Privacy Policy for customers of courses and memberships

Last updated September 13, 2023

1. Who are we and how can you contact us?

The data controller of personal data is ERT (English Roundtable Talk), the Netherlands (VAT number: NL004874309B27), E-mail: info@englishroundtabletalk.com.

With regard to the protection of personal data, we comply with EU Regulation 679/2016 (GDPR) pursuant to art. 3 of the same. For any doubt or need you can contact us at the following E-mail address: info@englishroundtabletalk.com.

2. Why do we ask you for this personal data (purpose) and on what legal basis?

We ask you for this personal data in order to provide the requested service (online consultancy, digital course, registration for ongoing services, etc.) and to be able to issue tax documents in compliance with the law.

3. What types of data do we collect?

We ask you to provide us with your name and surname, your E-mail address, your residential address, your telephone number, your credit card details (which we only partially see), your Tax Code and / or VAT number.

The processing of your personal data is carried out pursuant to art. 6, par. 1, lett. b) of the GDPR, i.e. it is necessary for the execution of a contract to which you are a party (the purchase of one of our courses or services) or for the execution of pre-contractual measures adopted at your request (for example if you ask us for information about our services or courses before buying them).

4. How do we use the collected data?

The treatment is carried out through the: collection, registration, organization, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.

Your data, once entered in the appropriate FORM, are sent and managed by the Mailing List Mailerlite service (https://www.mailerlite.com/). Through this platform we manage your data for statistical purposes and to provide you with information in the event of upgrading the courses you are enrolled in or on other courses or services similar to those you have purchased.

Once you have purchased the course, you will need to register on the appropriate platform. Remaining registered on this platform (or any other platform where we decide to transfer the course) is a necessary condition to be able to use it for life.

If you decide to request the deletion of your personal data from this platform, you will no longer be able to take advantage of our courses and this choice will not entail any right of reimbursement, unless it occurs within the terms of validity of the 100% satisfaction or refund guarantee.

The Mailerlite platform allows you to unsubscribe from the Newsletter or Mailing List at any time, with the same ease with which you signed up. However, we take care that the platform works correctly and that it adapts and complies with the rules of the European Regulation on the protection of personal data.

We may use the data collected to send you promotions and offers of services or information products similar to those you have purchased.

5. Is the provision of data mandatory?

It is essential that you provide us with identification and contact data in order to provide the requested service and to comply with the tax and legal obligations imposed by national and European laws. In no case will we use your personal data for purposes other than those indicated in this statement and those freely chosen upon registration.

The provision of data is optional for personalized advertisements (Promotion and Marketing).

By selecting the appropriate boxes, therefore, you declare that you have read this information and give your consent to the processing of your personal data for the related purposes.

So with this action, you give us your consent to the processing of personal data, within the limits and for the purposes indicated in this statement.

6. Data recipients

Your personal data may be disclosed to our freelance collaborators who help us in the management of courses and related activities as well as in the organization of our back office. Our collaborators are our personal data processing managers and are bound by our precise instructions and policies, as well as by obligations of confidentiality and secrecy. Upon request, we can provide you with a list of our collaborators, data processors.

Furthermore, your data may be disclosed to our employees, in charge of managing them for the purposes indicated in this statement, trained and trained by us for the correct treatment.

Data processing is always carried out in a partially automated way.

For checkout and payments we use:

SamCart: https://www.samcart.com/terms-and-conditions SamCart, Inc., 11850 West Market Place, Suite CD, Fulton, MD 20759: for cart and checkout management.

Paypal of PayPal (Europe) S.a r.l. Payment via Paypal implies that both parties have adhered to the TOS and Privacy Policy of the service: https://www.paypal.com/it/webapps/mpp/ua/legalhub-full

7. Transfer of data to third countries

Your data can be transferred to non-EU countries such as the United States and Canada.

For the United States, despite the fact that there is no adequacy decision by the European Commission, we make sure that all the necessary precautions and guarantees exist under the contract to guarantee the security of your data.

For Canada there is an Adequacy Decision of the European Commission dated December 20, 2001 [notified under number C (2001) 4539] (2002/2 / EC).

The lack of adequate guarantees is not linked to the supplier in and of itself, which we make sure it takes all the necessary security measures to keep your data safe, but is linked to the laws of third countries which are not always aligned with the guarantees. of protection offered by the GDPR. However, this is an ever-changing situation and, in any case, our suppliers continue to comply with the conditions of the Privacy Shield Framework.

In particular, we make use of the following external platforms:

Mailerlite, for the collection of lists and consents: (https://www.mailerlite.com/) which uses standard contractual clauses in order to guarantee the security of your data.

Disqus, for the management of user comments: https://disqus.com based in San Francisco (CA). California is under the California Consumer Privacy Act which contains provisions very similar to the GDPR.

Samcart, for the management of the shopping cart and for the conclusion of the purchase process (Maryland – USA).

For Paypal (which requires both parties to have an active account), please refer to the manager’s Privacy policy: https: //www.paypal.com/it/webapps/mpp/ua/legalhub-full

For targeting and retargeting we use:

Facebook and Instagram of Facebook Ireland Ltd: https://www.facebook.com/privacy/explanation and https://www.facebook.com/policies?ref=pf

Youtube by Google Irland Ltd: https://policies.google.com/privacy?gl=IT&hl=it

8. What are your rights and how can you get information on the data, modify it, delete it or have a copy of it?

According to the European Regulation, you have the right to ask:

access to your personal data (therefore to know what personal data we hold),

the rectification of inaccurate data or the integration of incomplete ones (in case any of your data has undergone changes, such as if you had to have a new E-mail address),

the deletion of personal data (upon the occurrence of one of the conditions indicated in art. 17, par. 1 of the GDPR and in compliance with the exceptions provided for in paragraph 3 of the same article)

the limitation of the processing of your personal data (for example, you could ask us to no longer subscribe to our Newsletter even though you want to keep your login credentials to take advantage of the courses you have purchased), if one of the hypotheses indicated in art. 18, par. 1 of the GDPR.

oppose the processing (for example if you realize that your data is being processed in a manner that does not comply with this information) and data portability.

Request and obtain your personal data in a structured and intelligible format from an automatic device, also in order to communicate such data to another data controller (right to portability).

withdraw consent at any time, limited to cases in which the processing is based on consent for one or more specific purposes and concerns common personal data (for example date and place of birth or place of residence), or particular categories of data (for e.g. data revealing your racial origin, political views, religious beliefs, health or sex life). The treatment based on consent and carried out prior to the revocation of the same retains, however, its lawfulness.

lodge a complaint with a supervisory authority (Authority for the protection of personal data – www.garanteprivacy.it).

9. How long will we keep your data?

Your personal data will be stored:

For membership and / or subscription services: for as long as the subscription to our programs lasts and for 10 years from the last invoice or receipt issued in your name or for a longer period if this is required by law of law.

For digital courses: since our courses are available to you for life, together with any updates / upgrades that we will allow, they can also be extended free of charge to members of previous editions, if you decide to request the total cancellation of your personal data you may no longer have access to our courses and subsequent updates. In this case we respect your choice but you will not be able to ask for any refund of the price of the course, unless this request is received during the validity period of the 14-day 100% Satisfaction or Refund guarantee. In the event of a request for deletion of your personal data, we will keep them for a period of 10 years from the last invoice or receipt issued to you or for a longer period if this is required by law or regulations

Regarding the consent to Promotion and Marketing, the retention period is 24 months from the provision of consent, regardless of whether the user is still active or unsubscribed.

10. How do we guarantee the security of your data?

We are particularly careful and respectful of your personal data and, therefore, we put all our efforts to treat them correctly and to guarantee their safety and protection from the risks of loss, theft or abuse by third parties.

11. Additional information

For any doubts or problems you encounter, we will be happy to provide you with any information and possible solution, by writing to info@englishroundtabletalk.com. We recommend that you contact us and tell us any of your doubts or needs.

This Privacy Policy may be subject to subsequent amendments and / or additions. So we invite you to consult it periodically according to your needs.