Purpose    Description    Legal basis    Justification for legal basis

Information we collect when you contact us

Contact form    When you send us a contact form through our website, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).     necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) GDPR    where your contact us about the providing of goods or services or the steps taken at your request prior to the providing of goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Mail     If you contact us by mail, we will collect any information you provide to us in any postal communications you send us.     necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) GDPR    where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

E-Newsletter     When you sign up for our e-newsletter on our website or opt to receive news, offers, updates on out-of-stock items from us by entering your name and email address and clicking subscribe or ticking a box at checkout indicating that they would like to receive your e-newsletter, we collect your email address , information about your browser, information about the page you signed up on, and any other additional information you may provide to us.     your consent (Article 6(1)(a) GDPR    you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Registering on our website     When you register and create an account on our website, we collect the following information: Email address, IP address, and any other information you provide to us when you complete the registration form.If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.     your consent (Article 6(1)(a) GDPR    you give your consent to create your account, to allow you to authenticate yourself and place an order, to allow you to update your account

Information to process your order

Information collected when you place an order     When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), billing name, and information about your browser.If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.     necessary to perform a contract (Article 6(1)(b) GDPR    we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Improvement of the products and services offered on the Website    to carry out satisfaction surveys (requests for opinions, surveys, etc.)to take into account, publish and, only if necessary, moderate your opinions on purchased productsto carry out customer studies (product tests, sales statistics, etc.)     our legitimate interests (Article 6(1)(f) GDPR    finding out how a customer’s experience was to improve your business’ website or to be able to contact the customer by phone where (if necessary) in relation to their order.[2]

 

Processing your payment     After you place an order on our website you will need to make payment for the goods or services you have ordered.    necessary to perform a contract (Article 6(1)(b) GDPR    to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing and self-advertisement

Marketing communications     At checkout and upon first arriving to the site you will have the option of receiving marketing communications from us.Our similar goods and servicesYou can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by ticking a box to opt out or clicking ‘unsubscribe’ in any email from us.We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.     consent (Article 6(1)(a) GDPR    you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Third parties

Information received from third parties     Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include partner companies who we are doing a joint promotion with.It is also possible that third parties with whom we have had no prior contact may provide us with information about you.Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.We also collect optional information from you, such as your phone number or information about how your experience was in the form of a survey. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.If you do not supply the optional information requested at checkout, such as phone number. we will not be able to contact you by phone or SMS.     consent (Article 6(1)(a) of the General Data Protection Regulation).    where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Disclosure and use of your information for legal reasons

Preventing fraud and criminality     Indicating possible criminal acts or threats to public security to a competent authorityIf we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.     Compliance with a legal obligation Article 6.1(c) GDPR    preventing crime or suspected criminal activity (such as fraud).

Disclosure of information in connection with the enforcement or potential enforcement our legal rights     We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).     our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).    enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings     We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.     our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).    resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements     We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.     Compliance with a legal obligation Article 6.1(c) GDPR    legal obligations to disclose information which are part of the applicable laws.

​

​

6.    Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

1.    Our use of automated decision-making and profiling[3]

We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of automated decision making and profiling described in this section. You can do that by (i) opting-out of cookies and similar technologies in accordance with the method described in the relevant section below or (ii) by writing to us in this regard. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

1.    You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: http://Team Positive Tutoring.com/en-us/cookie-policy Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.

2.    Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.

•    How to object: you can block these cookies by using the cookies control management tool on our site or by opting out of seeing personalised ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our cookies policy.

7.    Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

1.     Use of profiling for web analytics

Our web analytics services, Google Analytics and Qubit, Inc. use collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on) and how much you are spending on our site. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy. Information collected about you, once collected is anonymised and stored on an aggregate basis. IP addresses are anonymized at the point of collection on our site.

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by using our cookie control tool and your location will be analysed based on your IP address. We may target advertisements or content on our site based on the level of interest we receive from certain visitors and their behaviour on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation) and the basis upon you give us consent to use this by opting into cookie tracking.

[Legitimate interest: : improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires. Also to serve advertisements to you which seem most relevant to the visitor.

1.     Use of profiling in marketing emails

We use web beacons in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy (http://Team Positive Tutoring.com/en-us/cookie-policy ).

1.     Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

2.     Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates, click through rates, and what items you clicked on in an email.

•     How to object: You may object to this by contacting us at data_privacy@cotyinc.com or you may opt out by using our cookie control tool.

1.     Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

2.     Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content.

8.    Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

1.    Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

•    Hosting provider(s), including GoDaddy. 

•    Our third party service providers are located in the UK.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

1.    Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

9.    How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

1.    Retention periods

Order information: when you place an order for goods and services, we retain that information indefinitely or until you request that we delete unless this conflicts with our compliance of a legal responsibility.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form ,we will retain your information for as long as it takes to respond to and resolve your enquiry and indefinitely afterward unless it is requested to be deleted AND it does not interfere with our compliance with laws and our legitimate business interest.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

1.    Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

•    the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);

•    whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);

•    whether we have any legal basis to continue to process your information (such as your consent);

•    how valuable your information is (both now and in the future);

•    any relevant agreed industry practices on how long information should be retained;

•    the levels of risk, cost and liability involved with us continuing to hold the information;

•    how hard it is to ensure that the information can be kept up to date and accurate; and

•    any relevant surrounding circumstances (such as the nature and status of our relationship with you).

10.  How we secure your information

1.     List of security measures 

We understand that you care how your personal information is used and/or shared with others, and we value your trust and seek to safeguard your personal information.

 

We take appropriate technical and organisational measures, including physical and administrative, to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

•    only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;

•    using secure servers to store your information;

•    verifying the identity of any individual who requests access to information prior to granting them access to information;

•    using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;

•    only transferring your information via closed system or encrypted data transfers.

1.    Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

 

11.  Transfers of your information outside the European Economic Area

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we and our data processors process data may have laws which are different, and potentially not as protective, as the laws of your own country.

Your information will be transferred and stored outside the European Economic Area (EEA) or the United Kingdom (UK) in the circumstances set out below, notably toward the United States of America (USA), which does not offer the same level of protection of your personal data. We will also transfer your information outside the EEA or the UK or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Server log information

Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting company, Shopify. You can access their privacy policy here: www.shopify.com/privacy

Country of storage: Canada (country benefiting from an adequacy decision) and the United States (transfer subject to the European Commission’s Standard Contractual Clauses)

 

12.  Contact form and Email

Information you submit to us via our contact form is transferred outside the EEA and stored on our third party email and customer service systems. Our email provider is Adobe Inc..You can access their privacy policy here: https://www.adobe.com/privacy/policy.html.

Country of storage: United States(transfer subject to the European Commission’s Standard Contractual Clauses).

 

13.  E-Newsletter

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and the UK  and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Adobe Inc. You can access their privacy policy here: https://www.adobe.com/privacy/policy.html

14.  Country of storage: United States (transfer subject to the European Commission’s Standard Contractual Clauses). Text marketing

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and the UK and stored on our third party mailing list provider’s servers. Our third party text marketing provider is: Attentive Mobile, Inc. You can access their privacy policy here: https://www.attentivemobile.com/privacy

Country of storage: United States (transfer subject to the European Commission’s Standard Contractual Clauses).

 

15.  Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America.

 

16.  Payment Processors

Information you submit to us by our third party payment processors:

Shopify Payments, is transferred outside the EEA and stored on their servers. You can access their privacy policy here: https://pay.shopify.com/tos-privacy-policy

Country of storage: Canada (country benefiting from an adequacy decision) and the United States (transfer subject to the European Commission’s Standard Contractual Clauses)Global-e, does not transfer personal data outside the EEA and stores the personal data on their servers. You can access their privacy policy here: https://www.global-e.com/en/privacy-policy/ 

17.  Country of storage: Ireland. Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by filling out our contact form or sending an email to data_privacy@cotyinc.com

•    to request access to your information and information related to our use and processing of your information;

•    to request the correction or deletion of your information;

•    to request that we restrict our use of your information;

•    to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);

•    to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and

•    to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

•    https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and

•    https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

 

1.     Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

1.     How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

1.    Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to (“TEAM POSITIVE TUTORING”, “we” or “us”) to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and

•    to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

•    clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: http://Team Positive Tutoring.com/en-us/cookie-policy Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, we will not process it and will delete it.

 

18.  Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

19.  Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so.