Name of DPO: Rachael Convery
Email address: email@example.com
Postal address: 2nd Floor, Warwick Building, Kensington Village, Avonmore Road, London W14 8HQ, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to address your concerns before you approach the ICO so please contact us in the first instance.What is personal data?
Personal data is any information about an individual from which that individual can be identified. Your name, address, phone number and bank account number are examples of personal data. It does not include data where an individual’s identifying information has been removed (anonymous data).Personal data we collect
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:
- Where we need to fulfil a contract we have entered into with you.
- Where we need to comply with a legal obligation.
- 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.
We may also use your personal data in the following situations, which are likely to be less common:
- Where we need to protect your vital interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
If you have provided consent, we may send direct marketing communications to you. You have the right to withdraw consent to marketing at any time by following the opt-out links on any marketing message or by contacting us at firstname.lastname@example.org.
Examples of how we may use your personal data:
- for the purpose you provided personal data, for example to enrol you in one of our courses, to process your order of one of our products or to respond to a specific enquiry;
- to enhance your experience of other Manhattan Prep products and services;
- to administer, support, improve and develop our business;
- send you information about Manhattan Prep products or services and information that we believe will be of interest to you or to send you information about select third party’s products or services that may be of interest to you;
- allow you access our websites to post your content or communicate with others; and
- as otherwise described to you at the point of collection.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.Cookies
When someone visits www.manhattanprep.co.uk (the “Site”) we install cookies that contain standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to various parts of the site. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting either of our websites. We will not associate any data gathered from cookies with any personally identifying information from any source.
A cookie is a string of information that is sent by a website and stored on your hard drive or temporarily in your computer’s memory. You can disable our cookies using the cookie-menu on your Web browser, but doing so may materially affect the functionality of the Sites and the information you can access through it. To learn more about cookies and browser functionality, search for “cookies” in the help function of your browser.
We and our service providers also may use so-called “pixel tags”, “web beacons”, “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some Site pages and HTML-formatted e-mail messages to, among other things, compile aggregate statistics about Site usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to Site visitors and may be associated with cookies on the visitors’ hard drives. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns.When and how we share your personal data with others
We do not share personal data with third parties for their marketing purposes. We may hire other companies to perform services on our behalf including, without limitation, facilitating some aspects of our web site and services, managing our database, sending e-mail and other mail to you, processing and collecting payments, providing us with legal, financial and accounting advice and conducting required audits. These other companies may be supplied with or have access to your information solely for the purpose of providing these services to us or on our behalf. We also may disclose personal data in special circumstances where it is necessary under the law (for example, when necessary to protect our or a third party’s intellectual property or proprietary rights) or when we, at our sole discretion, believe it is appropriate, in connection with a sale or transfer of some or all of our assets, or when we, in good faith, believe that the law requires us to do so.
If you have Enrolled in our courses through your employer, sponsor or educational institution, we may share your personal data, Programme participation and other user data with such third party or parties. Similarly, if a third party pays for your Enrolment in a Programme, we may share your data with that third party.
We may share your personal data with our affiliates, subsidiaries and other members of the Kaplan group of companies, including companies located outside of the EU. In many cases, Kaplan may disclose aggregated and anonymous data, which may include information about or derived from you, with third parties.
If you are under 18, we may share your personal data with your parents or guardians in order to perform our contract, comply with our legal obligations and if it is in your vital interests.The security of your personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, service providers, business partners, agents and other third parties who have a legitimate need to know. They will only process your personal data on our instructions or as otherwise agreed and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.Our storage and retention of your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Please contact us at email@example.com if you would like more information.
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 your working relationship with us.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.Your rights as a data subject
Under certain circumstances, by law 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 that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- 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 exercised your right to object to processing (see below).
- 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. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us at firstname.lastname@example.org.What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.Your right to withdraw consent