Privacy Policy

May 2018

1. Introduction

1.1 This Privacy Policy explains how Reflection Investment B.V., along with its affiliates (hereinafter referred to as “we”, “us” or “inlingua Edinburgh”), collects, uses, shares, transfers and protects the personal information of the user (hereinafter referred to as “you”) and the corresponding rights of the user. Personal information refers to any information related to a natural person that has been identified or is identifiable. Please let us know if you have any questions.

1.2 This Privacy Policy shall apply to platforms on which it is displayed, including but not limit to the inlingua Edinburgh website, products, and services, and other platforms which link to this Privacy Policy. If this Privacy Policy does not cover certain specific personal information processing scenarios, we will explain it to you in the form of supplementary policies or pop-up windows.

1.3 We may process your personal information in different scenarios based on different legal reasons, such as performing contracts and providing products and/or services to you, based on legitimate business interests or with your prior consent.

2.Personal Information may collected by inlingua Edinburgh

In any scenario in which you interact with us, we are likely to ask you to provide personal information. If you do not provide the relevant information, you may not be able to achieve the specific purpose for a particular scenario. For example, you cannot purchase an inlingua Edinburgh course / service; our admin team cannot reach you and provide you with pre-sales and after-sales service; or you cannot access to our online test, online payments solutions, you cannot receive special offers.

Here are some of the scenarios where we may collect your personal information:

2.1 When you register for an English or Language course, you may provide relevant personal information, such as user first name, last name, gender, phone number, email, mailing address, zip code, diet information, accommodation options, method of payment and bank account information, etc.

2.2 Where permitted by law, inlingua Edinburgh may also obtain data about you from third-party sources. For example, when you use a third-party network account or via an Agent / partenr to register at inlingua Edinburgh, we may obtain your personal details from a third-party network service company. Depending on your choice of third-party network account, we may collect your WeChat account, Facebook or Google account information. In such case, only the account information will be obtained.

2.3 When you study with us, we may also collect information about your courses, feedbacks, language level, expectations, nationality, age, religion, etc.

2.4 When you call our admin team for assistance, we may ask for your name, phone number, booking details and record your number of calls, date of call, problem encountered and the solution we give to you.

2.5 If you participate in one of inlingua Edinburgh events, we may also ask for information such as your name, gender, email address, and phone number, target language, previous knowledge, etc.

2.6 Your information shared through inlingua Edinburgh Community, such as your personal photos uploaded on our Facebook Page, WhatsApp group, your thoughts and experiences shared through forums and friends, etc.

3. How inlingua Edinburgh may use Personal information

inlingua Edinburgh will use your personal information based on the following legitimate purposes. One or more purposes may be applied at the same time. If we use your personal information beyond the following purposes or the scope allowed by the law, we will obtain your consent again on the basis of special purpose needs.

3.1 Used for authentication, security, fraud monitoring, archiving purposes to ensure the security at our school and services provided to you by inlingua Edinburgh.

3.2 Provide you with services such as course confirmation, quotes, invoices, receipt and delivery of goodies; refund of payment for goods; after-sales support; accommodation booking / upgrade information, and other similar purposes.

3.3 Help inlingua Edinburgh to improve products and services. For example, inlingua Edinburgh will analyse and study the collected data to make user-friendly adjustments to its website and interface design in accordance with user characteristics. When you choose to share your feedback, inlingua Edinburgh can modify offers, improve services according to your reviews, which helps to ensure that quality is the best.

3.4 With your consent, inlingua Edinburgh may send you our latest offers and service information, and may also send you holiday greetings. You may choose to unsubscribe at any time if you do not wish to receive such information.

3.5 Description of services based on location information: some pre-loaded web-section in inlingua Edinburgh website provide services based on the user’s precise or unique geographic location, such as maps, navigation and price lists, special packages. These services are provided by third parties independent of inlingua Edinburgh. Therefore, your personal information, including your location, will be collected and processed by third parties and not controlled and processed by inlingua Edinburgh. You can choose to turn off location-based services and refuse to share location information.

4. Instructions on the use of Cookies and similar technologies

4.1 In order to ensure that the website works well, inlingua Edinburgh will use cookies and similar technologies such as pixel tags and website beacons. Cookies are plain text files that are stored on a computer or mobile device by web server. The content of cookies can only be retrieved or read by the server that creates it. Each cookie is unique to your web browser or mobile app. Cookies usually contains some identifiers, commonly-used information and other details. For instance, you can reduce the number of login authentications needed and improve your experience through cookies technology when browsing different web pages of inlingua Edinburgh website. Otherwise, you may not be identified as the same person and may be asked to enter the authentication information again if logging onto to inlingua Edinburgh website and then be required to go to another web page of inlingua Edinburgh website.

4.2 These technologies help inlingua Edinburgh and third parties to better understand user behavior, tells inlingua Edinburgh which section of inlingua Edinburgh website you have browsed, and measure and improve the effectiveness of inlingua Edinburgh’s services. inlingua Edinburgh will not use cookies for any purposes other than as described in this policy. You can manage or delete cookies based on your own preferences. However, please note that some inlingua Edinburgh services may be designed to require the use of cookies and disabling cookies may affect your rights to use these services or some of these features.

4.3 In addition to cookies, inlingua Edinburgh also uses other similar technologies such as local storage, web beacons, and pixel tags on its website. Like local storage of HTML5, this can cache frequently-used data related to you so that such data can be rendered to you quickly when you switch between different web pages of the inlingua Edinburgh website. For another example, an email sent to you may contain a click URL linked to the content of the website. If you click on the link, this click will be tracked to help inlingua Edinburgh better understand your product and service preferences and improve customer service. Web beacons are usually transparent images embedded in websites or e-mails. With the help of the pixel tags in emails, inlingua Edinburgh can know whether the email content is effectively served to the user.

5. How inlingua Edinburgh may share personal information

5.1 We may disclose your personal information between affiliates or subsidiaries and ensure that the same level of protection is provided for your personal information between affiliates and subsidiaries.

5.2 inlingua Edinburgh may disclose your personal information to its partners under certain circumstances. For example, when you book inlingua Edinburgh services through inlingua Edinburgh’s online store, inlingua Edinburgh will disclose your services purchase and personnal information to our authorized administration team.

5.3 In addition, inlingua Edinburgh may disclose your information to public authorities with jurisdiction over the territories in which we operate to provide personal information of our users in compliance with the law or in the performance of legal procedure.

5.4 In any case of sharing your personal information with third parties, we endeavor to disclose it to such third parties only to the extent permitted by law and we require data recipients to process and protect your personal information in compliance with applicable laws and regulations.

5.5 inlingua Edinburgh promises not to sell personal data to any third party and guarantees the legitimate and fair use of user information only to the extent permitted by law.

6. How you access and control your personal information

6.1 inlingua Edinburgh will do its utmost to take the appropriate technical measures to ensure that you can access, update, correct and delete your own registration information or other personal information provided when using inlingua Edinburgh services. When you access, update, correct and delete the aforementioned information, you may be asked for authentication to protect the information security.

6.2 You can control your own personal information. For example, you can turn off the location sharing button to stop sharing your device’s location information, or you can revoke prior consent for data collection and processing. However, please understand that once you make above choice, you may not be able to enjoy the related services.

6.3 Wherever required, you can contact us through contact information provided in this Privacy Policy. If we have a reasonable basis to believe that your request is fraudulent and/or cannot be verified, or certain personal data rights are not stipulated by law in your country and region, we will reject your request.

7. How inlingua Edinburgh protect Personal information

7.1 inlingua Edinburgh only retains your personal information for the time period necessary for the purposes described in this Privacy Policy and as required by applicable laws and regulations.

7.2 inlingua Edinburgh uses various management policies (such as establishing information security system; signing a confidentiality agreements with information management employees; allowing only work-related employees to access the information collected; and other similar policies) and security techniques and procedures (such as entering passwords before access, access control isolation, monitoring for computer use, etc.) to prevent the loss of information, improper use, and unauthorized reading or disclosure. For example, in some services, inlingua Edinburgh uses encryption technology (such as SSL) to protect the personal information you provide. However, please understand that due to technical limitations and possible malicious means, it is impossible for any company providing Internet-related services to guarantee 100% security of information, even if all efforts are made to strengthen security measures. You need to understand that the systems and communication networks you use to access inlingua Edinburgh services may be subject to problems that are beyond inlingua Edinburgh’s control.

7.3 If inlingua Edinburgh is informed that the security of the data it has acquired and stored is compromised or the user’s nonpublic information is disclosed to an unrelated third party due to external acts (such as hacker attack), inlingua Edinburgh will take reasonable actions (including but not limited to internal investigations, reporting and notification to law enforcement agencies, and cooperation with the law enforcement agencies) as it may consider appropriate, notwithstanding any disclaimer in this Policy. In parallel, inlingua Edinburgh will take legal and reasonable steps as it deems appropriate to notify the relevant users, informing them of the information disclosed and the extent to which we are aware of such situations.

7.4 Data cross-border transfer: your personal information may be transmitted and transferred across borders, and stored and processed in the target country. Depending on the laws in your country, the receiving country and region of these data may not meet the requirements. We promise that we will have the right security measures to ensure that the protection level of data can meet the full requirements of the laws and regulations of your country and region.

8. Third-party service

8.1 This Privacy Policy does not apply to products and services provided by third parties. inlingua Edinburgh products and services may include products and services from third parties, as well as links to third-party websites. When you use these third party products or services and personal information is collected and/or processed, the privacy policy of the third party shall apply.

8.2 We are not responsible for how third parties collect, use, share, transfer and protect user’s personal information, and cannot control how it is processed.

8.3 To avoid any misunderstandings, please refer to this third party’s service agreement and read its privacy polic

9. Change and modification

9.1 You may request a copy of this Privacy Policy from us using the contact details listed below. We may amend or update this Privacy Policy from time to time. You will be able to see our last updated privacy policy, along with its revision date. The revised privacy policy will take effect from the date of publication. Please check the Privacy Policy from time to time to confirm whether we have made any changes with reference to use of personal information.

9.2 If any changes to this Privacy Policy have a material impact on your rights, we will take reasonable steps to notify you of such changes.

10. Notification and delivery

10.1 Any notice from inlingua Edinburgh will be sent to the email address, phone number, and/or mailing address left when you register for an account or purchase of inlingua Edinburgh product, or pushed directly through mobile phone system. If sent via electornic methods, notice shall be deemed served when your device or the used electronic system receives the message; if sent by courier, it shall be deemed served on the third day after sending out.

If you have any questions, comments, suggestions or doubts about this Privacy Policy or our products, please feel free to give us a feedback. Our contact:

  • E-mail address: digital@inlingua-edinburgh.co.uk
  • Mailing Address: inlingua Edinburgh, 40 Shandwick Place, EH2 4RT, Edinburgh, United Kingdom
  • Tel.: +44 (0) 131 220 5119

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This Agreement is updated on May, 2018.

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