CHINESE-ENGLISH LEGAL EDUCATION LIMITED (referred to as “we”, “us” or “our” in this policy) are committed to protecting your personal data and respecting your privacy. This policy sets out the basis on which we collect and process your personal data as a data controller when you use our app or services.
IMPORTANT INFORMATION AND WHO WE ARE
CHINESE-ENGLISH LEGAL EDUCATION LIMITED is a company registered in England and Wales with Company number 13826320 and our registered office is at 10-11 Austin Friars Austin Friars, London, England, EC2N 2HG.
We are the controller and is responsible for processing your personal data. Where services are provided to you by other entities within the wider CHINESE-ENGLISH LEGAL EDUCATION group, the entity providing the service will be responsible for your personal data.
This version was last updated on 24 May 2022. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you as follows:
· Identity Data such as first name, last name, maiden name, username or similar identifier, marital status, title, date of birth and gender.
· Contact Data such as billing address, delivery address, email address and telephone numbers.
· Financial Data such as billing address, bank accounts and payment information.
· Transaction Data such as details regarding payments made to or from you, and other details regarding services you have purchased.
· Device Data such as the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone settings.
· Profile Data such as your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
· Usage Data such as details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
· Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.
· Location Data such as your current location disclosed by GPS technology.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
HOW YOUR PERSONAL DATA IS COLLECTED
We will collect and process the following data about you:
Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together “Our Sites”), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion or survey, submit background information for the purpose of enquiring about out services and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
· Device Data from the following parties:
o analytics and search providers such as Google;
o Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK;
· Identity and Contact data from WeChat; and
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services where such services are used in connection with the App.
In order to use the App you may be required to share your data with certain third parties:
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so.With respect to these laws, we process personal information about you for one or more of the following circumstances :
· Where you have consented before the processing.
· Where we need to perform a contract we are about to enter or have entered with you.
· 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.
· Where we need to comply with a legal or regulatory obligation.
We will get your consent before sending you direct marketing communications via email or text message. You have the right to withdraw that consent at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Type of data
Lawful basis for processing
To install the App and register you as a new App user
To process in-App purchases and deliver Services including managing payments and collecting money owed to us
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the App
Marketing and Communications
Necessary for our legitimate interests (to develop our products/Services and grow our business)
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. You must not share a password with anyone.
Once we have received your information, we will use strict procedures and security features to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches and browser web storage.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and compliance purposes.
In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 3 years then we will treat the account as expired and your personal data may be deleted.
YOUR LEGAL RIGHTS
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
l Request access to your personal data.
l Request correction of your personal data.
l Request erasure of your personal data.
l Object to processing of your personal data.
l Request restriction of processing your personal data.
l Request transfer or your personal data.
l Right to withdraw consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting our DPO using the contact details at the beginning of this policy.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Importantly, these rights are not absolutely guaranteed and there are several exceptions where we may not have an obligation to fulfill your request. Please consult your local data protection laws to determine what rights may be available to you and which exceptions may apply.
YOUR RIGHT TO COMPLAIN
If you have any complaints about our use of your personal data, please contact us. Alternatively, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues. Details of how to do this can be found on the ICO website.
Lawful Basis For Processing:
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.