LAST UPDATED: 27th August 2021
Please read all of the following information carefully.
By using our site and/or registering with us, you are agreeing to the terms of this Policy.
Everything TEFL Ltd (“we”) are committed to protecting and respecting your privacy. Everything TEFL Ltd takes the security of and our legal responsibilities around your personal data seriously. This statement explains relevant information about our processing of your personal data collected via this website (“website” or “site”).
We aim to always respect your data protection rights in compliance with the latest Data Protection Laws, including the GDPR.
Who we are
This website is owned and operated by Everything TEFL Ltd, (we) a limited company registered in the Republic of Ireland having our registered office at 28 – 32 Pembroke Street, Dublin 2, Republic of Ireland.
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.
Our Data Protection Officer (DPO) can be contacted by email at firstname.lastname@example.org
This policy (and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation, the data controller is Everything TEFL Ltd.
Everything TEFL Ltd collects and processes personal information for a variety of reasons. If you wish to communicate with us about this privacy notice, or any issue relating to information governance or data protection, please contact us using the following details:
Information Governance & Risk Management Team
Everything TEFL Ltd
28 – 32 Pembroke Street,
Republic of Ireland
Telephone: +353 (1) 554 6227
Everything TEFL Ltd shares personal information within the wider Everything TEFL Ltd group of entities situated both within and outside the EU. We do this under a data-sharing agreement that includes the appropriate EU model international data transfer clauses to make sure your personal information is protected, no matter which entity in the Everything TEFL Ltd group holds that information.
Where Everything TEFL Ltd makes transfers of personal information outside the Everything TEFL Ltd Group to another organisation we rely on the use of the EU model international data transfer clauses where the country the organisation is situated in is not listed as ‘adequate’ by the European Commission.
Collection and Use of your data
Some data will be collected automatically by our site, other data will only be collected if you voluntarily submit it and consent to us using it for the purposes set out in section 5, for example, when signing up for an account. depending upon your use of our site, we may collect some or all of the following data: Name, address, bank details and so forth.
All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
We use your data to provide the best possible services to you. This includes:
- Providing and managing your account;
- Providing and managing your access to our site;
- Personalising and tailoring your experience on our site;
- Supplying our services to you;
- Personalising and tailoring our services for you;
- Responding to communications from you;
- Supplying you with email newsletters or alerts etc. that you have subscribed to, you may unsubscribe or opt-out at any time by clicking on the ‘unsubscribe to the list’ link at the footer of our email newsletters or by contacting our Customer Services Team at email@example.com
- Market research;
- Analysing your use of our site and gathering feedback to enable us to continually improve our site and your user experience;
- Ensuring our investigations and appeals are handled accurately and fairly;
In some cases, such as during an investigation or appeal, we may use public data such as social media accounts or review sites in order to ensure accuracy and fairness.
In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the services we can provide you without your consent, for us to be able to use such data.
With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in the controller; and/or
- processing is necessary for the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
We collect and use personal information to offer people information, products and services. This policy will apply in all locations where we operate to all forms of information and to all systems used to collect, store, process or transfer information.
Everything TEFL Ltd is committed to:
- performing privacy impact assessments to protect the privacy and rights of its customers and employees
- protecting the confidentiality, integrity and availability of the information it collects, stores, transfers and processes in accordance with law and international good practice, and meeting its legal requirements and contractual obligations
- explaining why it needs personal information, only asking for the personal information it needs and only sharing personal information within the Everything TEFL Ltd and with other organisations as necessary or where the person concerned has given their consent
- allowing people to request access to the personal information it holds on them and to complain if they believe their information has been mishandled
- not keep personal information for longer than necessary
- taking measures to protect the rights and freedoms of individuals whose personal information may be transferred to countries with differing data protection laws
- ensuring that actual or suspected breaches of information security are reported and investigated
- assessing and measuring the maturity of its information security controls annually
- applying these standards to its supply chain and delivery partners.
We will provide adequate and appropriate resources to implement this policy and will ensure it is communicated and understood.
We also use other organisations to process your personal information in order to carry out services on our behalf. We use them to:
- Provide customer service, surveys and marketing
- Personalise our services
- Process payments
- Carry out fraud and other legal investigations
Where we use another organisation, we make sure that your personal information is protected and remains in our control.
We also, in certain situations, share personal information with government bodies and law enforcement bodies. Where we do share personal information with these types of organisations we’ll make sure it’s protected, as far as it is reasonably possible.
We’ll use your personal information to send you direct marketing and to better identify products and services that interest you. We do that if you’re one of our customers or if you’ve been in touch with us another way (such as registering to attend an Everything TEFL Ltd event).
This means we’ll:
- create a profile about you to better understand you as a customer and tailor the communications we send you (including our marketing messages);
- tell you about other products and services you might be interested in;
- try to identify products and services you’re interested in; and
We use the following for marketing and to identify the products and services you’re interested in.
- Your contact details. This includes your name, gender, address, phone number, date of birth and email address.
- Information from cookies and tags placed on your connected devices.
- Information from other organisations such as aggregated demographic data and publicly available sources like the electoral roll and business directories.
- Details of the products and services you’ve bought and how you use them.
We’ll send you information (about the products and services we provide) by phone, post, email, text message, online banner advertising. We also use the information we have about you to personalise these messages wherever we can as we believe it is important to make them relevant to you. We do this because we have a legitimate business interest in keeping you up to date with our products and services. We also check that you are happy for us to send you marketing messages before we do so. In each message we send, you also have the option to opt-out.
We’ll only market other organisations’ products and services if you have said it is OK for us to do so.
You can ask us to stop sending you marketing information or withdraw your permission at any time.
Everything TEFL Ltd retains personal information in line with our corporate retention requirements. Your data will be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). However, in some circumstances, part or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”). You are deemed to accept and agree to this by using our site and submitting information to us. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with, and the use of the EU-approved Model Contractual Arrangements. If we intend at any time to transfer any of your data outside the EEA, we will always obtain your consent beforehand.
Right to access personal information
Under the law, any individual has a right to ask for a copy of the personal information held about them. This means that you can ask for the information that Everything TEFL Ltd holds about you. This is known as the right of ‘subject access’.
When making a request you will need to give us:
- a request in writing (by post or by email)
We may need to ask you to provide:
- proof of your identity
- proof of your home address
- any information that we reasonably need to locate the information you have requested (for example details of the Everything TEFL Ltd offices or staff that you have had contact with and when)
We will not start looking for your information until we receive all of the above. In order to submit your request, or for help making a request, please contact us.
Rights concerning the processing of your personal information
Right to restrict processing of personal information
In some situations, you have the right to require us to restrict the processing of your personal information. We may restrict your personal information by temporarily moving the information to another processing system, making the information unavailable to users, or temporarily removing published information from a website. We may also use technical methods to ensure the personal information is not subject to further processing and cannot be changed. When we have restricted processing of personal information, this will be clearly indicated on our systems.
You can require us to restrict processing in the following circumstances:
- You are concerned that the information we hold about you is inaccurate. You can ask us to restrict the information until we can determine whether the information is accurate or inaccurate.
- We are processing your personal data unlawfully and you do not want us to delete the information but restrict it instead.
- We no longer need the information for the purposes for which we collected it, but they are needed by you for the establishment, exercise or defence of legal claims.
- You have objected to the processing (see below), and we need to decide whether the legitimate grounds we have to process the information override your legitimate interests.
Processing you think is unlawful
If you tell us that you think we are processing your personal information unlawfully, but you do not want the information to be erased, you have the right to require us to restrict the processing of that information.
We will ask you for an explanation about why you think the processing is unlawful, and may also ask that you provide evidence to support this view.
Processing of personal information you think is inaccurate
You can tell us if you think the personal information we are processing about you is factually inaccurate. You can require us to restrict how we use your personal information until we can verify the accuracy of the information. We will ask you for an explanation about why you think the information is inaccurate, and may also ask that you provide some supporting evidence of the alleged inaccuracy.
If we find that the personal information we are processing about you is inaccurate, we will take appropriate steps to correct the information.
Personal information is no longer needed by Everything TEFL Ltd but needed by you in connection with a legal claim
In most circumstances, we will securely delete or dispose of personal information when we no longer need it for our legitimate business purposes. Our approach to retention is outlined in our corporate retention schedules.
However, if the personal information we no longer need would assist you in establishing, exercising or defending a legal claim, you can require us to keep the information for as long as necessary. We may ask you to provide an explanation and any available supporting evidence that a legal claim is ongoing or contemplated.
Right to erasure of personal data (“the right to be forgotten”)
In the following circumstances, you have the right to require that Everything TEFL Ltd securely deletes or destroys your personal information:
- If the personal information we hold about you is no longer necessary for the purposes for which we originally collected it.
- The processing is based on consent – if you have previously given your consent to Everything TEFL Ltd collecting and processing your personal information, and you notify us that you withdraw your consent. Please note: withdrawing your consent does not mean the processing of your personal data which occurred before the withdrawal was unlawful.
- We are processing your personal information for direct marketing purposes, and you want us to stop.
- If you think Everything TEFL Ltd has processed your personal information unlawfully.
If you think any of the above situations apply, we may ask you for an explanation and further information to verify this.
Right to object to processing
You have the right to object to the Everything TEFL Ltd processing your personal data in the following circumstances:
Personal information used for direct marketing
If we are using your personal information to send you direct marketing, you have the right to object at any time. If you exercise this right, we will stop processing your personal information for direct marketing purposes. However, we may keep your information on a “suppression list” to ensure your information is not added to any marketing lists at some point in the future.
Automated decision making and profiling
‘Profiling’ is the automated use of personal data held on a computer to analyse or predict things that have a legal effect, or other similarly significant effects, on the individual. Examples would include economic situation, health, personal preferences or interests and location. You have the right not to be subject to a solely automated decision (that is, a decision made electronically, with no human intervention), and this may include profiling (although there is no general right to object to profiling). If you are concerned the Everything TEFL Ltd has made a solely automated decision about you, you can object.
Please note, Everything TEFL Ltd is allowed to carry out automated decisions with no human intervention where you have given your explicit consent to this processing (although you have the right to withdraw your consent).
We are also permitted to make automated decisions with no human intervention in the following circumstances:
- The automated decision is necessary to enter into, or perform a contract, or complete a contract involving you and the Everything TEFL Ltd.
- The automated decision is allowed under a law passed at the European Union level, or at the level of the European Union or EEA member state level (i.e., is allowed under national law). The law will provide safeguards to protect your rights and freedoms.
However, you still have a general right to object in both of the above circumstances, providing reasons why you think the processing is having a negative effect on you. If you do object, we will carefully consider your reasons, and decide whether to review the decision-making process in your specific case.
Right to data portability
If you have provided your information to Everything TEFL Ltd, you have the right to request and receive a copy of that information in a structured, commonly used and machine-readable format.
You also have the right to ask us to send the information we hold about you to another organisation.
There are some situations in which the right to data portability does not apply. For further information, please contact us.
Exercising your rights concerning the processing of your personal information
If you wish to exercise any of the above rights concerning the way in which we process your personal information, please contact:
Risk Management Team
Everything TEFL Ltd
28 – 32 Pembroke Street,
Republic of Ireland
Telephone: +353 (1) 554 6227
Your right to complain to a national data protection regulator (data protection supervisory authority)
If you think we have processed your personal information unfairly or unlawfully, or we have not complied with your rights under GDPR, you have the right to complain to a national data protection regulator.
Complaints about how we process your personal information can be considered by the data protection regulator.