Last updated: January 20th 2023
1. ABOUT THIS PRIVACY AND COOKIES NOTICE
1.1 The website primaveraenglish.com (the Site) is operated by Primavera English (“we”, “us”, “our”). Our registered office is at Waldino R. Lovera 6035 c/ R.I. 3 Corrales, Asunción, Paraguay.
1.2 We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the General Data Protection Regulation 2016/679 (the GDPR), the California Online Privacy Protection Act 2003 (the CalOPPA) and any other applicable US legislation (together, Data Protection Law).
1.3 When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy and cookies notice explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.
1.4 This notice was last updated on the date shown at the top. We may change this notice at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made.
2. CONTACT INFORMATION
2.1 If you have any concerns or would like further information about our use of data or this notice in general, you can contact Jeanette Bazeley at firstname.lastname@example.org.
3. WHAT INFORMATION DO WE COLLECT?
3.1 We collect, store and use the types of personal data set out in the list at the end of this notice.
4. HOW WILL WE USE YOUR PERSONAL DATA?
4.1 We will use your personal data for the purposes set out in the list at the end of this notice.
5. HOW DO WE SHARE YOUR PERSONAL DATA?
5.1 When we share personal data, we do so in accordance with Data Protection law. We may share certain personal data:
5.1.1 with employees, contractors, consultants or advisers, to facilitate sales, improve our customer experience and for general commercial purposes;
5.1.2 with parties who provide products or services to us, such as, user analytics, email services, payment processing, advertising, user notification and feedback functionality, delivery couriers, marketing companies who help us manage our communications with you, data insight companies, the suppliers of the products we sell, in order to process the sales, and deliver the mentioned products etc;
5.1.3 with government or quasi-governmental organizations, law enforcement and other regulatory authorities or third parties when required or permitted by law, including but not limited to in response to court orders, for the prevention and detection of crime and to protect intellectual property and any other legal rights;
5.1.4 if the Company or part of the business is sold, transferred or integrated with another business, with our advisers, a prospective purchaser, a prospective purchaser’s advisers or the new owner of the Company to facilitate the process; and
5.2 We may also provide third parties with aggregated but anonymized information and analytics about our customers. Before we do so we will make sure that it does not identify you.
5.3 In some cases, when we share personal data, it will involve the transfer of that personal data to countries outside the EEA which have different data protection standards to those which apply in the EEA.
5.4 Where we transfer personal data outside the EEA we will ensure that there are adequate safeguards to protect your privacy rights under Data Protection Law.
6.2 We use the following categories of cookies and similar technologies on this Site:
6.2.1 Strictly necessary cookies: These cookies are essential to enable you to move around the Site and use its features. Without these cookies, services you have asked for (such as remembering your login details or the items you placed in your basket) cannot be provided.
6.2.2 Analytics cookies: These cookies collect information about how you use the Site, for instance which pages you go to most often, what searches you perform and if you get error messages from web pages. Information these cookies collect can be used to improve how the Site works.
6.2.3 Customization cookies: These cookies allow the Site to remember choices you make (such as your user name) and provide enhanced, more personal features. These cookies cannot track your browsing activity on other Sites.
6.2.5 Social media cookies: These cookies allow you to share your activity on the Site on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the privacy policies of the social networks in question for information regarding how their cookies work.
6.2.6 Targeting or advertising cookies: These cookies record your visit to the Site, the pages you have visited and the links you have followed. We use this information to make our Site and the advertising displayed on it more relevant to your interests. [We may also share this information with third parties for this purpose.
6.3 When you visit the Site for the first time (and periodically after that), we will request your consent to the setting of all cookies other than strictly necessary cookies.
6.4 You can delete existing cookies and disable some or all types of cookies in future if you wish. To disable some or all types of cookies, you will have to change the settings on your browser. If you change your mind, you can enable cookies again at any time. Disabling cookies on your browser may stop the Site from working properly.
6.5 To find out more about cookies please visit www.allaboutcookies.org.
7. THIRD PARTY LINKS
7.1 This Site may contain links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other Sites which you choose to access from this Site. We encourage you to review the privacy policies of those other Sites, so you can understand how they collect, use and share your personal information.
8. YOUR RIGHTS
8.1 We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.
8.2 Depending on the reason we have your personal data, you have a right to:
8.2.1 access the personal information we hold about you (commonly known as subject access);
8.2.2 request that we correct or complete personal information we hold about you that is inaccurate or incomplete;
8.2.3 request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 3.5;
8.2.4 restrict how we use your personal information, in certain circumstances;
8.2.5 request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and
8.2.6 where we have asked for your consent to process your data, to withdraw this consent.
8.3 These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.
8.4 If you wish to exercise any of these rights, please contact us using the details in paragraph above.
8.5 Your right to object
8.5.1 You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.
8.5.2 If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defense of legal claims.
8.6 Do Not Track Requests Policy
8.6.1 You have the right to set up your browser in a way that it will instruct websites not to track your browser. This Site responds and honors the Do Not Track (DNT) setting configured on your web browser.
8.7 We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities.
9. DATA RETENTION
9.1 Your personal data will only be kept for as long as necessary for our purposes. Specific periods are set out in the list at the end of this notice.
10. DATA PROTECTION PRINCIPLES
10.1 We process your personal data in accordance with the following principles:
10.1.1 we process your personal data lawfully, fairly and in a transparent way;
10.1.2 we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;
10.1.3 we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;
10.1.4 we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
10.1.5 we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and
10.1.6 we process personal data securely and in a way that protects against unauthorized or unlawful processing, accidental loss, destruction or damage.
10.2 When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.
10.3 Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.
11. WHAT IS OUR LAWFUL BASIS FOR PROCESSING?
11.1 We will only process personal data when we have a lawful basis for doing that processing. The list at the end of this notice sets out the lawful basis we rely on for each type of data we process.
11.2 We will choose one of the lawful bases in the GDPR to justify how we use your personal data. These are:
11.2.1 Consent: You have given consent to the processing of your personal data for one or more specific purposes.
11.2.2 Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.
11.2.3 Legal obligation: We need to process your personal data to comply with a legal obligation.
11.2.4 Vital interests: The processing is necessary to protect the vital interests of you or another person.
11.2.5 Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.
11.2.6 Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
List of personal information we use
The list below sets out detailed information about our purposes for processing (1), the legitimate basis for processing (2) and the retention period (3) for the personal data.
Name and contact details
- To deliver your purchases to you, to send you order updates, for fraud prevention and detection.
- Performance of contract, Compliance with legal obligations.
- For three years since you provided the information, or until you withdraw consent if earlier.
- To take payment and give refunds, for fraud prevention and detection.
- Performance of contract, Compliance with legal obligations.
- Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
The payment processor, Payoneer, may provide us with unique authentication tokens to make payments requests with. The payment processor Payoneer may also provide us with information such as your name, credit card type, expiration date, and the last four digits of your credit card number. This information is used only to make single payment requests, or register the user for an ongoing subscription that requires automatic payments in the future.
In addition, Primavera English may also request and receive any payment history between the user and Primavera English.
The payment processor Payoneer adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our payment processor.
- To provide customer service and support, to train our staff and improve customer experience.
- Legitimate interests in dealing with complaints or claims and improving our customer experience. Performance of contract.
- For six years since the contact took place.
- To provide customer service and support and handle returns, to provide services covered under our limited warranty.
- Performance of contract. Compliance with legal obligations.
- For six years after purchase.
Browser, device and Site usage information
- To improve the Site, to protect the Site against fraud, to set default options for you, such as language and currency.
- Legitimate interest in maintaining our Site and keeping it safe, and to deliver a better experience for our visitors.
- For three years since you last visited the Site.
Information from linked accounts
- To enable you to log into the Site simply without having to create a specific account.
- Legitimate interest in providing a better customer experience and reducing friction during the use of our website.
- For three years since you last logged on to the Site.
Responses to surveys, competitions and promotions
- To run the surveys, competitions or promotions.
- Legitimate interest in administering and/or improving our products and services generally.
- For six years.
Customer comments and product reviews
- To improve our products and services, where relevant, to establish, exercise or defend legal claims.
- Legitimate interest in dealing with complaints or claims, and improving our products and services as well as our customer experience. Consent.
- Indefinitely (depending on the platform), or until you remove the data or withdraw consent.
Information generated in the course of the use of our products and services
- For internal research and development purposes, to improve and test the features and functions of our Site.
- Legitimate interest in maintaining our Site and improving our products and/or services generally.
- For six years.
Information collected through cookies and similar technologies
- To conduct and store site usage analytics, statistical and trend analysis and market research, to generate customer profiles to facilitate marketing initiatives.
- Legitimate interest in improving our customer experience, and personalize it to their particular needs. Consent.
- Three years after you last visited the Site.