Data Protection Policy and Privacy Statement
Dun Laoghaire Tuition Centre Ltd (DLTC Language School) is a provider of English language education programmes and services related to the teaching and learning English including, assessment and placement, examinations, research, accommodation, social activities and excursions. DLTC is based in Ireland and provides services to clients internationally.
This Data Protection Policy and Privacy Statement explains how DLTC Language School collects and uses personal data in the course of its business operations. The company is committed to the protection of our clients’ data in compliance with the General Data Protection Regulation (GDPR) and other legislation and is happy to respond to any questions or requests regarding data protection through our Data Officer (details below).
DLTC Language School is a Data Controller. The company is registered in Ireland (IE365344) with a business address at 25 Lower Georges Street, Dun Laoghaire, Ireland.
1. What personal data do we collect?
DLTC Language School may collect different information from you at various times based on the requests your make or the contact you have with us. The information we collect is generally related, but not limited completely, to the following:
- Identification – including name, age, gender and identification details;
- Contact details – for communications purposes;
- Enrolment details – such as mother tongue, course preferences, progression, preferences and special requirements as well as feedback and survey responses;
- Technical data – including IP address, login data and duration, browser type in order to secure our testing services or to provide such services as WiFi;
- Images – with your consent when attending DLTC Language School activities or events;
- Marketing preferences – such as your interests in and use of our products and services.
1.1 How do we collect personal data?
Personal data may be collected about you at times when you, or a representative on your behalf, engage or communicate with us, such as when:
- Information is requested from us or you ask us questions about or products or services;
- A registration or enquiry form is completed, a booking is made or a contract established for our products and services;
- Our websites are visited and web-based services are used;
- Competitions are entered or you attend an information session or company event; when you engage with us for marketing research purposes or in an activity such as providing us with feedback or opinions;
- You engage with us using a social media channel, email, blog or other communication method;
- You visit or use an DLTC Language School school site as a student or visitor.
1.2 How do we use personal data?
Your personal data is used by DLTC Language School based on one or more of the following:
- The consent that you have given;
- To deliver a contract that is agreed;
- To protect your vital interests;
- To comply with legal obligations or public responsibilities placed on us;
- Because of our legitimate business interests.
We will use your personal data solely to:
- Provide you with information on products and services that you have asked about or that we consider to be of interest to you;
- Allow us deliver contracts for the products and services you have booked with us;
- Help us to monitor, develop and improve our products and services;
- Send informational communications to you regarding our activities, products and services.
We may conduct analysis on the data that we receive through the use of our websites, social media channels, products or services and report on this information for business purposes in a manner where personally identifying data is removed.
DLTC Language School does not conduct automated data processing operations on personal data.
1.3 How do we share personal data?
DLTC Language School may share personal data only in cases where it is necessary for us to:
- Engage with authorised parties, such as agents, who operate on your behalf;
- Deliver, or enable delivery of, products or services that we have contracted with you or on your behalf;
- Comply with the requirements of regulators, immigration or other governmental authorities or as required by law.
Where we engage with third parties to provide products or services, we confirm that suitable and compliant controls are in place for the protection of personal data, and that data sharing is minimised to that which is required for the delivery of the services and products only.
1.4 Do we transfer your personal data to other countries?
It may be necessary for DLTC Language School to transfer data to another country, for example, host family details. Data transfers within the European Union and European Economic Area (EU/EEA) are protected by the rights and responsibilities established the General Data Protection Regulation. If it is necessary to transfer personal data beyond the EU/EEA, we will ensure that there are suitable protections in place to ensure the security of the data that is transferred.
1.5 How long do we keep personal data?
DLTC Language School retains your personal data for the duration of our relationship and for a defined period of time after that, subject to legal requirements and obligations. If we hold data for longer we will anonymise it by removing all personally identifying information such as name, contact details.
1.6 What are our retention periods?
Where DLTC Language School is required to retain certain personal data to comply with our legal or public obligations, we will do so until the end of the required period. In all other cases we will securely dispose of or anonymise personal data as follows:
- Identifiable customer records: 7 years after current tax year.
- Student Academic records – indefinitely in order to provide transcripts etc;
- Images including videos – 7 years after current tax year
- Direct Enquiries/Contact/Mailing list membership – indefinitely until requested removal;
- Comments on site – indefinitely;
1.8 What are your rights?
You can ask us for a copy of the personal data that we hold about you. You can also ask us about how we collect, process or share your personal data. In addition, you can ask us to restrict the way we use your data, may ask us to update or to delete the data we already have. To exercise your rights you should contact the Data Officer (firstname.lastname@example.org). We may be limited in some requests owing to legal or other public obligations placed on us. We will respond to requests and will explain any cases where we cannot complete what you have asked. In most circumstances there will be no fee for requests.
1.9 Questions or comments regarding data protection at DLTC Language School
Any questions or comments about the use of your personal data at DLTC Language School can be sent directly to the Data Officer (email@example.com). We will investigate your questions and respond to you promptly. We may have to ask for some additional information from you to verify your identity so we can assist with your question.
If you believe that we have not responded adequately to in a timely manner, you may contact the Data Protection Commissioner (Ireland – www.dataprotection.ie).
Changes to this Statement
DLTC Language School may update this Statement from time-to-time. The current version is available to be viewed at www.dltc.ie/policies. This Statement updates and replaces all previous versions.
2. HANDLING PERSONAL DATA FOR WEBSITES FOR PURELY INFORMATIONAL USE
If you use our website purely for informational purposes, in other words if you do not register or if you transfer information to us otherwise, we only collect those personal data that are transferred by your browser to our server. If you would like to view our website, we collect the following data that are technically necessary for us in order to show you our website and guarantee stability and security.
- IP address
- date and time of the request
- time zone difference from Greenwich Mean Time (GMT)
- content of request (actual web page)
- access status/HTTP status code
- respectively transferred data amount
- website from which the request is received
- operating system and its interface
- language and version of the browser software
If you have questions or comments on this topic, please contact us using the contact information provided in section 9
2.2. GOOGLE SERVICES
All services mentioned under sections 2.2 are provided by Google Ireland Gordon House, Barrow Street, Dublin 4, Irland and/or Google Inc. 1600 Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA (”Google”).
You can prevent participation in various Google services in several ways: a) by adjusting your browser software accordingly, in particular, the suppression of third-party cookies results in you not receiving any third-party ads; b) by disabling the cookies for conversion tracking by setting your browser to block cookies from the domain ”www.googleadservices.com”, https://www.google.en/settings/ads, although this setting will be deleted if you delete your cookies; c) by deactivating the interest-based advertisements of the providers that are part of the ”About Ads” self-regulation campaign via the link https://www.aboutads.info/choices, although this setting will be deleted if you delete your cookies; d) by permanent deactivation in your Firefox, Internet Explorer or Google Chrome browsers under the link https://www.google.com/settings/ads/plugin, e) by setting your cookie preferences accoringly. We point out that, in this case, you may not be able to use all features of this offer in full.
For detailed information on how Google secures and handles your personal data please see https://policies.google.com/privacy?hl=en.
2.2.1 GOOGLE ANALYTICS AND UNIVERSAL ANALYTICS
This website uses Google Analytics, a web analytics service that uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of your use of the website.
Google will use this information on our behalf to evaluate your use of the website, to compile reports on website activity and to provide other services related to website usage and internet usage to us Google may also transfer this information to third parties as required by law or if said third parties process this data on behalf of Google.
You can prevent the storage of cookies by setting your browser software accordingly; however, we point out that in this case you may not be able to use all the functions of this website in full. You may also prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by downloading the browser plug-in available at the following link and installing it: http://tools.google.com/dlpage/gaoptout. If you want to deactivate the tracking via Google Analytics for your mobile devices please follow the following link to activate the respective opt-out cookie.
We use Google Analytics to analyze and regularly improve the use of our website. With the statistics we can improve our offer and make it more interesting for you as a user.
Google Analytics Terms of Service: https://marketingplatform.google.com/about/analytics/terms/gb/, Overview on Google Analytics security and privacy principles: https://support.google.com/analytics/answer/6004245?hl=en
This website also uses Google Analytics for a cross-device analysis of visitor traffic conducted via a user ID. You can disable the cross-device analysis of your use in your customer account under “My Data”, “Personal Information”.
Universal Analytics enables cross-device tracking of users and leads to more refined information for those responsible (generally https://support.google.com/analytics/answer/2790010).
2.2.2. GOOGLE ADS (FORMERLY GOOGLE ADWORDS)
We use the offer of Google Ads, in order to draw attention to our attractive offers with the help of advertising (so-called Google Ads) on external web pages. In relation to the data of the advertising campaigns, we can determine how successful the individual advertising measures are. We are interested in showing you advertisements that are of interest to you, to make our website more interesting to you and to achieve a fair calculation of advertising costs.
These advertising materials are supplied by Google via so-called “ad servers”. To do this, we use ad server cookies, from which certain performance metrics such as ads or user clicks can be measured. If you access our website through a Google ad, Google Ads will store a cookie on your PC. These cookies usually lose their validity after 30 days and should not serve to personally identify you. As a rule, the unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wants to be addressed) are usually stored as analysis values for this cookie.
These cookies allow Google to recognize your internet browser. If a user visits certain pages of an Ads customer’s website and the cookie stored on their computer has not yet expired, Google and the customer may discover that the user clicked on the advertisement and was redirected to that page. Each Ads customer is assigned a different cookie. Thus cookies cannot be tracked via the websites of Ads customers. We ourselves do not collect and process any personal data in the aforementioned advertising measures. We receive only statistical evaluations provided by Google. On the basis of these evaluations, we can identify which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify the users on the basis of this information.
Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence over the scope of the data collected by the employment of this tool by Google and the further use of such data, and inform you therefore according to our level of knowledge: By including Ads Conversion, Google receives the information that you have accessed the relevant part of our website or have clicked on an advertisement from us. If you are registered with a service provided by Google, Google may associate the visit with your account. Even if you are not registered with Google or have not logged in, there is a chance that the provider will find out your IP address and store it.
2.2.3 GOOGLE REMARKETING
In addition to Ads Conversion, we use the Google remarketing application, which enables you to see our ads after visiting our website as you continue to use the internet. This is done by means of cookies stored in your browser, through which your usage behavior when visiting various websites is recorded and evaluated by Google. This is how Google determines your previous visit to our website. Consolidation of the data collected during the remarketing with your personal data, which may be stored by Google, does not occur by Google according to its own statements. In particular, according to Google, pseudonymization is used in remarketing.
With the use of remarketing, information about your browsing behavior is collected for marketing purposes in anonymous form and stored on your computer using cookies (targeting / retargeting). Based on an algorithm, we can then show you targeted product recommendations as personalized banner ads on other websites (so-called publishers). If you do not want this to occur, you can disable it via the Ads Preferences Manager (https://www.support.google.com/ads/answers/2662922?HL=EN).
2.2.4 GOOGLE CAMPAIGN MANAGER (FORMERLY GOOGLE DOUBLECLICK)
Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server when you visit our website. We have no influence over the scope of the data collected by the employment of this tool by Google and the further use of such data, and inform you therefore according to our level of knowledge: By including Campaign Manager, Google receives the information that you have accessed the relevant part of our website or have clicked on an advertisement from us. If you are registered with a service provided by Google, Google may associate the visit with your account. Even if you are not registered with Google or have not logged in, there is a chance that the provider will find out your IP address and store it.
Furthermore Campaign Manager cookies (DoubleClick Floodlight) help us to understand whether you complete certain actions on our website after viewing any of our display/video ads on Google or other platforms through Campaign Manager or clicking through one of these ads (conversion tracking). Campaign Manager applies this cookie to understand the content with which you have interacted on our website to be able to send you targeted advertising later on.
If you want to prevent Google from collecting the data generated by the cookies please download and install the browser plugin available under “Display settings”, “Extension for Campaign Manager deactivation” at https://support.google.com/adsense/answer/142293?hl=en.
Further information on Campaign Manager is available at https://www.google.de/doubleclick
2.2.5 GOOGLE RECAPTCHA
This website uses Google reCAPTCHA to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program (“bots”).
reCAPTCHA analyses the behaviour of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website.
This service allows Google to determine from which website your request has been sent and from which IP address the reCAPTCHA input box has been used. In addition to your IP address, Google may collect other information necessary to provide and guarantee this service.
2.2.6 GOOGLE MAPS
This website uses Google Maps to display our location and to provide directions (e.g. via our store finder and event calendars). To enable the display of certain fonts on our website, a connection to the Google server in the USA is established whenever our website is accessed.
If you access the Google Maps components integrated into our website, Google will store a cookie on your device via your browser. All user settings and data are processed to display a location and describe a certain route.
By connecting to Google in this way, Google can determine from which website your request has been sent and to which IP address the directions are transmitted.
2.2.7. GOOGLE FONTS
This website uses Google Fonts to display external fonts. For this purpose, your browser loads the required web fonts into your browser cache to display texts and fonts correctly, which requiresyour browser to establish a direct connection to Google Servers. Google can identify the website from which your request has been sent and to which IP address the fonts are being transmitted for display.
2.2.8. GOOGLE TAG MANAGER
This website uses the Google Tag Manager that allows website tags to be managed using an interface. The Google Tag Manager only implements tags. This means that no cookies are used and no personal data is collected. The Google Tag Manager triggers other tags, which in turn collect data if necessary. However, the Google Tag Manager does not access this information. If recording has been deactivated on domain or cookie level, it remains valid for all tracking tags implemented with Google Tag Manager.
2.3. YOUTUBE VIDEOS
We have also incorporated YouTube videos into our websites. The videos are stored at www.youtube.com and can be played directly from our websites. These videos are incorporated in such a way that no personal data related to you as the user is sent to YouTube if you do not play the videos.
If you do play the videos, YouTube cookies will be stored on your computer and data will be sent to Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, as the YouTube operator. When playing videos stored with YouTube, the following personal data is sent to Google, Inc.: the IP address and cookie ID, the specific address of the page visited on our websites, language setting of the browser, system date and time of access and your browser’s identifier. The data is transmitted regardless of whether you are registered with or logged in to Google. If you are logged in, this data will be attributed directly to your account.
If you do not want this attribution to your profile, you must log out before activating the button. YouTube or Google, Inc., stores this data as use profiles and uses this data for the purposes of advertising, market research and/or designing its websites based on demand. Such use is meant in particular (not only for logged-in users) to provide advertising based on demand and to inform other users of your activities on our website. You have a right to oppose the creation of these user profiles, and to exercise this right, you must address yourself to Google Inc. as the operator of YouTube. Additional information on the purpose and scope of data collection and processing by Google, Inc., can be found at www.google.at/intl/policies/privacy/. We do not process the personal data collected when the YouTube video is accessed.
2.4. FACEBOOK PIXEL
For conversion measurement, our website uses the pixel visitor promotion of Facebook, Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook“).
Because we use the “Custom Audiences” remarketing feature, which you can disable an time as described below, your behaviour can be tracked after you have been redirected to our website by clicking on a Facebook ad. As a result, the effectiveness of Facebook ads can be evaluated for statistical and market research purposes and future advertising measures optimized.
The data collected is anonymous to us as operators of this website; we cannot draw any conclusions about the identity of users. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook data usage directive. As a result, Facebook can enable advertising to be displayed on Facebook sites and outside of Facebook. This use of the data cannot be influenced by us as a site operator.
See the data protection notice of Facebook for more information on how to protect your privacy: https://www.facebook.com/about/privacy/.
You can also disable the “Custom Audiences” remarketing feature in advertisement settings at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen#_. For this you have to be logged in to Facebook.
If you do not have a Facebook account, you can opt out of Facebook Commercial Advertising on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/uk/your-ad-choices.
3. OPERATION OF SOCIAL MEDIA ACCOUNTS
We are operating several accounts on social media networks or platforms in order to communicate with our customers, interested parties and other users and to inform them about our brands, products and services.
We would like to point out that user data may be processed outside the European Union by the Social Media companies when visiting their websites which can result in risks for users (e.g. it could be difficult to enforce data subject rights of users).
Please note that your data is usually processed for market research and advertising purposes by the Social Media platforms when visiting their websites. For example, user profiles can be created on the basis of user behaviour and the documented interests of users. The user profiles can then be used to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (in particular if the users are registered users of the respective platforms and are logged in).
The processing of your personal data when visiting our Social Media channels is carried out on the basis of our and the Social Media platform’s legitimate interests (effective information of and communication with customers, prospects and users) pursuant to Art. 6 Para.1 (f) GDPR. If you are requested by the respective providers of the Social Media platforms to consent to the aforementioned data processing, the legal basis for the processing is Art. 6 Para 1 (a) GDPR.
With regard to the exercise of your data subject rights under the GDPR we point out that these can be asserted most effectively with the Social Media providers. Only the Social Media providers have access to your personal data and can directly take appropriate measures and provide information to you. Should you nevertheless need help, please let us know.
Last Update: 07/01/2021