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DATA PROTECTION POLICY

Key details:

  • Lightning English is operated by the Denmark-registered company Language Consulting, solely owned by Krisia Dawn Justesen.
  • This policy has been prepared by Krisia Dawn Justesen.
  • This policy became operational on 15 June, 2021.
  • Next review date: 15 December 2021.

INTRODUCTION

Language Consulting needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, and other people the organization has a relationship with, or may need to contact.

This policy describes how this personal data must be collected, handled, and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures that Language Consulting:

  • Complies with data protection law and follows good practice
  • Protects the rights of customers and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

Data protection law

The GDPR describes how organizations — including Language Consulting — must collect, handle, and store personal information.

These rules apply regardless of whether data is stored electronically, on paper, or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely, and not disclosed unlawfully.

The GDPR is underpinned by eight important principles. These say that personal data must:

  • Be processed fairly and lawfully
  • Be obtained only for specific, lawful purposes
  • Be adequate, relevant and not excessive
  • Be accurate and kept up to date
  • Not be held for any longer than necessary
  • Processed in accordance with the rights of data subjects
  • Be protected in appropriate ways
  • Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

PEOPLE, RISKS, AND RESPONSIBILITIES

Policy Scope

This policy applies to:

  • The head office of Language Consulting
  • All branches of Language Consulting
  • All staff and volunteers of Language Consulting
  • All contractors, suppliers and other people working on behalf of Language Consulting

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus any other information relating to individuals

Data protection risks

This policy helps to protect Language Consulting from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with Language Consulting has some responsibility for ensuring data is collected, stored and handled appropriately. Whomever at Language Consulting handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

Krisia Dawn Justesen is ultimately responsible for ensuring that Language Consulting meets its legal obligations. She is responsible for:

  • Keeping updated about data protection responsibilities, risks and issues.
  • Reviewing all data protection procedures and related policies, in line with a set schedule.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from staff and anyone else covered by this policy.
  • Dealing with requests from individuals to see the data Language Consulting holds about them (also called ‘subject access requests’).
  • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

Krisia Dawn Justesen is responsible for IT used at Language Consulting, including computers, laptops, mobile phones and other devices that can store personal data. She will:

  • Ensure that all systems, services and equipment used for storing data meet acceptable security standards.
  • Perform regular checks and scans to ensure security hardware and software is functioning properly.
  • Evaluate any third-party services the company is considering using to store or process data. For instance, cloud computing services.

She is responsible for any marketing-related activities at Language Consulting. She is responsible for:

  • Approving any data protection statements attached to communications such as emails and letters.
  • Addressing any data protection queries from journalists or media outlets such as newspapers.
  • Where necessary, working with other staff or subcontractors to ensure marketing initiatives abide by data protection principles.

General guidelines for data usage

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, it can be requested from Krisia Dawn Justesen.
  • Language Consulting will request that suppliers understand their responsibilities when handling data.
  • In particular, strong passwords must be used and they should never be shared.
  • Personal data should not be disclosed to unauthorized people, either within the company or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to Krisia Dawn Justesen. When data is stored on paper, it should be kept in a secure place where unauthorized people cannot see or access it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason.

When not required, the paper or files should be kept in a locked drawer or filing cabinet. She will make sure paper and printouts are not left where unauthorized people could see them, like on a printer. Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorized access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between employees.
    If data is stored on removable media (like a USB or external disk), these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to Language Consulting unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, Krisia Dawn Justesen will ensure the screens of her computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically.
  • Personal data should never be transferred outside of the European Economic Area.
  • Only central copies of any data will be accessed and updated. There must not be multiple copies of personal data.

Data accuracy

The law requires Language Consulting to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort Language Consulting should put into ensuring its accuracy. Krisia Dawn Justesen takes reasonable steps to ensure it is kept as accurate and up-to-date as possible.

Data will be held in as few places as necessary. Krisia Dawn Justesen should not create any unnecessary additional data sets. She should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call. Language Consulting will make it easy for data subjects to update the information Language Consulting holds about them. For instance, via the Lightning English website. Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database. It is Krisia Dawn Justesen’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests

All individuals who are the subject of personal data held by Language Consulting are entitled to:

  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, using the below contact form. Enquiries sent through this form are sent directly  to Krisia Dawn Justesen. You can also call Krisia Dawn Justesen directly at +45 40329899.

Individuals will not be charged. Krisia Dawn Justesen will aim to provide the relevant data within 30 days.

Krisia Dawn Justesen will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Language Consulting will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information

Language Consulting aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How the data is being used
  • How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

PRIVACY POLICY

Who is behind this website?

At Language Consulting, I am committed to maintaining the trust and confidence of the visitors to my web site (Lightning English). In particular, I want you to know that Krisia Dawn Justesen is not in the business of selling, renting or trading email lists with other companies and businesses for marketing purposes. I just don’t do that sort of thing. But just in case you don’t believe me, in this Privacy Policy, I have provided lots of detailed information on when and why I collect your personal information, how I use it, the limited conditions under which I may disclose it to others and how I keep it secure. Grab a cup of tea and read on.

Website Cookies and Third-Party Services

Website

Comments

When visitors leave comments on the site WordPress collects the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. The WordPress privacy policy can be found here: https://wordpress.org/about/privacy/

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Embedded content from other websites

Articles and pages on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Google Analytics

When someone visits LightningEnglish.com, I use a third party service, Google Analytics, to collect standard internet log information and details of my website visitors’ behavior patterns. I do this to find out things such as the number of visitors to the various parts of my website. This information is only processed in a way which does not identify anyone. I do not make, and do not allow Google to make, any attempt to find out the identities of those visiting my website.

I have also enabled IP address anonymization so that my website users’ IP addresses are not transmitted to Google. Google’s privacy policy is here: https://policies.google.com/privacy?hl=en and you can read about IP address anonymization here.

Facebook

I work with third-parties such as Facebook (and Facebook-owned channels such as Instagram) to provide targeted advertisements. With Facebook, I use a pixel to collect anonymous information about what ads you have clicked on. The use of these tools can tell me when and how you came to visit my website, the pages that you visited and products you went on to buy. This information will be used to make advertising more relevant to your interests and keep you up to date with news of products and services, offers and promotions.

For more information and the privacy policy for Facebook Inc., visit http://www.facebook.com/policy.php 

More information on the data collection is at http://www.facebook.com/about/privacy/your-info-on-other#applications as well as http://www.facebook.com/about/privacy/your-info#everyoneinfo 

Gurucan

My online courses are hosted on the Gurucan platform. Gurucan collects necessary data and requires a login to give access to enrolled course participants. Gurucan then shares information with me about students’ purchases and their progress in the course. It also allows me to send participants email directly from the platform. These emails concern the specific courses participants are enrolled in, and information regarding their enrollment and access.

For more information and the privacy policy of Gurucan, visit https://www.iubenda.com/privacy-policy/61439206/full-legal

Demio

Some Lightning English events are hosted on Demio. This platform collects data about the people registered for the event, provides each with a unique link, and registers their behavior during the event, including time spent at the event, time spent in the event’s active window, and their behavior regarding downloads. This information is used to improve future versions of the events. For more information and the privacy policy for Demio, visit https://www.demio.com/privacy-policy

ConvertKit

I use ConvertKit to manage the Lightning English email list. Subscribers provide their first name and email address, and are required to confirm their subscription to the list. All emails sent from Lightning English through ConvertKit have an unsubscribe link in the footer. ConvertKit also collects information regarding users’ interaction with the emails, including opening details, links clicked, and files downloaded. I use this information to provide more relevant information to my email list. ConvertKit’s privacy policy can be found here: https://convertkit.com/privacy. In this document “Subscribers” includes people who subscribe to the Lightning English mailing list.

TuCalendi

The Lightning English booking system is managed by a third-party service, TuCalendi. It collects your name and email address, the time of the desired booking, and the answers to questions I specify in custom fields. For more information and TuCalendi’s privacy policy, visit https://www.tucalendi.com/en/privacy

Access to your personal information

If you are a client, or have enquired about my services, I will keep some personal data on file. This may include, but is not limited to emails, notes on paper, notes stored digitally, photos, video files, and audio files. You are entitled to view this data, and/or request the personal information that I hold be deleted. Email your request to me at krisia@lightningenglish.com.

Privacy Statement

Your privacy is important to me and I have taken measures to make sure that I protect it and let you know how I will use it. Below, you will find how your information is used.

Submitting a form on my website

I will use the information that you provide to me on my website to provide you with information you request, or to provide the services that you have requested. This may involve emailing you to confirm the service and for other administrative matters, or to inform you about changes to the service, or to notify you of new services.

Changes to my privacy policy

This privacy policy will be amended regularly to comply with current GDPR guidelines. The policy has been amended on 15 June, 2021.

USE OF THIS WEBSITE

This Website is controlled and operated by Krisia Dawn Justesen in Denmark. I make no representation that materials in the website are appropriate or available for use in other locations. Anyone who elects to access this website from any other location does so on their own initiative and is responsible for compliance with applicable local laws.

Use of website

The terms and conditions apply to your use of the Language Consulting website at LightningEnglish.com (the “Website”). The terms and conditions apply regardless of how you access the website, including any devices by which you can access the website at home, or on the move. You must read these Terms and Conditions carefully, and I recommend that you print and keep a copy for your future reference. By accessing, browsing, using the Website, or sending me information through the website, you confirm that you have read, understood and agree to these terms and conditions in their entirety. If you do not agree to these terms and conditions in their entirety, please do not use this website.

Use restrictions

The copyright in all material provided on this site is held by Krisia Dawn Justesen. Except as advised herein, none of the material on this site may be copied, reproduced, distributed, republished, downloaded, displayed, posted or transmitted in any form or by any means, including, but not limited to, electronic, mechanical, photocopying, recording, or otherwise, without the prior written permission of Krisia Dawn Justesen. Any use of these materials on any other site or networked computer environment for any purpose is prohibited.

Permission is granted to display and download the materials for your personal, non-commercial use only, provided you do not modify the materials and that you retain all copyright claims, marks and other proprietary notices contained within the materials. You can share the link to this website’s homepage or individual pages or blog posts on social media. You may pin photographs on Pinterest.

Ownership rights / copyright

All rights, including copyright and other intellectual property rights, in and to this website are owned by or licensed to Krisia Dawn Justesen.

Links to external websites

Links to third party websites on this site are provided solely as a convenience to you. If you use these links, you will leave the Lightning English website. We do not actively review all of these third-party sites, nor do they possess any control and are not responsible for any of these sites or their content.

Thus, Language Consulting does not endorse or make any representations about any other linked site, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites linked from this Site, you do this entirely at your own risk.