.com users based on their visit to our sites and other sites on the Internet. You may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy. https://policies.google.com/technologies/ads”> The legal basis under which we serve ads is ‘Consent’. On your first visit to the site a message will appear at the bottom of the page alerting you to our use of cookies for this and other purposes. You can, if you wish, turn off ad personalisation by visiting the link below. You will still see ads but these will not be tailored to your interests: https://support.google.com/ads/answer/2662922?hl=en-GB If you prefer to not see adverts at all you can install a ad blocker in your browser. We advise you to search for the current recommended ad blockers. 1.5 Voicethread Flo-Joe uses Voicethread to offer visitors the chance to record themselves doing speaking activities. Voicethread sets the following cookies: VTSESSID GF_-841880044 GP_131903127713413190… UUID The legal basis we collect and store this data in our server logs is for ‘legitimate interest’, namely to provide you with the service you have requested. 1.6 Spreaker Flo-Joe uses Spreaker to deliver some of our audio/podcasts. You can find out more about Spreaker cookies here: https://www.spreaker.com/cookies

2) Subscribers to our pay-for products and services

If, as an individual user, you buy one of our products or services, in addition to the personal information which is collected and stored above (see ‘Users of the free resources on our website (splendid-speaking.com above), we also collect and store basic information. Products such as ‘CAE Speaking Success’, ‘IELTS Speaking Advanced’ and other paid for products are protected from unauthorised usage and to gain access after you’ve paid you need to create a username and password and supply an email address. This information is stored in a database on our server and enables you to login to gain access to the product you have bought and manage your account. Your password is encrypted. We have no interest in knowing your address, telephone or other personal information such as your age or ethnic background and this information is not required when you create your account. We also do not process your debit or credit card payments. After creating your account you are directed to one of our payment providers, PayPal or Securetrading, to make payment. We are not passed any information about your card details. We are able to login to our account on the payment processors website and get information such as your name, email address, the time you made the payment etc, but this is stored on the payment processors website not ours. We also make use of strictly necessary cookies to manage your use of products. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for cannot be provided. The legal basis under which we store this information is to fulfil our contractual obligations to you.

3) Email and Newsletter Communication

We collect the e-mail addresses of those who communicate with us via e-mail, who are making a request for additional information, sign up for our newsletters, purchase one of our products or who are offering feedback. This information is only used to respond to the request made by the visitor. We do not and will not release any e-mails sent to us to any third party for any reason whatsoever without the individual’s consent. The legal basis under which we store this information is ‘Legitimate Interest’ To safeguard your privacy, we use a “confirmed opt-in” system with our newsletters. This ensures that no-one can sign you up to our newsletter without your permission. Splendid Learning uses aWeber to responsibly manage our email campaigns. We will send you email newsletters if you give us permission to do so (by subscribing to our mailing list). We will respect your permission. We will only send you email that is related to what you subscribed to and why you subscribed. We will abide by AWeber’s anti-spam rules and anti-spam laws like CAN-SPAM. You can unsubscribe whenever you want with a click of your mouse. At the end of every newsletter you receive from Splendid Learning you will see an unsubscribe link. Click on that link and you will see an unsubscribe page with two columns marked “Subscribed” and “Unsubscribed”. Click on the button in the “Unsubscribed” column. This will immediately unsubscribe you. Should you have any problems unsubscribing from our newsletters, email Splendid Learning and we will remove your details from aWeber at our earliest convenience. aWeber sets the following cookies: TS8fba11awpopup_1444301963_uniqTScd899e Information about aweber these cookies can be found here. https://www.aweber.com/privacy.htmInformation about Mailchimp cookies can be found here. https://mailchimp.com/legal/cookies/ The legal basis under which we store the personal information listed above is ‘Consent’. On your first visit to the site a message will appear at the bottom of the page alerting you to our use of cookies and other privacy issues.

4) General Privacy

We are committed to protecting the information you provide to us. We take all reasonable security measures to protect personal information from loss, unauthorised access, disjunction, misuse, modification or disclosure. As far as permissible under law, we accept no responsibility for any unauthorised access to information held by us. N.B. We are currently carrying out an audit of all third party cookies and will update this privacy policy when necessary. Your legal rightsYou have the right to: Request access to your personal data. Request correction of the personal data that we hold about you. Request erasure of your personal data. Please note that this Privacy Statement may be updated from time to time. If you have any questions about this document or our terms of use, please contact us.