Privacy Policy


INTRODUCTION

This policy (together with our Terms of Use) and any additional terms of use incorporated by reference into the Terms of Use, applies to your use of:

  • The ENGLISHSCORE mobile application software (App) available on our site OR hosted on www.englishscore.com (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

  • Any of the services accessible through the App (Services) that are available on an App Store OR other sites of ours (Services Sites)

  • The EnglishScore services embedded within other sites (Partner Sites).


This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for individuals under the age of 18 and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below.

[IMPORTANT INFORMATION AND WHO WE ARE]

[THE DATA WE COLLECT ABOUT YOU]

[HOW IS YOUR PERSONAL DATA COLLECTED?]

[HOW WE USE YOUR PERSONAL DATA]

[DISCLOSURES OF YOUR PERSONAL DATA]

[INTERNATIONAL TRANSFERS]

[DATA SECURITY]

[DATA RETENTION]

[YOUR LEGAL RIGHTS]

GLOSSARY

[DESCRIPTION OF CATEGORIES OF PERSONAL DATA]

IMPORTANT INFORMATION AND WHO WE ARE

BC EnglishScore Limited is the controller and is responsible for your personal data (collectively referred to as ”Company”, “we”, “us” or “our” in this policy).


We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

  • Full name of legal entity: BC EnglishScore Limited

  • Email address: privacy@englishscore.com

  • Postal address: EnglishScore, Att: Legal Department, Level 2, One Hammersmith Broadway, London, W6 9DL, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues [or other competent supervisory authority of an EU member state] if the App is downloaded outside the UK.

Changes to the privacy policy and your duty to inform us of changes to your personal data

We keep our privacy policy under regular review.

This version was last updated on 20 June 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our App or Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data.

  • Contact Data.

  • Financial Data.

  • Transaction Data.

  • Device Data.

  • Content Data.

  • Profile Data.

  • Usage Data.

  • Marketing and Communications Data.

  • Location Data.

  • Educational Data.

  • Sensor Data.

We explain these categories of data here below.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App or Site or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register the App, subscribe to any of our Services, search for the App or Service, make an in-App purchase, share data via the App’s social media functions, enter a competition, promotion or survey and when you report a problem with the App or our Services. If you contact us, we will keep a record of that correspondence.

    • Information we collect about you and your device. Each time you use the App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.

    • Information we receive from other sources, including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below :

    • Device Data from our analytics and advertising networks suppliers as detailed in the [GLOSSARY] below:

    • Educational Data from our partners if you use their services

    COOKIES

    We use cookies and similar technologies to distinguish you from other users of the App and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

    HOW WE USE YOUR PERSONAL DATA

    We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

    • Where you have consented before the processing.

    • Where we need to perform a contract we are about to enter or have entered with you.

    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

    • Where we need to comply with a legal or regulatory obligation.

    PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

    Purpose/activity


    Type of data


    Lawful basis for processing


    To install the App and register you as a new App user


    Identity

    Contact

    Financial

    Device


    Your consent


    To deliver Services and process in-App purchases including managing payments and collecting money owed to us, and to prevent improper use of our Service


    Identity

    Contact

    Financial

    Transaction

    Device

    Marketing and Communications

    Location

    Sensor


    Your consent

    Performance of a contract with you

    Necessary for our legitimate interests (to recover debts due to us)


    To manage our relationship with you including notifying you of changes to the App or any Services


    Identity

    Contact

    Financial

    Profile

    Marketing and Communications


    Your consent

    Performance of a contract with you

    Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

    Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)


    To enable you to participate in a prize draw, competition or complete a survey


    Identity

    Contact

    Device

    Profile

    Marketing and Communications


    Your consent

    Performance of a contract with you

    Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)


    To administer and protect our business and this App including troubleshooting, data analysis and system testing


    Identity

    Contact

    Device


    Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)


    To deliver content and advertisements to you

    To make recommendations to you about goods or services which may interest you

    To measure and analyse the effectiveness of the advertising we serve you


    To monitor trends so we can improve the App


    Identity

    Contact

    Device

    Content

    Profile

    Usage

    Marketing and Communications

    Location

    Educational

    Consent

    Necessary for our legitimate interests (to develop our products/Services and grow our business)


    To communicate with potential Customers, Suppliers and Partners.

    Identity

    Contact

    Marketing and Communications

    Necessary for our legitimate interests (to develop our products/Services and grow our business)


    DISCLOSURES OF YOUR PERSONAL DATA

    We share some of the data we collect from you with other companies whose systems we use to operate the App, Sites, and Services for the purposes as set out in the above table ‘Purposes for which we will use your personal data’. We limit the information provided to these External Third Parties to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.


    You can always find an up-to-date list of these External Third Parties in the [GLOSSARY]. We reserve the right to update the Glossary without notifying you.


    We also share data with other companies who have a business relationship with EnglishScore, or a financial interest in us. We limit the information provided to these organisations to that which is reasonably required by them in order to scrutinise company performance and commercial and financial aspects of our business on the basis of being necessary for our legitimate interests.


    You can always find an up-to-date list of these Internal Third Parties in the [GLOSSARY]. We reserve the right to update the Glossary without notifying you.


    • External Third Parties as set out in the [Glossary].

    • Internal Third Parties as set out in the [Glossary].


    We may also share data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets also on the basis of being necessary for our legitimate business interests. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

    We may share your personal data (in a pseudonymised format only) with academic researchers for the purposes of statistical analysis and study, for example to validate the quality and robustness of the tests we provide.


    INTERNATIONAL TRANSFERS

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

    • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

    • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

    Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

    DATA SECURITY

    All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

    Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.


    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.


    DATA RETENTION

    By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

    In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.

    In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


    YOUR LEGAL RIGHTS

    Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

    Please refer to the [GLOSSARY] and section ‘Your Legal Rights’ regarding your legal rights:

    • [Request access to your personal data.]

    • [Request correction of your personal data.]

    • [Request erasure of your personal data.]

    • [Object to processing of your personal data.]

    • [Request restriction of processing your personal data.]

    • [Request transfer or your personal data.]

    • [Right to withdraw consent.]

    You also have the right to ask us not to continue to process your personal data for marketing purposes.

    You can exercise any of these rights at any time by contacting us, using our Contact Details - privacy@englishscore.com

    GLOSSARY

    LAWFUL BASIS Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

    THIRD PARTIES

    INTERNAL THIRD PARTIES Other companies in the Blenheim Chalcot Group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting or other business services:


    Blenheim Chalcot LTF Limited of 1 Hammersmith Broadway, London, W8 9DL, UK; The British Council of 10 Spring Gardens, London, SW1A 2BN, UK; BC Trading Limited of 0 Spring Gardens, London, SW1A 2BN, UK.

    EXTERNAL THIRD PARTIES Service providers acting as processors based in the UK, the EU and India who provide IT and system administration services:


    • Google of 1600 Amphitheatre Parkway, Mountain View, CA 94043;

    • Mailchimp of The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA;

    • SurveyMonkey Europe UC of 2 Shelbourne Buildings, Second Floor, Shelbourne Rd, Ballsbridge Dublin 4, Ireland;

    • Blenheim Chalcot IT Services of 103-104 B Wing, Fulcrum Hiranandani Business Park, Sahar Airport Road Andheri (East) Mumbai – 400099.

    • Facebook

    • MixPanel

    • Stripe

    • PayTM



    YOUR LEGAL RIGHTS You have the right to:

    • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    (a) if you want us to establish the data’s accuracy;

    (b) where our use of the data is unlawful but you do not want us to erase it;

    (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

    (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    DESCRIPTION OF CATEGORIES OF PERSONAL DATA

    • Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.

    • Contact Data: billing address, delivery address, email address and telephone numbers.

    • Financial Data: bank account and payment card details.

    • Transaction Data: includes details about payments to and from you and details of in-App purchases.

    • Sensor Data: includes audio, video, image and other sensor information on your device

    • Device Data: includes the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.

    • Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.

    • Usage Data: includes details of your use of any of our App including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise.

    • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

    • Location Data: includes your location supplied when entering billing information or by using GeoIP technology

    • Educational Data: includes answers you supply to the EnglishScore assessment, your resulting grade, and the grade(s) or similar you achieve when completing further learning or assessment services offered by Us or our partners.