- English Momentum, Inc.
- 406 Cambray Rd.
- Cambray, Ontario K0M 1E0
Effective Date: 26/02/2020
Policy Version: 1.9
‘Non-personal data’ (NPD) is information that is in no way personally identifiable. ‘Personal data’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.
A ‘visitor’ is someone who merely browses our website. A ‘member’ is someone who has registered with us to use or buy our services and products. The term ‘user’ is a collective identifier that refers to either a visitor or a member. A ‘customer’ is someone who has made a purchase. A ‘subscriber’ is someone who has an active subscription product. A ‘student’ is someone who is enrolled in an online course or takes Skype lessons.
Information We Collect
Generally you control the amount and type of information you provide to us when using our website.
Our Legal Basis for Collecting and Processing Personal Data
Our legal basis for collecting and processing your PD when you buy our products or services is based on the necessity of it to enter into a contract or to carry out our contract.
Our legal basis for collecting and processing your PD when you register for free membership, download free digital products, subscribe to podcasts, sign up for our newsletter and information about our products and services through our website opt-in forms is based on consent.
If You Don’t Give Us Your Personal Data
If you do not provide us with enough PD, we may not be able to provide you with all our products and services. However, you can access and use some parts of our website without giving us your PD.
We Collect Your PD in the Following Ways:
We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our website, if any, as well as the name of the website you’ll visit when you leave our website. This information also includes the IP address of your computer/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our website. Your IP address is anonymized before being sent to Google Analytics. We use all this information to analyze trends among our users to help improve our website.
When Entering Our Site
When you enter and use our website and agree to accept cookies, some of these cookies may contain your PD.
When you use our services, we may collect and process information about your actual physical location. We use IP tracking to determine your location. This is used to determine your time zone when booking a Skype lesson, or to present prices in your local currency.
At Member Registration
When you register for membership, we collect your name and email address to provide you with various features and/or functionality of our website. Once registered, you can login as a member. This gives you the ability to download free digital products from us; no other personal information is collected at that time.
When you use a social login, we collect only your public profile data which you granted to your social network before you ever initiated Social Login on this site. This data includes your first name, last name, email address, link to your social media profile, unique identifier, and the link to your social profile avatar. This data is used to create your user profile at our website.
Online forms are used on our website to register, login, sign up for the newsletter, comment on blog posts and podcast episodes, contact us, and make purchases. The information you enter into these online forms may contain PD.
When Buying Premium Features, Products, or Services
Our website may offer premium features for the use of which you must pay. If we were to charge you for the use of these premium features, we would need to collect payment source information (such as a credit card) to bill you for using such premium features.
If you buy products or services from us, we collect your name, email address, physical address, credit card information, phone number.
- Navigating our website
- Signing in and identifying you as a member or user of our website
- Allowing you to post comments
- Allowing you to share content with your social networks
- Remembering what you have put in your shopping cart
- Remembering your preferences and settings
- Our website analytics
- Identifying the areas of our website that you have visited
- Remarketing our products or services to you
- Targeted advertising
- Affiliate marketing
We may also use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us understand the behaviour of our customers, members, students, and visitors. Our web beacons are not used to track your activity outside our website.
Our website uses Google Analytics to collect information about the use of our site. Google Analytics collects information such as how often users visit our site, what pages they visit, and what other sites they used prior to coming to our site. We use the information we get from Google Analytics to improve our site. Google Analytics collects only an anonymized form of the IP address assigned to you on the date you visit our site, not your name or other identifying information. We do not combine the information collected through the use of Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our site, the cookie cannot be used by anyone but Google. For more information about how Google collects and processes your data, visit https://policies.google.com/technologies/partner-sites
You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. https://tools.google.com/dlpage/gaoptout
How Your Information Is Used
We use the information we receive from you as follows:
- Provide our products and services that you have requested or purchased
- Personalize and customize content
- Make improvements to our website
- Contact you with updates to our website
- Resolve problems and disputes
- Contact you with marketing and advertising that we believe may be of interest to you
Communications and emails
When we communicate with you about our website, we will use the email address you provided when registering as a member. We may also send you emails about your downloads, purchases, subscriptions, and reminders of scheduled Skype classes. You can change contact preferences at any time through your account or by contacting us.
If you have subscribed to our newsletter, you will receive email notification whenever new content is added to the site as well as promotional information about our website. You can opt out of the newsletter at any time by using the opt out link at the bottom of every newsletter.
Only logged in users can leave comments on the site. We collect the data shown in the comments form and associate this to the logged in user’s profile. We store comments indefinitely so that subsequent comments can be posted immediately and do not need to be held until approved by the moderator. We are only using default WordPress comments, so PD in comment metadata is not shared with any third-party service providers.
What we collect and store
When you purchase an online course from us, we’ll ask you to provide your email address. We will use this information to send you information about your account and order and to create your account on our Learning Management System (LMS). Even if you register in a free course, we will still store your email address. We store information about you for as long as your account exists. We store course progress, including completion status, quiz scores, assignments and/or essay submissions (if applicable). We will also store comments on courses, lessons, topics, assignments, and essays if you choose to leave them.
Who on our team has access
Members of our team have access to the information you provide us. For example, Administrators, the course Teacher and Group Leaders can access order information such as your enrolled courses, course progress and username/email address. Any additional information added in My Account/Account Details can also be visible to the administrator(s).
We collect information about you during the checkout process on our store.
What we collect and store
While you visit our site, we’ll track:
- Products you’ve viewed:
- (We’ll use this to, for example, show you your recently viewed products)
- Location, IP address and browser type:
- (We’ll use this for purposes like selecting a currency, estimating taxes and identifying your time zone for Skype class bookings)
When you purchase from us, we’ll ask you to provide information including your name, billing address, email address, phone number, credit card/payment details, your Skype username, and optional account information like notes about your order. We’ll use this information for purposes, such as, to:
- Send you information about your account and order
- Respond to your requests, including refunds and complaints
- Process payments and prevent fraud
- Set up your account for our store
- Comply with any legal obligations we have, such as calculating taxes
- Connect with you on Skype for one-on-one tutoring
- Improve our store offerings
- Send you marketing messages, if you choose to receive them via our newsletter
If you create an account during checkout or are already logged in as a member, we will store your name, address, email, Skype username, and phone number, which will be used to populate the checkout form for future orders.
We generally store information about you only for as long as we need the information to fulfill the purposes for which we collected it, and for as long as we are legally required to continue to keep it. For example, we will store subscription orders online for as long as the subscription is active, product reviews indefinitely, and order information offline for seven years for tax and accounting purposes. This includes your name, email address and billing address.
Who on our team has access
Members of our team have access to the information you provide us. For example, both Administrators and Shop Managers can access:
- Order information (like what was purchased, when, and subscription expiry date)
- Customer information (like your name, email address, and billing information)
Our team members have access to this information to help fulfill orders, process refunds and support you.
Use of Credit Cards
You may have to provide a credit card to buy products and services from our website. We use Stripe and PayPal as our third-party billing services. We collect your name, email address, billing address, phone number, and credit card details which we encrypt before it travels over the internet using industry-standard technology for conducting secure online transactions. For the purposes of processing recurring subscription payments, we store the customer’s name, billing address, email address, phone number, unique payment identifier, and payment provider identifier. The transaction is processed on PayPal or Stripe and your credit card number is not stored on our server. We use commercially reasonable efforts to make sure that your credit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorized use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number.
Sharing PD with Third Party Service Providers:
We may provide your PD to affiliates who provide services with regards to our website (such as payment processors and other service providers.)
We accept payments made from PayPal accounts. We also accept credit card and debit card payments through PayPal and Stripe. When processing payments, some of your data will be passed to the payment processor of your choice, PayPal or Stripe, including information required to process or support the payment, such as the purchase total and billing information.
Third-Party Data Transfer Between Online Services:
Customer information provided during the checkout process is sent to Zapier, a third-party service which transfers data between online apps. We use Zapier to transfer customer and transaction data into QuickBooks Online for accounting purposes.
Aggregate Data Analysis:
We do not sell, rent, or otherwise provide your PD to third parties for marketing purposes. However, we use services (Google Analytics, Facebook, Quickbooks Online) that aggregate data for the purpose of analysis and/or marketing. Any such data aggregation would not contain any of your PD. You can visit these pages (Google Analytics, Facebook, Quickbooks Online) to read their privacy policies.
Online Course Engagement:
Data collected by the LMS including information relating to your course progression and quiz performance is shared with third parties who help us provide our courses and services to you; for example – Google Analytics and Facebook Pixel for analytics and reporting that helps us understand engagement with the content that will help with course improvement as well as with marketing, MailChimp to contact you about your course progress and to inform you of future courses we believe may be of interest to you, PayPal and Stripe for processing payments and subscriptions, and gamification programs.
Your comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
Our social share buttons are provided by Heateor Team. They do not collect your PD, but to use the share buttons you need to be logged into the social platform. Each social platform may be collecting your PD according to their privacy policies.
Facebook and Messenger Share buttons
Twitter Tweet button
Reddit share button
Mix share button
Weibo share button
WhatsApp share button
Instagram share button
LINE share button
LINE QR Code and ‘Add Friend’ Badge
Third-party providers whose content has been linked to or embedded on this site may collect data about you.
Links to other websites
Embedded content from other websites
Blog posts and courses on this site may include embedded content (e.g., videos and podcast episodes). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
Security Against Malicious Attacks:
PD collected in Security Logs
The IP address of visitors, user ID of logged in users, and username of login attempts are conditionally logged to check for malicious activity and to protect the site from specific kinds of attacks. Examples of conditions when logging occurs include login attempts, log out requests, requests for suspicious URLs, changes to site content, and password updates. This information is retained for 30 days.
WPBruiser is an anti-spam and security plugin that protects the site from spam bots and Brute Force attacks. It is based on algorithms that identify spam bots without captcha images. WPBruiser is not saving any information about the user if the request is legit. In such cases where WPBruiser blocks a request, the IP Address is saved and kept in the site’s database for 30 days after which the IP is deleted. There is no sharing of data with WPBruiser.
Who we share your data with
Where we send your data
International Data Transfers:
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy. Personal information that you publish on our website or submit for publication on our website may be available via the Internet around the world. We cannot prevent the use or misuse of such information by others. You hereby agree to the transfers of personal information described within this section.
Legally required releases of information
We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal action or claims from third parties, including you and/or other members; (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.
Disclosures to Successors
Changing and Revoking Your Personal Information
Change your account settings
If you have registered on our website, we have stored the personal information you provided in your account. You can see, edit, or delete your personal information at any time (except you cannot change your username). Website administrators can also see and edit that information.
Change or revoke social media permissions
If you have registered and logged in through your social media account such as Facebook, Twitter, or GooglePlus, you can restrict or revoke this consent at any time by logging into your social media account privacy settings and changing your permissions. The next time you log into English Momentum, your social login will not work. Using the same email address, you will need to request a new password. Once your password is set, use the standard login form.
Do Not Track settings
Change and turn off tracking features in your browser. You can turn off tracking features and other security settings in your browser by visiting the following links:
- For Internet Explorer visit: https://www.englishmomentum.com/do-not-track-explorer11
- For Mozilla Firefox visit: https://www.englishmomentum.com/do-not-track-firefox
- For Google Chrome visit: https://www.englishmomentum.com/do-not-track-chrome
- For Safari visit: https://www.englishmomentum.com/do-not-track-safari
Retaining and Destroying Your Personal Information
We retain information we collect from you (including PD) for only as long as we need such information for legal, business, or tax purposes. Your information may be retained in electronic form, paper form, or a combination of both. When your information is no longer needed, we will destroy, delete, or erase it.
Requesting an export of your personal information
If you have an account on this site, you can log in and request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You must be logged in to submit this request from this link.
Requesting the erasure of your personal information
You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Protecting the Privacy Rights of Third Parties
If any postings you make to our website contain information about third parties, you need to make sure that you have permission to include them in your posting. While we are not legally liable for the actions of our users, we will remove any postings for which we are notified that such postings violate the privacy rights of others.
Protecting Youth’s Privacy
You must also be old enough to consent to the processing of your personal data in your country. (In some countries, we may allow your parent or guardian to give their consent on your behalf).
Our website and services are not directed to children, and you may not use our services if you are under the age of 13. However, we realize that a child may attempt to access our website. We do not knowingly collect PD from a child under the age of 13. If you are a parent or guardian and believe that your child or teenager under the age of majority has provided us with personal information without your consent, please contact us. We may ask for proof of identification before we remove any information to prevent malicious removal of account information. If we discover that a child is logging into our website, we will delete his/her information within a reasonable period of time.
Teenagers’ privacy (Canada):
In compliance with the Canadian Marketing Association’s Code of Ethics, we do not knowingly collect personal data from teenagers living in Canada and under the age of majority. If we discover that you are a young teenager living in Canada and using our services, we will contact you requesting your parent or guardian’s consent to collect your PD.
- If we learn that you are age 13-15, we will contact you requesting your parent or guardian’s consent to collect your contact information.
- If we learn that you are age 16 and making a purchase, we will request your parent or guardian’s consent to collect your personal data.
Teenagers’ privacy (China & South Korea):
If we discover that you are under the age of 14, living in China or South Korea, and using our services, we will contact you requesting your parent or guardian’s consent to collect your PD.
Teenagers’ privacy (Malaysia):
If we discover that you are under the age of 18, living in Malaysia, and using our services, we will contact you requesting your parent or guardian’s consent to collect your PD.
Our Email Policy
We comply with Canada’s federal CASL (Canadian Anti-Spam Law) and GDPR (General Data Protection Regulation). You can always opt out of receipt of further email correspondence from us or our affiliates by using the unsubscribe link provided at the bottom of every email. We will not sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business or if our company files for bankruptcy..
Our Security Policy
At English Momentum, we understand the importance of protecting your personal data. We have taken steps to build our website using industry-standard encryption and authentication tools to protect the security of your PD. When we collect your PD through our website, we will encrypt your PD before it travels over the Internet using industry-standard technology for conducting secure online transactions. We also use technologies such as secure routers and firewalls to protect your PD. Unfortunately we cannot fully guarantee secure data transmission over the Internet because of its nature.
Once we receive your PD, we have security measures in place to protect against the loss or misuse of your PD, though again we cannot fully guarantee against such loss or misuse. We strongly urge you to protect any password you may have for our website and not share it with anyone. You should always log out of our website when you finish using it, especially if you are sharing a computer with someone else or are using a computer in a public place.
Data Breach Procedures
If a data breach is suspected, it will be investigated, confirmed and reported to the Office of the Privacy Commissioner of Canada. All users whose PD has been compromised will be notified via the email address stored in users’ personal profiles within 72 hours of finding the breach. However, if it is only anonymized data that has been compromised, notification is not necessary. To contain the breach, the site will immediately be shut down. Before going back online, a technician will identify the point of entry and repair the site.
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