Privacy Policy

Introduction and Contact Details of the Data Controller

First of all, genuine-english.com takes your privacy very seriously. This policy has been written in the spirit of the founding principles of the business; to be open, fair, and genuine. This privacy policy applies between you, the user of this website, and Joseph Simpson t/a (trading as) genuine-english.com, the owner and provider of this website. This policy has been created by the data controller, Joseph Simpson. To the best of his knowledge, this document complies with the requirements of the GDPR (General Data Protection Regulation). This policy applies to the use of any and all data collected by Joseph Simpson t/a genuine-english.com or provided by you in relation to your use of this website, including your use of the shop.

You are strongly encouraged to read this privacy policy carefully and contact the Data Controller via any of the below methods if you have any questions or concerns about the privacy practices that genuine-english.com follows:

Data Controller: Joseph Simpson
Email: hello@genuine-english.com
Phone: +44 (0) 7774184580
Post: Office 2/3, 2nd Floor, 48 West George Street, Glasgow, G2 1BP.

Definitions and interpretation

In this privacy policy, the following definitions are used.

Data = collectively all information that you submit to genuine-english.com via the website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws.

Data Protection Laws = any applicable law relating to the processing of personal data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations, and secondary legislation.

GDPR = the UK General Data Protection Regulation

genuine-english.com, we or us = Joseph Simpson t/a genuine-english.com and/or individuals employed by Joseph Simpson acting in the course of their employment or engaged as a consultant or otherwise providing services to Joseph Simpson.

User or you = any third party that accesses the website and is not either (i) employed by Joseph Simpson and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Joseph Simpson and accessing the Website in connection with the provision of such services.

Website - the website that you are currently using, genuine-english.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

Scope of this privacy policy:

This privacy policy applies only to the actions of genuine-english.com and users with respect to this website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites. For purposes of the applicable Data Protection Laws, Joseph Simpson, is the “Data Controller”. This means that Joseph Simpson determines the purposes for which, and the manner in which, your data is processed.

Data processing when you use the website or contact us via the website, email, post, or phone.

How genuine-english.com collects data.

1. Data is given to genuine-english.com by you

2. Data is collected automatically

The data that is provided by you.

If you complete one of the contact forms on the website, or contact genuine-english.com by telephone, post, email, or through other means, genuine-english.com will collect the following information if you provide it:

• Your name (required to submit the contact form)
• Your email address (required to submit the contact form)
• Your telephone number (optional)
• Information about you that is related to the products/services we offer (optional)
• Your learning goals (optional)
• How we can help you (optional)
• Additional information that you provide related to your enquiry (optional)
• A sample of your writing (optional)
• The purpose/audience of your writing (optional)
• The type of writing review you are interested in purchasing
• If you have a deadline for your writing to be completed by (optional)
• Additional relevant information related to a writing review enquiry (optional)

In each case, data is collected in accordance with this privacy policy.

Data that is Collected Automatically

Cookies

genuine-english.com uses third-party website tracking technologies to provide and continually improve our services, and to display advertisements according to users’ interests. You may agree, revoke, or change your consent at any time with effect for the future.

IONOS SiteAnalytics

The website uses IONOS SiteAnalytics. IONOS SiteAnalytics does not store any personal data of website visitors. Tracking and Logging data is collected exclusively for statistical evaluation and technical optimisation of the website. The following data is collected:

• Referrer (previously visited website)
• Requested website or file
• Browser type and browser version
• Operating system used
• Device type used
• Time of Access
• IP address in anonymised form (used only to determine the location of access)

No data will be passed on to third parties.

For more information about IONOS SiteAnalytics, please see the link: https://www.ionos.co.uk/help/data-protection/data-processing-of-website-visitors-of-your-11-ionos-product/data-collection-for-siteanalytics/

In each case, data is collected in accordance with the privacy policy.

How genuine-english.com uses personal information provided by you:

The primary usage of personal information is to provide you with goods and services, namely, English language teaching/learning resources, lessons, and branded merchandise. We use your personal information to communicate with you in order to deliver such goods/services.

With your permission, we may contact you with marketing and promotional materials related to the goods and services we offer. You must opt in to marketing and can opt out at any time.

Your personal information is used if genuine-english.com needs to contact you regarding a product/service you have purchased or enquired about. Your personal information may be used for the administration of the services you have enquired about or purchased.

No personal data will be passed on to any third parties.

How genuine-english.com uses the data that is collected automatically

This data is used for statistical evaluation and technical optimisation of the website only. No data will be passed to any third parties.

Data processing when you make a purchase via the genuine-english.com online shop

Processing Payments via the genuine-english.com shop:

genuine-english.com uses a website builder and online shop provided by IONOS Ltd., a trusted website and online shop provider in the UK. Some or all of the personal and financial details you submit when making a purchase may be processed by 3rd parties when you purchase a product from the genuine-english.com online shop. Generally, for a payment to be processed you will need to provide some or all of the following details when prompted to do so:

• Full Name
• Email Address
• Billing Address
• Delivery Address
• 16-digit bank card number
• The expiry date of your bank card
• Your CVV code (3-digit number on the back of your bank card)
• The name of the bank

Some payment providers (e.g. Paypal) may ask you to sign into your account to make/confirm the payment.

At the point of sale, you will also be asked to confirm that you agree with the genuine-english.com privacy policy, terms and conditions of sale, and the booking and cancelation policies related to your purchase. If you are not requested to tick a box to confirm your agreement to these terms, completing the payment process will be considered your agreement to the policies and terms of sale mentioned in the previous sentence.

The third parties that may process your data will depend on the method of payment/payment processor you choose. This personal and financial data is processed in accordance with the privacy policies of the third party companies which process transactions through our website. The details of the third party companies who process transactions and therefore may process your personal and financial data will be available to you at the point of sale. All third party payment processing companies are expected to comply with PCI DSS. To be absolutely certain that this is the case, please check with the third party payment provider before making a purchase via genuine-english.com.

At the point of sale on the genuine-english.com online shop, genuine-english.com may collect a limited amount of personal data if required to complete the transaction and provide you with the service/product. The data we may collect includes:

• Your full name
• Your delivery address
• Your email address
• Your phone number


This data will be processed in accordance with this privacy policy and will not be passed on to third parties. The data will only be used to contact you regarding your purchase (to deliver the service or product you have purchased to you), unless you have confirmed that you also wish to receive marketing from us in the future.

Please note the following key points related to payments made via the genuine-english.com online shop

1. genuine-english.com does not keep a record of your financial details and to the best of our knowledge does not have access to any financial information inputted into our online shop.
2. If you have purchased a product in which your delivery address is required, we will process that personal data in accordance with this policy. Please see Delivery of physical products below for more details.
3. If you have purchased a product or service and we need to get in touch with you to arrange and/or provide it, we will do so using the personal information you have provided. That personal information will be processed in accordance with this policy.

Delivery of physical products

If you purchase a physical product (not a digital product) via the genuine-english.com online shop, you will need to provide your delivery address to a 3rd party delivery service in order to receive the product. This data will be processed by a 3rd party company. For more details related to how the 3rd party delivery company processes your data, please see the privacy policy of the 3rd party delivery company you pick to deliver the product.

In very limited circumstances, you may decide to allow genuine-english.com to arrange the delivery of your physical product on your behalf. In this case, with your express permission, we will collect the relevant delivery details from you and provide these details to a third party delivery company (e.g. the post office). You will be informed which third party company we have provided your personal details to. Your delivery details will be processed by us, in accordance with the privacy policy, and by a 3rd party delivery company, in accordance with the 3rd party company’s privacy policy.

Automatic data collection when you use the online shop.

The usage of cookies and IONOS SiteAnalytics is the same when using the shop as it is when you generally use the website. Please see the sections of the policy titled, ‘data that is collected automatically’ and ‘how genuine-english.com uses the data that is collected automatically’ to learn more about automatically collected data.

Purchasing products and services via bank transfer:

In limited circumstances, it may be necessary to process payments for genuine-english.com services and products via bank transfer. In the event that this is the case, we will provide you with an invoice which includes our bank account details.

The payment can be made via bank transfer in the way you would normally make a bank transfer (using a banking app or in your local bank branch). In order for you to receive an invoice from us we will ask you to provide us with your name, the country where you currently reside, and your email address. We will keep these personal details in accordance with this privacy policy and provide you with a receipt once the payment has been received. No financial details (other than the name of the transferrer of the money) will be known to us as it won’t be provided by the bank on our account statement.

What safeguards does genuine-english.com have in place to protect data?

IONOS 1&1 Limited.

The website was created using a website builder provided by 1&1 IONOS Limited, a company trusted by many businesses in the UK.
genuine-english.com has an SSL certificate offered by IONOS 1&1 limited and issued by DigiCert. genuine-english.com uses technical and organisational measures to safeguard your data, for example:

• Personal data are stored on password protected computers
• Data stored on email accounts and on the website building platform are also password protected.
• Financial data is not held by genuine-english.com - payments via the website are completed using third party companies with their own policies and safeguards in place. Please refer to the privacy policy of the 3rd party payment method you use when you opt to pay via the website shop for more details.

genuine-english.com has measures in place to deal with any suspected data breach. If you suspect any misuse or loss, or unauthorised access to your data, please let us know immediately by contacting the Data Controller at hello@genuine-english.com.

Security reviews are conducted routinely to ensure that personal data is protected.

Where does genuine-english.com store personal data?

Personal data are stored on computers, a website building platform, and email accounts, all of which are password protected.

genuine-english.com uses IONOS 1&1 Limited’s platforms and data centres. According to Section 2.1 of the Data Processing Agreement between the Data Controller and 1&1 IONOS Limited:
“In the provision of the services, Controller may choose to hold Controller’s customer personal data (“personal data”) at Controller’s own risk, on the platforms and data centres of 1&1. The only processing activities that may be performed by 1&1 are the storage of such personal data and any backups in order to provide continuity of service and disaster recovery. Such backups are merely for the aforementioned purpose and shall not be available to Controller.”

For more information regarding IONOS 1&1 Limited’s Data Processing Agreement, please see the link: 

https://www.ionos.co.uk/help/data-protection/overview-of-the-general-data-protection-regulation-gdpr/contract-for-data-processing/?utm_source=search&utm_medium=standalone&utm_term=data%20protection%20agreement&utm_campaign=all

Data Retention:

Unless a longer retention period is required or permitted by law, genuine-english.com holds your data on its system for the period necessary to fulfil the purposes outlined in the privacy policy, or until you request that the data be deleted.

Even if we delete your data, it may persist on backup and archival media for legal, tax or regulatory purposes.

What legal basis does genuine-english.com have for processing your data?

The processing of your data is necessary due to the legitimate interest of genuine-english.com to communicate with (i.e. respond to) anyone who contacts the company using any method of communication. For example: It is impossible to respond to a query that has been submitted via an enquiry form on the website without processing some personal details of the individual who has submitted the query.

There are several optional sections on the website’s enquiry forms that allow an individual to add further information, such as their learning goals, or a sample of their writing. These are optional because they are not absolutely essential in order to establish contact with an individual. The reason for requesting and processing this data is the legitimate interest of genuine-english.com to understand the needs of a potential customer and provide a response to them that will allow them to make a decision as to whether they would like to purchase a product or service from the website.

Processing your personal data may also be necessary for the legitimate interest of genuine-english.com to market our products and services to you. This will only be done if you join a mailing list and consent to genuine-english.com sending you information for marketing purposes. Of course, you always have the right to opt out of marketing communication at any time.

genuine-english.com receives statistical analysis of website performance from IONOS SiteAnalytics. The legitimate interest of genuine-english.com to use this statistical analysis is to improve the website by understanding how the website is being used by those who visit it.

A secondary legal basis for processing your data is in order to adhere to or initiate a contract. In this case, a contract is defined as an agreement that genuine-english.com will provide a service or deliver a product in exchange for a payment in advance, following a set of rules outlined prior to purchase (please see our terms and conditions of sale for more details). For example: A customer may input data to purchase lessons on the website using the online shop. The legal basis for the processing of this data is to finalise and implement the contract when a customer purchases lessons, or a product.

To simplify this further: genuine-english.com needs a limited amount of your personal data in order to communicate with you, market our products/services to you, and deliver our services/ products to you. The primary legal basis for this is Legitimate Interests. The secondary legal basis for this (if needed) is Contract.

When you first access genuine-english.com you will see a cookie notice which will allow you to take the action you prefer. If you submit a query to any one of our contact forms, you will be asked to agree to having your data processed before you submit any personal information. If you make a purchase in our shop, you will be asked to agree to the privacy policy and store terms and conditions of sale prior to finalising your purchase. Please read this information carefully and only accept the terms and conditions if you are happy with them.

Your Rights:

You have the following rights in relation to your data:

1. Right to access - the right to request copies of the information genuine-english.com holds about you, or that we modify, update, or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
2. Right to correct - the right to have your data rectified if it is inaccurate or incomplete
3. Right to erase - the right to request that we delete or remove your data from our systems
4. Right to restrict our use of your data - the right to “block” us from using your data or limit the way in which we can use it.
5. Right to data portability - the right to request that we move, copy, or transfer your data.
6. Right to object - the right to object to our use of your data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above or withdraw your consent to the processing of your data (e.g. to opt out of marketing emails), please contact us via this email address hello@genuine-english.com .

If you are not satisfied with the way a complaint you make in relation to your data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk .

It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during the period for which we hold it.

Links to other websites:

This website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership or control:

genuine-english.com may, from time to time, expand or reduce our business and this may involve the sale and/or transfer of control of all or part of genuine-english.com. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the data for the purposes for which it was originally supplied to us.

We may also disclose data to a prospective purchaser of our business or any part of it.
In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General:

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal, or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This agreement will be governed and interpreted by the law of England, Wales, Scotland, and Northern Ireland. All disputes arising under the agreement will be subject to the exclusive jurisdiction of the English, Welsh, Scottish, and Northern Irish courts.

Changes to this policy:

genuine-english.com reserves the right to change this privacy policy as we may deem necessary from time to time or as we may be required by law. Any changes will be immediately posted on the website and you are deemed to have accepted the terms of the privacy policy on your first use of the website following the alterations.

You may contact the data controller, Joseph Simpson, by email at hello@genuine-english.com .

Attribution:
Some sections of this privacy policy have been taken directly from the free privacy policy offered by Rocket Lawyer (https://www.rocketlawyer.com/gb/en).