Privacy Policy
This Privacy Policy (‘the Policy’) (together with any other of our terms and conditions, and any other documents referred to in them) sets out the basis on which any personal data we collect from you, or that you provide, will be processed by us. Please read this Policy carefully to understand our views and practices regarding your personal data and how we will treat it.
We will only use your personal data in the manner set out in this Policy and in a way that is fair to you. We will only collect personal data where it is necessary for us to do so and where it is relevant to our dealings with you. We will only keep your personal data for as long as it is relevant to the purpose for which it was collected or for as long as we are required to keep it by law.
The Policy sets out
1. who we are
2. how we handle data for Parents and Students
3. how we handle online data
4. how we handle Staff data
5. General Principles
5.1 how we use your information;
5.2 where we store your information; and
5.3 consent.
Personal data (“Personal Data”) means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the person.
1. Who we are
For the purpose of the General Data Protection Regulations (the “Regulations”), the data controller is Exsportise Limited, a Company registered, at Aberdeen House, South Road, Haywards Heath, West Sussex, RH16 4NG under Company registration number 02330930
Our registration number with the Information Commissioner’s Office is 66115227, registered under Exsportise Limited.
We will refer to Exportise Limited as (‘Company’, “us”, “we”, or “our”) which operates https://www.exsportise.co.uk, the “Site”.
The user of our Site and other business or personal contacts that we deal with as customers or suppliers are referred to as ‘you’ or ‘your’. This Policy explains what happens to any personal data that you provide, or that is collected from you as part of our usual business, marketing and/or accessing our Site.
We use your such personal information only to answer enquiries, to provide our courses to you and to ensure that we keep in touch with targeted emails and marketing content. We are aware that you may also be accessing our website and that by accessing the Site, you agree to the collection and use of information in accordance with this Policy.
2. How we handle Students and Parents data
This policy explains how we collect your personal information, why we need it and what we do with it.
The ‘personal information’ that we may collect on you.
This may include but is not limited to:
Your contact details, including full name, mobile phone number, address and email address
Your parents’/emergency contact details
Your flight details and/or travel details
Your passport details
Your level of English
Any health or dietary information
Your attendance records
Welfare concerns including behaviour
Photographs/videos which contain your image limited to be able to identify you
Where do we get this personal data from:
We need to collect personal data on students and their parents in order to ensure we provide our courses and that we look after your welfare. We will need you to fill out the booking form in full for us to process your application for courses. We may also receive additional personal data on you from agencies and third parties where relevant.
Use of photos and/or videos
We take limited photos and/or videos of our students enjoying the courses. We may from time to time share these images through our social media and blogs to allow those who are involved in the course (including parents, students and representatives) to see the activities that are being undertaken.
We make sure that if we have blogs from the course that these are password-protected so that only those directly involved with the course (parents, staff, students, representatives) will be able to view them
We also make sure that the student’s full name will not be displayed or tagged with the image
Photos/videos may also be taken and used/shared as follows:
Group course/class photos (so students return home with a photo of them with the other course attendees)
The places that we may use these images are:
Centre blog posts
On our website, brochure and other printed publicity material
Social media posts - we do not tag our students in social media posts
Used by official representatives overseas for their website/brochure
Other professional organisations, such as The British Council and other affiliated bodies
We may use these images in future years for the above purposes.
If you do not wish the student’s image to be used for marketing purposes, please contact admin@exsportise.co.uk. Students should contact their Centre Manager to withdraw consent or if they have spotted the images being used in another context. In accordance with our safeguarding policy, we will not permit photographs, videos or other images of young people to be taken without the consent of the parents/carers and the child.
The People we may need to share your information may include:
Our insurance provider (if you are eligible for cover under our medical and travel insurance policy)
Our legal advisors for the establishment, exercise or defence of legal claims.
Examination boards, if you take one of their exams
Other professional organisations and affiliated bodies, such as The British Council and The British Activity Providers Association, which inspect our courses to ensure we meet agreed quality standards.
CCTV
All our centres which host our courses use CCTV cameras in various locations around the school/campus to ensure maximum security. These centres adhere to the ICO’s code of practice for the use of CCTV.
Lawful Basis of Processing
We process personal data regarding students that access our courses under contract. The processing of such personal data is necessary for the contract or we have been asked to take specific steps before entering into a contract.
Legitimate interest: we may also process personal data for the purposes of the legitimate interests of the Company. We may process your personal data provided that the legitimate interest is not overridden by your rights or freedoms. We have balanced this legitimate interest of the Company against the rights of the individual and do not conclude this is unreasonable, as at all times the data subject has a right to be forgotten and their personal details deleted.
Special categories of personal data: we also comply with an additional condition where we processes special categories of personal information such as health information and passport details, by seeking your consent to store and process this data.
Public interest in: we also have a public interest in providing students with a course, ensuring that we are complying with safeguarding guidelines and promoting the welfare of all our students and ensuring the proper operation of our programme.
Legal obligations: if we have a concern about the welfare of a student we may need to disclose this as well as your personal details to a local authority or police in appropriate situations.
Vital interests: we will protect your vital interests in certain situations where for example you are seriously hurt or unconscious and cannot give consent.
Holding your personal information
We will collect the personal information on you to discharge our duties and responsibilities.
We will keep your information indefinitely so that e.g. we can investigate a complaint or provide you with attendance confirmations unless you tell us you do not wish us to do so.
The Right to deletion and correction
We try to ensure we have the correct Personal Information on you.
You may ask for:
confirmation of what personal data is held on you, a copy of the data and who it has been shared with.
for your details to be amended if they are incorrect.
Your details to be deleted.
to stop receiving emails by using the unsubscribe links
Further guidance
To withdraw your consent and/or ask for amendment to your personal data please email: admin@exsportise.co.uk
If you have any questions, please talk to your Course leader (at the course centre) or email: admin@exsportise.co.uk
3. Online Information
This section explains how we use personal data collected from our website visitors.
We collect information from you when you:
(i) use our website (in the form of “traffic data”),
(ii) complete our on-line contact form (by means of “persistent cookies”),
(iii) request a brochure and/or show an interest in our services;
(iv) fill out an online application form.
While using our Site with the view to be accessing one of our courses, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. We need this information in order to reply to your enquiries, provide you with our courses, invoice you, collect payment and keep in touch with you from time to time with newsletters and targeted marketing emails. Personally, identifiable information may include, but is not limited to your name (“Personal Information”).
As part of this process we may collect and process the following Personal Information about you:
Your title, name, address, email address, telephone numbers, payment details, details on your child, emergency contact information and such other contact details as we require. This includes information provided at the time of accessing our Site or otherwise entering into discussions with us regarding our services, as well as targeted marketing purposes ‘our Company’.
Not all of this data will be personal data.
If you contact us, we may keep a record of that correspondence.
Initial online contact
We collect information you give us when you register or use our Site, including asking us to contact you. We require only the information we need to provide a service to you, such as your name, postal address, telephone number and email address. Where we would like more information to help us improve our services, over and above the basic required information, it will be clear that your response is voluntary and you are free not to provide us with more information if you would prefer not to do so.
Log Data
Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.
In addition, we may use third party services such as Google Analytics that collect, monitor and analyse this.
Cookies
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.
Like many sites, we may use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
Security of your personal data
We take all reasonable steps to prevent the loss or misuse of your personal data. We store personal data on secure systems.
If you no longer wish to receive our emails, then please unsubscribe or email: admin@exsportise.co.uk
4. Information for Staff on personal data
We have set out guidance on the personal data we collect on staff, how we use it and the rights that you have. If you have any questions, please speak to your manager. Staff include employed and contracted personnel. We also have a Data Protection Policy which has more details.
We need to collect personal data on staff during the recruitment process for employment purposes and in order to help us manage our business.
We will also collect the following personal data on you once you have been appointed.
your contact and emergency contact details
date of birth
employment history
bank details
attendance records and sick leave details
national insurance number
disclosure baring service check
health or dietary information
photographs/videos which contain your image
How we use and share your information
We will need to send limited personal data on your including your contact details, date of birth and national insurance number to payroll and/or accountants so we can pay you the correct amount and make the required tax deductions.
To provide our host centres details on your name and criminal check details, relevant allergies, health concerns and allow the host schools to monitor your use of the internet while you are on site.
Your personal data, qualifications, employment history and criminal check details with relevant inspection bodies, such as The British Council and The British Activity Providers Association
Use of photos and/or videos
We take limited photos and/or videos of our staff during the courses. We may from time to time share these images through our social media and blogs to allow those who are involved in the course (including parents, students and representatives) to see the activities that are being undertaken.
We make sure that if we have blogs from the course that these are password-protected so that only those directly involved with the course (parents, staff, students, representatives) will be able to view them
We also make sure that the staff’s full name will not be displayed with the image
Photos/videos may also be taken and used with group course/class photos (for students to return home with a photo of them with the other students and staff)
We may use these images in:
Centre blog posts
On our website, brochure and other printed publicity material
Social media posts
Used by official representatives overseas for their website/brochure
Other professional organisations, such as the British Council and other affiliated bodies
We may use these images in future years for the above purposes.
If you do not wish your image to be used for marketing purposes, please contact your manager or email: admin@exsportise.co.uk
CCTV
All our centres which host our courses use CCTV cameras in various locations around the school/campus to ensure maximum security. These centres adhere to the ICO’s code of practice for the use of CCTV.
Lawful Basis of Processing
We will generally process personal data regarding staff as we are under contract. The processing of such personal data is necessary for the contract or we have been asked to take specific steps before entering into a contract.
Legitimate interest: we may also process personal data for the purposes of the legitimate interests of the Company. We may process your personal data provided that the legitimate interest is not overridden by your rights or freedoms. We have balanced this legitimate interest of the Company against the rights of the individual and do not conclude this is unreasonable, as at all times the data subject has a right to be forgotten and their personal details deleted.
Special categories of personal data: we also comply with an additional condition where we processes special categories of personal information such as health information and passport details, by seeking your consent to store and process this data.
Recruitment: If you apply for a job with us or as a contractor, we may use your information for the purposes of recruitment and selection, corresponding with you and equal opportunities monitoring. We will not store your Personal Data for more than 12 months if you are not successful.
Employees/Contractors: we will keep relevant employee and contractor personal data while you are employed and for up to 7 years after you leave to comply with HMRC requirements (legal obligations) and to ensure we have records to allow us to deal with any contractual issues.
The Right to deletion and correction
We try to ensure we have the correct Personal Information on you.
You may ask for:
confirmation of what personal data is held on you, a copy of the data and who it has been shared with.
for your details to be amended if they are incorrect.
Your details to be deleted.
to stop receiving emails by using the unsubscribe links
5. General Principles
5.1 How we use your information
We use your information to provide the courses. As part of this we may also contact you for market research purposes (to include polls), targeted marketing (including newsletters and promotional material) with regards to our business and to help improve our customer service.
We will also use your information in the following ways:
To ensure that content from the Site is presented in the most effective manner for you and for your computer.
To provide you with information regarding our courses.
To deal with our suppliers.
To provide you with billing information in relation to our courses.
To manage the Site, detect fraud or Site abuses, send you information relevant to the Site and in case we have any queries.
To carry out our obligations arising from any contracts entered into between you and us.
To notify you about changes to our business.
To provide you with information about services we offer that we feel may be of interest to you.
We also need to use your contact details and other information for any aspect of the Site (including, without limitation, providing customer support, preventing or investigating prohibited activity, enforcing our terms and conditions, and verifying information).
When we share your information
We may disclose your information to relevant third parties in certain circumstances, but we will not sell, rent or trade your Personal Information.
We may share your information with another organisation that buys our Company or our assets, or with another organisation from which we acquire a company or business, and in the course of any preceding negotiations with that organisation, which may or may not lead to a sale.
We may share your information with our funders or potential funders, such as our bank and with our professional advisors who have a reasonable need to see it.
We may share your information with any group companies of ours so that they can provide you with information about our products and services available from them.
Other than as set out in this Policy, we shall NOT sell or disclose your personal data to third parties without obtaining your prior consent unless this is necessary for the purposes set out in this Privacy Policy or unless we are required to do so by law.
5.2 Where we store your personal data
All information you provide to us is stored on our secure servers. We use industry standard security and firewalls on our servers.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Only authorised personnel and contractors have access to your information.
We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage.
Transfers of Data in Europe
Data protection legislation is harmonised throughout the European Economic Area (‘EEA’) which comprises the EU member states, Norway, Iceland and Liechtenstein. Countries outside the EEA do not generally have the same level of protection for personal information as those within the EEA. We may need to transfer your data in Europe dealing with you and our agents. We may in very limited occasions need to transfer data out of the EEA if you are resident out of this area and we will ensure we do all we can to ensure your personal data is kept secure.
Other websites
Our Site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.
5.3 Consent
By submitting data to us and using the Site, you consent to our use of your data and of anyone you represent in the manner set out in this Policy (as amended from time to time, as described below) and you are responsible for ensuring that you have authority to consent on behalf of anyone about whom you submit data to us.
You can revoke any consent you have given us under this Policy at any time by contacting us at admin@exsportise.co.uk and referencing this Policy in the email subject line, using the body of the email to say what consent you are revoking.
Changes to This Policy
This Policy is effective as of October 2018 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change this Policy at any time and you should check this Policy periodically. Your continued use of our business after we post any modifications to this Policy will constitute your acknowledgement of the modifications and your consent to abide and be bound by the modified Policy.
If we make any material changes to this Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our Site.
Contact Us
If you have any questions about this Policy, please contact us.
If you have any queries about the information we hold on you, please email admin@exsportise.co.uk
You can also complain to the Information Commissioner’s Office https://ico.org.uk/concerns/ or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Last updated: October 2022