Last updated: May 2023
Epiphany Language Studio Limited is a company incorporated and registered in England and Wales under company number 12241137 with its offices at First Floor, 17-19 Foley Street, London, England, W1W 6DW (“English with Lucy”, “we”, “us”, “our”), and we operate the following websites (together, the “Platform”):
- englishwithlucy.teachable.com (the “Teachable Website”)
Additionally, English with Lucy hosts an online community page on CircleCo, Inc.’s community platform, which can be accessed here: https://community.englishwithlucy.co.uk/ (the “Community Page”).
The Platform and the Community Page allows its users (“User”, “you”, “your”) to:
- access and download educational resources and materials
- view, access and purchase online lessons and courses
- sign-up to mailing lists
- interact with other Users and teachers, provide feedback on the Services and submit homework
As part of delivering our Services and operating our Platform, we may, from time to time, process certain personal data which relates to Users.
We are committed to protecting and respecting your privacy. This Privacy Notice explains the basis on which personal data we collect from you will be processed by us or on our behalf.
Where we decide the purpose or means for which your personal data is processed, we are the ‘controller’ of your personal data.
We may make changes to this Privacy Notice in future, which will be posted on this page. Where appropriate, we will notify you of changes via email.
If you have any questions or comments about this Privacy Notice, please contact us at: [email protected]
- INFORMATION WE MAY COLLECT ABOUT YOU
We may collect and process the following information, which may include your personal data.
|Account Information: We require certain information from Users when they purchase online lessons and courses via the Platform. This includes: [full name, email address, profile picture and information relating to course and lesson attendance].|
|Order Information: We require certain information from Users when they sign up to, or order, lessons and courses via the Platform. This includes: full name, email address, billing address and payment information.|
|Enquiry Information: If a User submits a general enquiry via our Platform, or via third party platforms and service providers (such as Teachable and ConvertKit), we may process certain information about them. This includes: full name, email address and any other information they choose to provide us in the message text.|
|Analytics Information: We collect certain information about the device which Users use to access the Platform. This includes: operating system, application version, resolution, language, time zone and IP address.|
|Marketing Information: We offer certain subscription services for Users to sign up to via an online form on our Platform. When providing this type of service, we may process the following information about Users: full name and email address.|
|Comments Information: We allow users to comment on certain content which is uploaded to the Teachable Website, and these comments are then published on the Teachable Website and therefore are publicly available to other Users of the Teachable Website to view. In order to enable this functionality, we may process the following information about Users: first name, photo, country of residence, email address and any other information they choose to provide us in the message text. Comments Information will be publicly available to certain Users on our Platform.|
|Feedback Information: When collecting feedback on the Services, we collect certain information relating to Users via third party platforms and service providers (such as Boast and Google Forms). This information includes: full name, photo, country of residence, email address, survey responses, testimonials and any other information they choose to provide us.|
|Community Page Information: If a User uses our Community Page, we may process certain information about them. This includes: username, reactions to content published on the Community Page, livestreams of online lessons and courses (and screenshots of such livestreams), homework submitted via the Community Page and any other information they choose to publish on the Community Page (including messages, photos and videos).|
- WHY WE COLLECT INFORMATION ABOUT YOU
|To provide our Platform and Services to UsersWe may use Account Information, Order Information, Enquiry Information, Community Page Information and Comments Information to deliver Services to Users as per the terms agreed between us. The processing of information in this way is necessary for us to understand how best we can support Users via the provision of our Services, communicate with Users and deliver our Services to Users.This processing is also necessary for us to pursue our legitimate interests of: (i) improving the quality of our Services; and (ii) promoting English with Lucy’s commercial interests. We will retain this information for these purposes for 6 years from the date of your last activity on the Platform. Legal basis under GDPR: performance of contract and legitimate interests (listed above).|
|To manage our relationship with Users We may process Account Information, Order Information, Enquiry Information, Comments Information, Community Page Information and Feedback Information so that we are able to properly respond to questions, enquiries, complaints and support requests from Users. This processing is also necessary for us to pursue our legitimate interests of: (i) ensuring that we address any concerns or queries regarding our Services or Platform; (ii) correcting any issues experienced in relation to our Services or Platform; and (iii) improving the quality of our Services. We will retain this information for these purposes for 6 years from the date of your last activity on the Platform. Legal basis under GDPR: legitimate interests (listed above).|
|To maintain and improve our PlatformWe may process Enquiry Information, Feedback Information, Community Page Information and Analytics Information so that we can analyse Users’ use of our Platform, and understand and resolve any issues relating to our Platform. This may include sending information relating to any crashes or similar issues Users experience to a third party for further investigation. This processing is necessary for us to pursue our legitimate interests of: (i) ensuring that our Platform functions properly so that Users and other users have the best experience when using it; (ii) improving the quality and delivery of the Website and Services, and the experience of Users when using the Website and Services; and (iii) identifying and correcting any bugs on our Platform. We will retain this information for these purposes for 6 years from the date of collection. Legal basis under GDPR: legitimate interests (listed above).|
|To market the Platform and the Services, and inform Users about updates relating to the Platform and the Services, and other services that may be of interest to themWhere Users have consented, or where it is otherwise lawful for us to do so, we may use Marketing Information and Feedback Information to: (i) publish testimonials of the Platform and the Services; or (ii) send Users emails to keep them informed about our news, updates, latest projects, sponsored opportunities and partnerships which may interest them. Where we rely upon their consent to do this, Users can withdraw their consent at any time by clicking the “unsubscribe” link at the bottom of any of our emails.We will retain Marketing Information for these purposes until you have unsubscribed from marketing communications, or you have withdrawn your consent for your Marketing Information to be used for these purposes. We will retain Feedback Information for these purposes for 6 years from the date of collection. Legal basis under GDPR: consent.|
- DATA SHARING
|Information will only be shared between us and third parties in the ways that are described in this Privacy Notice|
|Personnel: We seek to keep your information confidential but may disclose it to our personnel insofar as it is reasonably necessary for the purposes set out in this Privacy Notice.|
|Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via a prominent notice on our Platform of any change in ownership or uses of this information, as well as any choices you may have regarding this information.|
|Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).|
|Enforcement: We may also disclose your personal data to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of English with Lucy, our customers, or others.|
|Third Party Suppliers: We use a range of suppliers to operate our business and provide our Services. Suppliers who may receive your personal data for the reasons set out in this Privacy Notice include:IT Service Providers: We use a range of other suppliers to provide our business infrastructure, including email service providers, software providers, web hosts, IT support consultants, and suppliers of security technology. Payment providers: Where you instigate a payment with us, your payment-related information will be processed by our payment providers.Marketing platform providers: We use other suppliers to assist our business with its marketing activities, pursuant to which we may share your personal data.Video communication platform providers: We use other suppliers to enable us to communicate with Users.Survey administration software providers: We use other suppliers for the purpose of generating and collecting your feedback on the Platform and the Services.|
- YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA WHICH WE PROCESS
You have the following rights over the way we process personal data relating to you, although each right is subject to certain qualifications, requirements and exemptions. You can contact us to make a request to exercise one of your rights (including by sending an email to [email protected]).
- Right to be informed: A right to be informed about the collection and use of your personal data (as explained in this Privacy Notice).
- Right to access and rectification: A right to ask for a copy of data we are processing about you and have inaccuracies corrected.
- Right to object, erasure and restrict processing: You can ask us to restrict, stop processing, or to delete your personal data.
- Right to data portability: A right to obtain a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer.
- Right to complain: You may make a complaint to a data protection regulator. Contact information for the Information Commissioner’s Office (the UK’s independent authority set up to uphold information rights) is available here: https://ico.org.uk/make-a-complaint/.
- DATA RETENTION
We will hold your personal data on our systems for as long as is necessary for the relevant purpose and to maintain business records for tax, legal and regulatory reasons, or as otherwise described in this Privacy Notice.
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 and regulatory requirements.
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 this information for research or statistical purposes.
We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal data. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
- INTERNATIONAL DATA TRANSFERS
Any personal data that we process in relation to you will be stored in the UK, the United States and/or Canada. Where we transfer your information outside of the UK, we will have agreements in place with the recipient which include standard data protection clauses adopted by the Information Commissioner’s Office to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by emailing [email protected].
It is possible that your personal data may be transferred outside of the UK by third parties, such as social media providers. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred internationally.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners and operators of the site. The table below explains the cookies we use and why.
|_ddu||Session||.englishwithlucy.com||This collects information about the users and their activity on the Platform, through embedded elements, for the purposes of analytics and reporting.|
|nitroCachedPage||Session||.englishwithlucy.com||This collects information about the users and their activity on the Platform, through embedded elements, for the purposes of site speed optimization.|
|FPLC||1 day||.englishwithlucy.com||This collects information about the users and their activity on the Platform, through embedded elements, for the purposes of analytics and reporting.|
Read more information provided by Google here.
|_fbp||3 months||.englishwithlucy.com||This is placed by Facebook for marketing and tracking purposes, and used to distinguish and keep track of unique Users. |
Read more information provided by Facebook here.
|_ga_0KL723T4XL||400 days||.englishwithlucy.com||This is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in the Platform and used to calculate visitor, session and campaign data for the Platform’s analytics reports. The cookie is updated every time data is sent to Google Analytics.|
Read more information provided by Google here.
|_ga||400 days||.englishwithlucy.com||This is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in the Platform and used to calculate visitor, session and campaign data for the Platform’s analytics reports. The cookie is updated every time data is sent to Google Analytics.|
Read more information provided by Google here.
|FPID||400 days||.englishwithlucy.com||This collects information about the users and their activity on the Platform through embedded elements for the purposes of analytics and reporting.|
Read more information provided by Google here.
We do not knowingly solicit data from, offer Services to or market to, children under the age of 16.
If you are under 16, or if a parent or guardian becomes aware that their child has provided us with information, please contact us at [email protected].
- CONTACT INFORMATION
If you have any questions about this Privacy Notice, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us by emailing us at [email protected].