Privacy and cookies policy

 

1. Introduction


1.1 We are committed to safeguarding the privacy of our website visitors, service
users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the
personal data of such persons; in other words, where we determine the
purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we 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 the profile settings page of your user account on our
website.
1.4 We use cookies on our website. Insofar as those cookies are not strictly
necessary for the provision of our website and services, we will ask you to
consent to our use of cookies when you first visit our website.
1.5 In this policy, “we”, “us” and “our” refer to MyVideoTutor Ltd. For more
information about us, see Section 17.


2. The personal data that we collect


2.1 In this Section 2 we have set out the general categories of personal data that
we process and, in the case of personal data that we did not obtain directly
from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you (“contact data”).
The contact data may include your name, email address, telephone number,
postal address and/or social media account identifiers. The source of the
contact data is the information will have entered to create an account on our
website..
2.3 We may process your website user account data (“account data”). The
account data may include your account identifier, name, email address,
business name, account creation and modification dates, website settings and
marketing preferences. The primary source of the account data is you,
although some elements of the account data may be generated by our
website.
2.4 We may process your information included in your personal profile on our
website (“profile data”). The profile data may include your name, address,
telephone number, email address, profile pictures, gender, date of birth,
educational details and employment details. The source of the profile data is
you.
2.5 We may process information relating to our customer relationships
(“customer relationship data”). The customer relationship data may
include your name, the name of your business or employer, your job title or
role, your contact details, your classification / categorisation within our
customer relationship management system and information contained in or
relating to communications between us and you, or between us and your
employer.
2.6 We may process your personal data that are provided in the course of the use
of our services and generated by our services in the course of such use
(“service data”). The service data may include data on the content

purchased on our platform, the amount of time spent accessing said content,
and data on the usage of our ‘workbooks’ feature . The source of the service
data is you and/or our services.
2.7 We may process information relating to transactions, including purchases of
goods and/or services, that you enter into with us and/or through our 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. The source of the transaction data is you and/or our
payment services provider.
2.8 We may process information contained in or relating to any communication
that you send to us or that we send to you (“communication data”). The
communication data may include the communication content and metadata
associated with the communication. Our website will generate the metadata
associated with communications made using the website contact forms.
2.9 We 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.
2.10 Please do not supply any other person’s personal data to us, unless we
prompt you to do so.


3. Purposes of processing and legal bases

3.1 In this Section 3, we have set out the purposes for which we may process
personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of
operating our website, the processing and fulfilment of orders, providing our

services, supplying our goods, generating invoices, bills and other payment-
related documentation, and credit control. The legal basis for this processing

is our legitimate interests, namely the proper administration of our website,
services and business.
3.3 Publications – We 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 our legitimate interests, namely the publication of
content in the ordinary course of our operations.
3.4 Relationships and communications – We may process contact data,
account data, customer relationship data, transaction data and/or
communication data for the purposes of managing our relationships,
communicating with you (excluding communicating for the purposes of direct
marketing) by email, SMS, post, fax and/or telephone, providing support
services and complaint handling. The legal basis for this processing is our
legitimate interests, namely communications with our website visitors, service
users, individual customers and customer personnel, the maintenance of our
relationships, enabling the use of our services, and the proper administration
of our website, services and business.
3.5 Personalisation – We may process account data, service data and/or usage
data for the purposes of personalising the content and advertisements that
you see on our website and through our services to ensure that you only see
material that is relevant to you. The legal basis for this processing is our

legitimate interests, namely offering the best possible experience for our
website visitors and service users.
3.6 Direct marketing – We may process contact data, account data, profile data,
customer relationship data and/or transaction data for the purposes of
creating, targeting and sending direct marketing communications by email,
SMS, post and/or fax and making contact by telephone for marketing-related
purposes. The legal basis for this processing is our legitimate interests,
namely promoting our business and communicating marketing messages and
offers to our website visitors and service users.
3.7 Research and analysis – We may process usage data, service data and/or
transaction data for the purposes of researching and analysing the use of our
website and services, as well as researching and analysing other interactions
with our business. The legal basis for this processing is our legitimate
interests, namely monitoring, supporting, improving and securing our website,
services and business generally.
3.8 Record keeping – We may process your personal data for the purposes of
creating and maintaining our databases, back-up copies of our databases and
our business records generally. The legal basis for this processing is our
legitimate interests, namely ensuring that we have access to all the
information we need to properly and efficiently run our business in
accordance with this policy.
3.9 Security – We 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 our legitimate interests, namely the protection of our website,
services and business, and the protection of others.
3.10 Insurance and risk management – We 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 our legitimate interests, namely the proper
protection of our business against risks.
3.11 Legal claims – We 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 our 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 – We may also process your personal
data where such processing is necessary for compliance with a legal
obligation to which we are subject or in order to protect your vital interests or
the vital interests of another natural person.


4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and all
its subsidiaries) insofar as reasonably necessary for the purposes, and on the
legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, obtaining professional
advice.
4.3 Your personal data held in our website database will be stored on the servers
of our hosting services providers.

4.4 Financial transactions relating to our website and services are handled by our
payment services providers, Stripe and Paypal. We will share transaction data
with our 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 their respective websites.
4.5 In addition to the specific disclosures of personal data set out in this Section
4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person. We
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.


5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedures, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept
for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 365 days following
the date of the most recent contact between you and us, and for a
maximum period of 730 days following that date;
(b) account data will be retained for a minimum period of 365 days
following the date of closure of the relevant account, and for a
maximum period of 730 days following that date;
(c) profile data will be retained for a minimum period of 365 days following
the date of deletion of the profile by you, and for a maximum period of
730 days following that date;
(d) customer relationship data will be retained for a minimum period of 365
days following the date of termination of the relevant customer
relationship and for a maximum period of 730 days following that date;
(e) service data will be retained for a minimum period of 365 days following
the date of termination of the relevant contract, and for a maximum
period of 730 days following that date;
(f) transaction data will be retained for a minimum period of 365 days
following the date of the transaction, and for a maximum period of 730
days following that date;
(g) communication data will be retained for a minimum period of 365 days
following the date of the communication in question, and for a
maximum period of 730 days following that date; and
(h) usage data will be retained for 730 days following the date of collection.
5.4 If you grant to us a licence to publish any of your personal data, we may
continue to retain and publish that personal data after the end of the relevant
retention period specified in this Section 5 in accordance with the applicable
licence terms, subject to your data subject rights. If we cease to publish such
personal data after the end of the relevant retention period specified in this

Section 5, that personal data will be retained for a minimum period of 365
days and a maximum period of 730 days following the date that publication
ceases.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or
the vital interests of another natural person.


6. Security of personal data

6.1 We will take appropriate technical and organisational precautions to secure
your personal data and to prevent the loss, misuse or alteration of your
personal data.
6.2 We will store your personal data on secure servers, personal computers and
mobile devices, and in secure manual record-keeping systems.
6.3 The following personal data will be stored by us in encrypted form: your
name, contact information, password(s) and cardholder data.
6.4 Data that is sent from your web browser to our web server, or from our web
server to your web browser, will be protected using encryption technology.
6.5 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.
6.6 You should ensure that your password is not susceptible to being guessed,
whether by a person or a computer program. You are responsible for keeping
the password you use for accessing our website confidential and we will not
ask you for your password (except when you log in to our website).


7. Your rights


7.1 In this Section 7, we have listed the rights that you have under data
protection law.
7.2 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 us to rectify inaccurate
personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us 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 we transfer your
personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can
complain about our 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.

7.3 These rights are subject to certain limitations and exceptions. You can learn

more about the rights of data subjects by visiting https://edpb.europa.eu/our-
work-tools/general-guidance/gdpr-guidelines-recommendations-best-
practices_en and https://ico.org.uk/for-organisations/guide-to-data-
protection/guide-to-the-general-data-protection-regulation-gdpr/individual-
rights/.

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


8. Third party websites


8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 In general we have no control over, and are not responsible for, the privacy
policies and practices of third parties.


9. Personal data of children


9.1 Our website and services are targeted at persons over the age of 11.
9.2 If we have reason to believe that we hold personal data of a person under that
age in our databases, we will delete that personal data.


10. Updating information


10.1 Please let us know if the personal information that we hold about you needs to
be corrected or updated.


11. About cookies


11.1 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.
11.2 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.
11.3 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.


12. Cookies that we use


12.1 We use cookies for the following purposes:
(a) authentication and status – we use cookies to identify you when you
visit our website and as you navigate our website, and to help us
determine if you are logged into our website;
(b) shopping cart – we use cookies to maintain the state of your shopping
cart as you navigate our website;
(c) personalisation – we use cookies to store information about your
preferences and to personalise our website for you;

(d) 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;
(e) advertising – we use cookies to help us to display advertisements that
will be relevant to you;
(f) analysis – we use cookies to help us to analyse the use and
performance of our website and services (cookies used for this purpose
are: “_ga*” and “_gid”); and
(g) cookie consent – we use cookies to store your preferences in relation
to the use of cookies more generally.


13. Cookies used by our service providers


13.1 Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.
13.2 We use Google Analytics. Google Analytics gathers information about the use
of our website by means of cookies. The information gathered is used to
create reports about the use of our 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. The relevant
cookies are: “_ga*” and “_gid”.


14. Managing cookies


14.1 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/enhanced-tracking-protection-
firefox-desktop (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://support.microsoft.com/en-gb/help/4468242/microsoft-edge-
browsing-data-and-privacy (Edge).

14.2 Blocking all cookies will have a negative impact upon the usability of many
websites.
14.3 If you block cookies, you will not be able to use all the features on our
website.

15. Cookie preferences


15.1 You can manage your preferences relating to the use of cookies on our
website by visiting your profile

16. Amendments

16.1 We may update this policy from time to time by publishing a new version on
our website.
16.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.
16.3 We may notify you of significant changes to this policy by email.


17. Our details


17.1 This website is owned and operated by MYVIDEOTUTOR LTD.
17.2 We are registered in England and Wales under registration number 14088991.
17.3 You can contact us:
(a) using our website contact form; or
(b) by email, using the email address published on our website.

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