We take your privacy very seriously and we are committed to protecting your personal information. This policy explains how we collect and use any information about you. If you have any questions please contact support@guidedelearning.com.

 

1. Who are we?

Guided E-Learning Ltd (company registration number company number 05843373 and registered address 2nd Floor 32 Brixton Road, London, SW9 6BU) will hold your personal information received in connection with and/or through the Portal and/or the Website and/or the Mobile App. For more information on us, please see our Website.

 

2. The types of information we collect and how we collect it

 

When you register and use the Guided e-Learning Community Portal (the “Portal”) and/or when you visit the Guided e-Learning website (the “Website“) and/or when you use the Guided e-Learning mobile application (the “Mobile App”), we may collect certain personal information from you.

 

You can sign up to access the Portal directly through the Website, or your school, the British Council or an education agent who is assisting you in applying to university in the UK (an “Education Agent”) may arrange for your access. The personal data we receive depends on how you access the Portal, the table below sets out the different personal data we receive.

 

How you access the Portal	Personal data
Where you sign up on the Portal directly (either on the Website or the Mobile App)	·       Name, email address, phone number, address, credit card details and/or your paypal details. ·       Academic record (including test and assessment results) ·       Login history ·       IP address ·       Your test scores ·       Information about why you are taking the exam ·       Any personal data you include in submissions to exam questions, including written, audio and video recordings.
British Council (outside of China)	·       Test taker ID, name, email address, test date and test type ·       Academic record (including test and assessment results) ·       Login history ·       IP address ·       Your test scores ·       Information about why you are taking the exam ·       Any personal data you include in submissions to exam questions, including written, audio and video recordings.
British Council (inside China)	·       NEEA number and email address ·       Academic record (including test and assessment results) ·       Login history ·       IP address ·       Your test scores ·       Information about why you are taking the exam ·       Any personal data you include in submissions to exam questions, including written, audio and video recordings.
Where your School or an Education Agent signs you up	·       Name, e-mail address and access end date ·       Academic record (including a record of classes attended, test and assessment results) ·       Login history ·       IP address ·       Your test scores ·       Any personal data you include in submissions to exam questions, including written, audio and video recordings.

 

Where you are an IELTS student we will also be provided with your test date, a desired band score and test type (either by you directly, the British Council, your school or Education Agent, as applicable).

 

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website or Mobile App feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may also receive certain personal information from you when you contact us by phone or email.

Where you answer exam or assignment questions, you have the option to provide us with personal data as part of these answers. The personal data you provide is your decision, and you do not have to provide us with any personal data as part of these answers.

3. How do we collect your personal data?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us on the Portal or by phone, email or otherwise. This includes personal data you provide where you sign up to the Portal directly, or where you provide us with personal data after your school, the British Council or an Education Agent has signed you up the Portal. This could include:
  • providing your email address to us;
  • providing us with the reasons you are taking the exam;
  • asking for technical or academic support from our support team or a teacher;
  • subscribing to our newsletter; and/or
  • answering written or spoke assessment questions with personal data.
• Automated technologies or interactions. As you interact with our Website or Mobile App, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy below for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • Where you are based outside of China and where the British Council provides you with access to the Portal, the British Council will provide us with your name, email address, test taker ID, test date and test type;
  • Where you are based inside China and where the British Council provides you with access to the Portal, the British Council will provide us with your NEEA number; and

Where your school or Education Agent provides you with access to the Portal, your school or Education Agent will provide us with your name and email address. Your school or Education Agent may also provide us with your test taker ID, test date and test type. If you have any questions about what data your school or Education Agent has or will provide us with then please get in touch with us or ask your school or Education Agent.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• for the purposes of performing part of the contract you have entered into with your school or Education Agent, the British Council or directly with us;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
• where you have provided express consent.

5. Purposes for which we will use your personal data

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new student	Name, email address, test taker ID, and/or NEEA number	Performance of a contract with you Necessary for our legitimate interests (to run our business and provide the Portal)
To take payment from you	Name, payment details, email and address	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To provide our services to you	Name, email address, academic history, test date and type of test, test scores, submissions to exam questions, information about why you are taking the exam.	(a) Performance of a contract with you (c) Necessary for our legitimate interests (to run our business and provide the Portal)
To keep your school the British Council, or Education Agent up to date on your progress	Name, email address, academic history, test date and type of test, test scores, and submissions to exam questions.	(a) Performance of a contract with you (c) Necessary for our legitimate interests (to run our business, provide the Portal and keep the British Council or your school up to date)
To administer and protect our business this Website, and the Mobile App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Name, email address, technical data, such as IP address, and login history.	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to prevent fraud)

 

6. Disclosing your personal data

We may share your personal data with the following third parties:

• With our teachers so that they can provide lessons and check your work;
• Where your school or Education Agent has arranged access to the Portal, we will provide your name, email address, academic history, test date and type of test, test scores, and submissions to exam questions to your Education Agent or school and/or to individual teachers at your school;
• Where the British Council has arranged access to the Portal, we will provide your name, email address, academic history, test date and type of test, test scores, and submissions to exam questions to the British Council; and
• Our IT providers, including:
  1. Sisense, which provides us with analytics on our service;
  2. Cloudflare, which ensures that the Portal is secure;
  3. Google Cloud, which hosts the Website, the Portal and stores all data (other than in China); and
  4. Alibaba Cloud which hosts the Website, the Portal and stores all data in China.
  5. Carnegie Speech who provide machine analysis of written submissions.
  6. Microsoft Azure who provide machine analysis of written submissions
  7. ELSA who provide machine analysis of spoken submissions

Whenever we transfer your personal data from the UK and/or EEA to outside of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK and EEA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Retaining your data

Where your school, the British Council or Education Agent arranges your access to the Portal, we will retain your data for 5 years from when it is provided to us, or longer if required by your school, the British Council or Education Agent (if applicable).

Where you have signed up to the Portal directly, we will retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

8. How do we protect personal information?

 

We place great importance on the security of your personal information and we always try to take appropriate precautions to protect it.

Despite all of our precautions however, no data transmission over the internet can be guaranteed to be 100% secure. So, whilst we strive to protect your personal information, we cannot guarantee the security of any information which you disclose to us or which is disclosed to us by your school, the British Council or Education Agent.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website and/or our Mobile App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

 

9. Your rights

 

You have a right to access the personal data that we hold about you. You also have a right to request that we rectify any inaccurate personal data that we hold, and, in certain cases, to ask us to erase any of your personal data that we hold. Where we are relying on consent to process your personal data, you can withdraw your consent. You also have the right to object to the processing of your personal data, request restriction the processing of your personal data and request a transfer of your personal data to a third party.

If you would like to exercise any of these rights please use the email address at the beginning of this policy.

If you have any questions about this privacy policy or our privacy practices, please contact email us using the address above.

If you are unhappy with the way in which your personal data has been handled you are entitled to make a complaint to the Information Commissioner’s Office. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

10. Changes

If your personal details change, please help us to keep your information up to date by notifying us at the email address at the beginning of this policy.

We may amend or update this policy at any time to take account of any changes to data protection law or other legislation.

1. What are cookies and tracking technologies?

A cookie is a text file containing a small amount of data downloaded to your computer when you visit our Portal and/or our Website.  The vast majority of websites use cookies.  Cookies can be useful because they help us select the content of our website and recognise you as a user. Some cookies are essential to enable you to move around our Portal and/or our   Website and use its features. A list of all the cookies that we use can be found in our cookie list.

2. The cookies we use now and how to delete them

When you access our Portal and/or our Website you will receive a message advising you that we use cookies.   This was necessary in order to display the web pages to you.  If you continue to use our Portal and/or our Website, further cookies will be placed on your computer. If you do not want us to place cookies on your computer then you can opt out in multiple ways:

• setting your browser to reject all cookies;
• to only allow “trusted” sites to set them; or
• to accept only those cookies from those websites which you are currently on.

Please remember if you opt out of cookies, our Website and/or our Portal may not be fully functional for you.

For further information please see the website: allaboutcookies.org.

3. Our classification of cookies

3.1 We classify our cookies in the following ways:

Strictly Necessary

These cookies are essential to enable you to move you around the Portal and/or the Website and use its features, such as accessing secure areas.

Performance

These cookies collect information about how you use our Portal and/or our Website, for instance, which pages you go to most often and if you get error messages from those pages.  We only use these cookies to improve how our Portal and/or our Website work.

Functionality

These cookies allow us to remember the choices you make (such as your user name) and provide enhanced features.

4. Our Cookies

Strictly Necessary	PHPSESSID
Performance	__cfduid __utma __utmb __utmc __utmt __utmv __utmz __ga __gat
Functionality		browserupdate.org

 

5. Our technology partners

We work with the following companies in maintaining and improving our web pages.

We use Google Analytics to better understand how our customers navigate to and through our web pages, how long customers spend visiting our content items and how often they return to visit our Portal and/or our Website.  Google’s privacy policy may be found here: Privacy Policy.

We use New Relic to monitor performance of our servers and our web pages around the world. New Relic’s privacy policy may be found here: Privacy Policy

We use Cloudflare to improve the performance and security of our servers. Cloudflare’s privacy policy may be found here: Privacy Policy