OHLA – Open Hearts Language Academy
Privacy and Cookies Policy
OHLA takes data privacy seriously and when we process your personal data we are processing it in compliance with the General Data Protection Regulation (GDPR).
Please read this privacy and cookies policy carefully to understand why data is being collected and what we do with that data once in our possession. Further information about data privacy may be found in our terms of business document.
What type of personal data will we collect from you?
The personal data we collect will depend on the nature of the services we are providing and what we are contracted to do for you. Typically where relevant, this might include the following:
- Contact details (including your name, address, date of birth, and email address)
- Photographic identification and proof of address documents (to carry out due diligence)
- Educational background documents (such as diploma, transcript, etc.
- Professional information (such as job title, previous positions, and professional experience)
- Banking and financial details (to establish the source of funds where a transaction is involved)
Where necessary to act in your best interest, we may need to process personal data which is very sensitive in nature such as diversity and health related details. In some circumstances, we may need to share this information with third parties, for example, accommodation providers, health and social care professionals, a court or other regulatory bodies. If you volunteer sensitive personal data, you will be allowing us to process it as part of engaging our services.
On what basis can we process your personal data?
Our reasons for processing your personal data are as follows:
- It is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you. The agreement between you and us, which is made up of our terms of business and engagement letter, sets out the terms of the contract and the services we will provide.
- It is necessary for the purposes of our legitimate interests, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this, we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.
- It is necessary in order to comply with mandatory legal obligations to which we are subject under EU or US law.
Personal data collected from you about other people
In commercial matters, in the course of providing our accommodation, health and social care and other professional services to you we will hold and use personal data about you and or your students. When you provide personal data to us relating to your students, you confirm that you are allowed to do so. You should ensure that those individuals understand how their data will be used by us.
In personal matters, you may be providing other third-party data to us, for example details about your family members, in which case we will use such data as a data controller in our own right and will comply with data protection legislation in relation to use of that data. You must have the authority to disclose personal data if it relates to someone else and all data disclosed should be complete, accurate and up to date.
What are we going to do with your personal data?
We will hold and use personal data about you to:
- Verify your identity and establish the source of funding in any transaction.
- Communicate with you during the course of providing our services, for example providing you with advice and dealing with your enquiries and requests.
- Prepare documentation to access services and/or complete transactions.
- Carry out obligations arising from any contract entered into between you and us as part of your educational, health and social care services.
- Refer you to another of our departments about additional legal services which may benefit you.
- Statistical purposes so we can analyze figures to help us manage our business and plan strategically for the future.
- Seek advice from third parties in connection with the services we provide.
- Respond to any complaint or allegation of negligence against us.
- Prevent money laundering or terrorist financing in accordance with financial crime regulations.
- Improve the products and services we provide.
- Customize our website for you.
- Send you information about products, services, offers and other things we think might be relevant to you.
How long do we keep your personal data for?
We will only retain your personal data for as long as is necessary to:
- Carry out health, care, educational and accommodation services.
- Establishment or defense of legal claims (for example negligence claims) that could be made against us.
- Compliance with legal obligations under EU/US law (anti-money laundering regulations say your identification and source of funds information must be kept for a minimum period from conclusion of the matter). We will keep your data in accordance with our data retention and erasure policy, a copy of which is available on request.
Who your personal data will be shared with?
We may, when required and necessary, share your personal data with other organizations. Depending on the work we are undertaking for you the other organizations may include:
- Our organization’s “accommodation providers” who are contractors from whom we obtain accommodation services.
- “Data controllers” that provide professional or commercial services, such as lawyers, accountants, medical and health practitioners.
- Experts that you and we agree are necessary to assist us to progress your matter.
- Providers of insurance, health and social care, educational and other related services to you and/or to our organization.
- Councils and other national and local government bodies.
- Organizations involved with the preparation, assessment and certification of quality standards for which our organization is seeking or maintaining accreditation.
Controlling information about you
If you have agreed that we can use your information for marketing purposes, you can change your mind easily, via one of these methods:
- Send an email to us.
- Write to us.
We will never lease, distribute or sell your personal information to third parties unless we have your permission, or we are required to disclose your personal details by law. Any personal information we hold about you is stored and processed under our data protection policy.
Security of your personal data
Your data will be held on secure servers with all reasonable technological and operation measures put in place to safeguard it from unauthorized access. Where possible any identifiable information will be encrypted or minimized.
Erasure of personal data
Where we obtained your personal data to fulfil our contractual obligations to you, or if we have a legitimate interest for processing your personal data, we will erase that data as soon as it is no longer necessary to retain it in relation to the purpose for which it was originally collected.
If you are not our client, your personal data may be processed to enable us to provide legal advice to our client and may also be used in legal proceedings on behalf of our client. We are allowed to use your personal data because it is in the legitimate interests of our client to do so. We may also have to use your personal data to comply with our own legal and regulatory obligations.
Cookies are small text files that are placed on your computer by websites you visit. Cookies help make this website work and provide information to us about how users interact with our site. We use this information to improve our website.
The cookies we use help to provide us with anonymized, aggregated technical information. This is principally so that we can make sure that the website is easy to navigate, identify the areas that are of particular interest to visitors and generally improve the site and our services. The information that we collect in this process will not identify you as an individual.
We do not seek to identify individual visitors unless they volunteer their contact details through one of the forms on the site. In some circumstances, our records will identify organizations visiting our site and we may use that information in managing our relationship with those organizations, for example, in considering how to develop the services that we offer them.
By using our website, you agree that we can place these types of cookies on your device.
When you accessed this website, our cookies were sent to your web browser and stored on your computer. If you wish to remove them, you can manage this via the settings on your browser, but note that this may impact your ability to utilize this and other websites. The way to clear cookies varies from one browser to another. You should look in the “help” menu of your web browser for full instructions. For your reference, please click the following links for details on how to manage cookies in each of the major web browsers:
If you have any questions about our privacy policies, want to exercise your right to see a copy of the information that we hold about you, or think that information we hold about you may need to be corrected, want to delete all or any part of it or to object to the processing on legitimate grounds, please contact Yves Paradis at firstname.lastname@example.org.
Revised as per May 25, 2021