Choices International Limited (“We”) are committed to protecting and respecting your (you, your) privacy. We take the privacy of all of our customers and other users seriously and take great care to protect your personal information.
This policy (together with our Terms of Website Use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting internationalacademyfootball.com you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Choices International Limited of 11 Portland Street, Manchester M1 3H1.
PRIVACY & GENERAL PRINCIPLES
Please read the following policy carefully to understand what information we may collect from you, how we may use it, and your rights in respect of our use.
We will be guided by the following principles when processing data:
- We will only collect data for specific and specified purposes; we will make it clear at the point when we request your information, what we are collecting it for and how we are going to use it.
- You may give us information about you by filling in forms on our site https://internationalacademyfootball.com/(our site) or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our site, subscribe to our service, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, email address and phone number, financial and credit card information, personal description and copies of identification documents.
- We will not collect data beyond what is necessary to accomplish those purposes; we will minimise the amount of information we collect from you to what we need to deliver the services required.
- We will collect and use your personal information only if we have sensible business reasons for doing so, such as managing a booking or gathering necessary information about a new member of staff, ETO or homestay.
- We will not use data for purposes other than that for which the data was collected, except as stated herein, or with prior consent.
- We will seek to verify and/or update data periodically, and we will accept requests for amendments of personal data.
- We will apply high technical standards to make our processing of data secure.
- Except when stated herein, we will not store data in identifiable form longer than is necessary to accomplish its purpose, or as is required by law.
We collect information on you:
- When you apply to join a course or programme at the school.
- When you contact us for information, via our website, by email, by phone, in person or via social media channels.
- When you work with us in a commercial capacity (for example as an ETO or partner).
- When you apply to be a homestay or residential accommodation.
- When you apply to work at Choices International, and when you are subsequently employed by Choices International.
- When you sign up for sport programmes with or without lessons; for a newsletter or subscribe to other services.
- When you give us feedback about your experience of Choices International.
- When you use our website or download our app.
- If you post on our social media channels or on our website or blog.
LEGAL BASES FOR PROCESSING YOUR DATA
The General Data Protection Regulation (GDPR) establishes 6 legal bases on which we can process your data: these are Consent, Contract, Legal Obligation, Vital Interests, Public Task and Legitimate Interests. For further information about these legal bases and fuller definitions, please refer to the ICO website.
We use different legal bases for processing your data depending on the purpose for collecting your data in the first instance:
- For all data collected as part of the process of enquiring about, applying for and booking a course or for any other related service (e.g. homestay, airport transfer, social programme, insurance to cover you during your stay), or where you give us feedback about aspects of this provision, we process using Contract or Legitimate Interests, namely the fulfilment of the booking. This may include sending of your data to our partners such as Educational Tour Operators (ETOs), Government Agencies or Schools. Where required by law to do so, we may also process your data under Legal Obligation.
- Any processing of customer data not directly related to the fulfilment of a booking or related services, such as signing up for newsletters or free lessons on our website, or sending messages to you on behalf of third parties, is managed under Consent. From time to time, we may use elements of the data you supply to target the messages we send to you. For example, we may use your location to send you information about an event or opportunity happening in your area. During your stay, we may take photographs or videos of you, and the use and processing of these is also managed through Consent.
- For all data collected as part of managing our relationship with commercial partners, such as ETOs, Government Agencies and Schools, we process using Contract, Legitimate Interest and Legal Obligation, namely the maintenance of the commercial relationship. As newsletters to commercial partners are an important part of how we communicate with them, these are managed under Legitimate Interest.
- For all data collected as part of the process of employing and managing staff, we process using Contract, Legal Obligation and Legitimate Interests, namely the employment of the employee. This will include data required for HMRC, pensions, insurance (including staff health insurance cover). As newsletters to our staff are an important part of how we communicate with them, these are managed under Legitimate Interest.
- For all data collected as part of the process of recruiting and managing homestay providers, we process using Contract, Legal Obligation and Legitimate Interests, namely the maintenance of the relationship with the homestay. As newsletters to homestays are an important part of how we communicate with them, these are managed under Legitimate Interest.
- We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is Legitimate Interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- To notify you about changes to our services.
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
- As part of our efforts to keep our site safe and secure.
- To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is Legitimate Interest, namely the proper protection of our business against risks.
We will make it as easy as we can for you to opt out of unwanted processing under Consent, providing it does not restrict our ability to provide you with the primary service you have requested.
We collect data for a wide range of purposes. Data is managed to ensure that it is either erased from our system when it is no longer required for the purpose for which it was collected, retained for legal reasons, or pseudonymised and/or minimised and retained.
We are co-processors of information relating to marketing and booking clients with partners overseas (for example ETOs, schools, government and national sponsors). As such, we may transfer some data outside of the EU, but this will be limited to data necessary for the performance of a contract made in the interests of the individual (which is an exemption to the 8th principle of the GDPR legislation). We remain responsible for the data held, processed or sent via our systems. We are not responsible for the security and processing of data which is held, processed or sent via our partners’ systems. However, we require all of our partners overseas to confirm that they will process data securely in line with the requirements of GDPR or the equivalent in their country. We do not sell your data at any time.
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Choices International Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
SPECIAL CATEGORY DATA/CRIMINAL RECORD DATA
We may request health data from potential students and employees. This data has special protection under the GDPR under the specific conditions listed in Article 9 (2) of the GDPR that processing is necessary either to protect the vital interests of the data subject, (or of another natural person where the data subject is physically or legally incapable of giving consent), or where processing is necessary for the purposes of preventive or occupational medicine or the assessment of the working capacity of an employee.
The school has safeguarding responsibilities and carries out DBS checks on all staff and other people who are likely to be have direct supervisory responsibility for or unsupervised contact with young people under the age of 18. We may process and record securely risk assessments of these DBS checks where the disclosure is not clear. These risk assessments will be disposed of securely when that person no longer has supervisory responsibility or unsupervised contact with young people under the age of 18 on behalf of the school.
CHILDREN UNDER 18
We collect or store personal information about children under the age of 18 in the context of managing bookings and directly related products, and for safeguarding purposes. Permission is obtained directly from a legal adult guardian to collect this information through our Parental Consent Form. As part of this process, we request special category data relating to the health of the child, which we manage through Vital Interest.
We also gain consent from parents for the use of photos or video taken during their child’s stay at Choices International through the Parental Consent Form.
How we will use information collected by our website
We may use information held about you in the following ways:
- To process a booking for one of our courses or products.
- To manage an application to work for us, or to be a homestay.
- To create a profile for you to help us provide a more personalised service which is suited to meet your preferences.
- To ensure that content from our site is presented in the most effective manner for you and your computer.
- To send you our newsletters or provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
Links from our website
PERSONAL INFORMATION AND YOUR RIGHTS
You have the right to rectify, erase or restrict the processing of your data subject to the exceptions outlined in this policy. You also have the right to withdraw consent to the processing of information for which you have previously given consent. You can contact us at any time to have these details removed from our database or to update this information, subject to satisfactory proof of your identity. You can read more about your individual rights on the ICO website.
You may also request access to the data we hold on you. Provision of such information will be subject to:
a) The payment of a fee (currently fixed at £10)
b) The supply of appropriate evidence of your identity.
We may withhold personal information that you request to the extent permitted by the law.
To make any of these requests relating to your personal data, please contact us at: email@example.com
LEGAL INFORMATION AND HOW TO CONTACT US
Any request for information (personal information, requesting a correction, or comments) should be addressed in the first place to: firstname.lastname@example.org