This is the privacy notice of Macmillan Education Limited.
With the help of this privacy notice (“notice”) we want to inform you about our processing activities that concern your personal data.
We will only collect, process and use your personal data in compliance with applicable data protection law and as set out in this notice. Below you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what control and information rights you may have.
- Personal data: means any information relating to a living person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
- Processing: means any operation which is performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation or any kind of disclosure or other use.
II. Scope of processing
Personal data we process
We will process the following personal data:
- Email address
- Bank details
- Ip Address
- Date of Birth
- Job Title and Company / Institution where relevant
III. Purpose of processing
1.1 We will process the personal data obtained from you to:
- Provide you with services you have requested
- To carry out the delivery of the goods and products you have ordered
- To directly provide you with advertisement with regard to our services and products
- To contact you
You can object to the use of your personal data for direct marketing at any time. We will then refrain from any processing to the extent it is related to such purposes. You can inform us about your objection by contacting us at:
Macmillan Education Caribbean
The Macmillan Campus
4 Crinan Street, London
N1 9XW UK
Tel: +44(0)207 014 6767
1.2 For this processing, the legal basis is
- Consent, Article 6 sec. 1 sent. 1 lit. a GDPR
- Performance of a contract, Article 6 sec. 1 sent. 1 lit. b GDPR
- Compliance with a legal obligation, Article 6 sec. 1 sent. 1 lit. c GDPR
- Legitimate interest, Article 6 sec. 1 sent. 1 lit. f GDPR
IV. Information about the specific uses that require registration
For the use of our web shop you have to set up an account as described under IV. Your customer account retains your personal data for future purchases. You can delete the personal data as well as the account in your account’s settings. This processing is based on Article 6 sec. 1 sent. 1 lit. b.]
By statutory law we are required to retain the provided financial data in relation to transactions (including address, payment and order information) for 4 years. However, after 7 years we will restrict the processing of your personal data to comply with the statutory requirements and will not process the personal data any further. Regarding this, the retention of your personal data is based on Article 6 sec. 1 sent. 1 lit. c GDPR.
This processing is based on our legitimate interest to optimise our services, to carry out the service you have requested and to meet our legal and business obligations.
The provision of the aforementioned personal data is necessary to enter the contract.
Additional personal data mentioned under II.1 is provided voluntarily.
Failure to provide the personal data can lead to disadvantages such as non-conclusion of a contract.
Some of the personal data provided is not a statutory requirement or necessary to enter the contract and is provided at your discretion. Failure to provide the personal data can lead to disadvantages such as an impaired service.
The personal data will be retained for as long as is reasonable to meet our business and legal obligations.
V. Automated decision making
We do not use your personal data for automated decision making which produces legal effects Information sharing
Your personal data will be disclosed to the following third parties:
Firsty Group Limited – United Kingdom
Google LLC – United States of America
Sage Pay Europe Limited – United Kingdom
Flux Digital Media Ltd – United Kingdom
for the purposes mentioned above (see II.2). Legal basis for the transfer of your personal data is to be able to provide you with requested services, carry out orders you request and optimise our services.
We may disclose your personal data to contractors who assist us in providing the services we offer to you. Such a transfer will be based on data processing agreements. Therefore, our contractors will only use your personal data to the extent necessary to perform their functions and will be contractually bound to process your personal data only on our behalf and in compliance with our requests.
Some of the recipients mentioned above reside outside the EEA. For further information about cross-border transfer in general and transfers outside of the EEA see II.5.
In the event that we undergo re-organisation or are sold to a third party, any personal data we hold about you may be transferred to that re-organised entity or third party in compliance with applicable law.
We may disclose your personal data if legally entitled or required to do so (for example if required by law or by a court order).
For statistical analyses we use a tool called Google Analytics, a web analytics service provided by Google LLC, Googleplex, Mountain View, California, U.S, to collect information about the use of this site.
The tool collects information such as users visiting the website, what content pages are accessed, IP addresses (geographic location), type of device you are accessing the website on, language of device you are accessing the website on, etc. We use the information we get from Google Analytics only to determine the most useful information you are looking for, and to improve and optimise this website. We do not combine the information collected through the use of Google Analytics with personal data.
The information generated about your use of the website will be transmitted to and stored by Google Analytics on servers in the United States. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or any other identifying information. The provider will use this information in order to evaluate your use of the website, to compile reports on website activities and to provide other services relating to website and internet use to us.
We have activated the IP-anonymisation within the Google Analytics service, and your IP address will be truncated within the area of member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. The IP-address your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google.]
The legal basis for this processing is Art. 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to analyse our website’s traffic to improve the user’s experience and to optimise the website in general.
VII. Third party content and social media plug-ins
1. Social media plug-ins
We use the following social media plug-ins: Facebook & Twitter. This allows you to communicate with such services and like or comment from our website. Social media plug-ins enable a direct communication between your device and the servers of the social media provider, allowing the social media provider to communicate with you and collect information about you browsing our website. This processing is based on Article 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to improve your website experience and to optimise our services.
Transfer of personal data takes places whether you have an account with the provider or not.
Your personal data will be transferred to and processed in United States.
Please note that we neither have the control of the extent of personal data that is collected by the respective plug-in provider nor do we know the processing’s purpose or the period your personal data will be retained.
Facebook: Address: 1 Hacker Way, Menlo Park, 94025.
Twitter: Twitter, Inc.
1355 Market Street.
San Francisco, CA 94103.
VIII. Cross-border data transfers
Within the scope of our information sharing activities set out above (see 4), your personal data may be transferred to other countries (including countries outside the European Economic Area (EEA)) which may have different data protection standards than your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavour to take reasonable measures to keep up an adequate level of data protection when sharing your personal data with such countries.
In the case of a transfer to a country outside of the EEA, this transfer is safeguarded by EU Standard Contractual Clauses. You can find further information about the aforementioned safeguards under https://ec.europa.eu/info/law/law-topic/data-protection_enn or by contacting the Data Protection Team at firstname.lastname@example.org
We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this notice, your personal data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements.
IX. Your rights
Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:
- require (i) access to and/or duplicates of your personal data retained, (ii) receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (iii) to transmit those data to another controller without hindrance from our side; where technically feasible you shall have the right to have the personal data transmitted directly from us to another controller;
- request proper rectification, erasure or restriction of your personal data, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn, or (iv) you have taken advantage of an existing right to object to the data processing; in case the personal data is processed by third parties, your request for rectification, erasure or restriction will be forwarded also to such third parties unless this proves impossible or involves disproportionate effort;
- refuse to provide and – without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question – withdraw your consent to processing of your personal data at any time;
- object at any time that your personal data will be used for direct marketing purposes, or - based on grounds relating to your particular situation - that your personal data shall be subject to data processing for other purposes;
- take legal actions in relation to any potential breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection regulators; and/or
- not to be subject to any automated decision making, including profiling (automatic decisions based on data processing by automatic means, for the purpose of assessing several personal aspects) which produce legal effects on you or affects you with similar significance.
You may (i) exercise the rights referred to above or (ii) pose any questions or (iii) make any complaints regarding our data processing by contacting us under the contact details set out below.
X. Contacting us
The information you provide when contacting us at Caribbean@macmillaneducation.com will be processed to handle your request and will be erased when your request is completed. Alternatively, we will restrict the processing of the respective information in accordance with statutory retention requirements.
XI. Amendments to this policy