ATOZ EDUCATIONAL SERVICES
DATA PROTECTION PRIVACY POLICY AND DATA SECURITY STATEMENT

Introduction

AtoZ Educational Services Ltd, a company registered in England & Wales under company number 10788418, with its registered office address at 20-22 Wenlock Road, London, N1 7GU (AtoZ) respects your privacy, whether you are an AtoZ website visitor, our customer,  our student, one of our customer’s children, clients or users, or simply an individual visiting our website, and we are committed to protecting your privacy through our compliance with this policy.

This Policy describes our practices in connection with information that we collect through our Website through any of our web-based applications and services (collectively, our “Applications”), as well as through HTMLformatted email messages that we send to you (collectively, including the Websites and the Applications, our “Services”).

By using the AtoZ website and any Services we offer, you are agreeing to be bound by this policy in respect of the information provided by you or collected about you.

This policy also applies to information about you that we collect or receive:

• In e-mail, text and other electronic messages between you and AtoZ.
• During any registration or otherwise on the AtoZ Website.
• When you interact with our marketing, promotions and applications on third-party websites and services.

It does not apply to information collected by any third party, including through any third-party application or content (including advertising) that may link to or be accessible from our Services.

Please read this policy carefully to understand our policies and practices regarding the collection of information about you, whether via our Websites, Applications, or from other sources, and how we will treat it.  If you do not agree with our policies and practices, you may choose not to use our Services.  Your continued use of our Website or Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Our Commitment 

We are strongly committed to the protection of your privacy online and accordingly; we take protective measures to protect the personal information provided to us by you. We also take further measures to comply with the relevant statement regarding what we can do with personal information we obtain from you.

You consent to our processing of your information. For a list of all your rights, please refer to the ICO website:
https://ico.org.uk/for–organisations/data–protection–reform/overview–of–the–gdpr/individuals–rights/

This Privacy Policy is not intended to, and does not, create any contractual or other legal rights or obligations on either your or our part.

General

In order to assist us you may provide us with information from time to time which we may require or use for the purposes of providing you with any required services, information or requested activity including contacting you and providing notification to you in relation to such services or related activity.

We may provide the data collected from you to other third party including our agents and contractors in connection with the service.

The registration information you provide may be required to use the Service or Website. We will store this information and data and use it to contact you, provide you with further details of the services and otherwise for the normal use, provision of services and improvement of the Website, unless you ask us not to do so.

The information may be disclosed to third parties to enable you to gain access to any restricted part of the Website, enable you to receive information which you have requested to be sent to you by post or for you to receive specified services.

We may use cookies to store and track information about you.

We are taking and will endeavour to continue taking all reasonable steps in order to protect your personal information and data. However, we cannot guarantee the security of any personal information or data you disclose online, having regard to the nature of the internet.

We may in certain cases use encryption technology from time to time to assist in protecting any information or data which you submit. In any event, you accept the inherent security implications of disclosing information over the internet and agree not to hold us responsible for any breach of security unless we have been negligent or wilfully in default of our obligations under the relevant legislation.

At any time, if you are concerned that the information, we hold about you is incorrect, please do not hesitate to contact us to correct such information.

We reserve the right to change this policy at any time by posting revisions on our Website.

Information We Collect and How We Collect It

AtoZ may collect several types of information from, including:

• “Personal Information” that identifies an end-user as an individual or relates to an identifiable person. For example, this includes name, organisation, title, postal address, e-mail address, telephone number, fax number, social media account ID or other identifiers by which end-users may be contacted online or offline.
• “Other Information” that does not reveal a person’s identity or directly relate to an individual, on its own or in combination with other information we have collected, such as browser and device information, app usage data, information collected through cookies, pixel tags and other technologies, general geographic location, demographic information and other information provided by a person, such as certain preferences, interests, activities, age, gender, education and occupation.

AtoZ may also collect personal information and other information from customers and Website visitors.  In some instances, we may combine other information with personal information (such as combining a Website visitor’s name with information we gather about this individual’s use of the Websites).  If we combine any other information with personal information, the combined information will be treated by us as personal information as long as it is combined.

We Collect This Information:

• Directly from individuals when they provide it to us.
• Automatically from end-users as they use the Applications, or from Website visitors as they navigate through the Websites, using technologies described in the section below titled “Third Party Advertisers and Analytics.” Information collected automatically may include browser and device information, details regarding use of the Services, IP addresses and information collected through cookies, web beacons and other technologies.
• From third party sources, such as public databases, joint marketing partners, and social media platforms. For example, if a Website visitor elects to connect his social media account to his account for our Websites, certain personal information from the social media account may be shared with us, which may include personal information that is part of the Visitor’s profile or his friends’ profiles.

 

Information Provided to Us

The information we collect through our Services and Website may include:

• Information that a person provides when utilising one of our Services or the Website, for instance at the time an end-user subscribes to or registers for a marketing email mailing list, registers to attend an event being organised by AtoZ, uses a web chat function with our tutor team, submits a request for proposal to AtoZ, or registers for a mailing list.
• Information that Website visitors provide by filling in forms on our Website. This includes information provided at the time of registering to receive tutorship for a student or their child, attend online demos, or access other special content on our Website. We may also ask customers or Website visitors for information when they enter a contest or promotion sponsored by us.
• Information that customers and end-users provide when receiving technical or customer account support. This includes records and copies of customer and end-user correspondence (including e-mail addresses).
• Responses to surveys that we might ask customers, end-users or Website visitors to complete for research purposes.
• Details of transactions that customers carry out through our Applications and of the fulfilment of customer orders.
• Records of search queries on our Services or Website.

Some parts of our Website may now or in the future allow visitors to create or post content on message boards, chat, profile pages and blogs and other services to which visitors are able to post information and materials.  Please note that any information posted or disclosed through these sections of our Website will become public information, and may be available to other Website visitors and to the general public.  We urge caution to anyone deciding to disclose their personal information, or any other information, on our Website.

Anyone submitting personal information relating to other people to AtoZ in connection with the Services or the Website represents that they have the authority to do so and to permit us to use the information in accordance with this policy.

 

How We Use Information

We will never sell your Personal Information to any third party!

We may use information that we collect or that is provided to us, including personal information, for any of the following purposes:

• To present our Services and their contents.
• To provide end-users with information, products, or services they request from AtoZ or our customers using our Applications, for example by processing event registrations, or enrolling end-users in mailing lists or programs in which they choose to participate
• To manage Application accounts and provide customer service.
• To provide Customers with notices about their AtoZ accounts, including expiration and renewal notices.
• To notify customers and end-users about changes to our Services, any products or services we offer or provide though our Services, our terms and conditions applicable to the Services, or this policy.
• To communicate with customers and visitors by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest and that are offered by us, our affiliated companies or other third parties.
• To allow customers and visitors to participate in online product demos, surveys, and online sweepstakes or contests (including to verify participant eligibility and deliver prizes), access and download materials, and use other interactive features on our Services.
• To better tailor the Website experience to Visitors interests, Application experience to end-user or customer interests, and display content according to user preferences.
• To facilitate social sharing functionality.
• To perform research and analyse use of, or interest in, our products, services or content (or products, services or content offered by others on our Website).
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
• As we believe to be necessary or appropriate:
  1. under applicable law, including laws outside your country of residence; o (b) to comply with legal process;
  2. to respond to requests from public and government authorities including public and government authorities outside your country of residence;
  3. to carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes;
  4. to protect our operations or those of any of our affiliates;
  5. to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others;
  6. to allow us to pursue available remedies or limit the damages that we may sustain; and
  7. to protect against or identify fraudulent transactions.  This includes exchanging information with other companies and organisations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
• In any other way we may describe when you provide the information.
• To fulfil any other purpose for which you provide it or with your consent.

We may also use contact information of customers and visitors to contact them via email, telephone or direct mail about products and services that may be of interest to them.  Where required, we will seek and obtain recipient’s express authorisation before we send marketing emails.  If you do not want us to use your information in this way, please adjust your email preferences that is accessible by clicking the unsubscribe link provided at the bottom of emails you receive from us.

 

Third Party Sub-processors and Service Providers

AtoZ may use certain third parties to help with the business administration and other activities related to the services provided. Some of these third parties may be based in the European Economic Area (“EEA”) and some are based outside the EEA.

We may transfer, store, use and process your information, including any personal information, to countries outside of the EEA. By using the AtoZ Website and/or Applications, you expressly consent to transferring your data to these countries. Please note that laws vary from jurisdiction to jurisdiction, and so laws and regulations relating to privacy and data disclosure, applicable to the places where your information is transferred to or stored, used or processed in, may be different from the laws and regulations applicable to the place where you are resident.

If the visitor, user or customer is located in the EEA, by using AtoZ’s Website or Services they expressly consent to the transfer of their personal data to the servers of AtoZ’s third party service providers. In particular, AtoZ’s third party service providers that may keep personal data with servers not located in the EEA will be notified to you on the Website or on amendment of this policy.

 

Disclosure of Your Information

We may disclose, use or publish aggregated information about users of our Services, non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes and information that does not identify any individual, without restriction.

If you choose to use our Website or Services to transact business with us or customers, any information you provide in connection with that transaction will be transferred to, and under the control of, the customer.  Customers may also have access to information (including personal information and Application usage data) related to how end-users interact with the Applications.  Although our own use and disclosure of your information will be in compliance with this policy, AtoZ cannot and does not take responsibility for the privacy practices of customers.

IMPORTANT: When you use our Website, our Services or Applications, your data may be sent to other countries in accordance with this policy.

We may disclose personal information that we collect or you provide as described in this policy:

• To our subsidiaries and affiliates for the purposes described in this policy.
• To contractors, service providers and other third parties as reasonably necessary or prudent to provide, maintain and support our Services.
• To a third party in the event of a merger, divestiture, restructuring, reorganisation, bankruptcy or insolvency event, dissolution sale of assets or other sale or transfer of some or all of AtoZ’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by AtoZ about our Website visitors, customers and end-users is among the assets transferred.
• To fulfil the purpose for which information is provided. (For example: If end-users provide an email address when registering for an event or subscribing to a mailing list, customers will use the email address to send the end-user information and announcements relating to that event or mailing).

You acknowledge, consent and agree that AtoZ may access, preserve and disclose your personal information pursuant to this policy if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary.  As we believe to be necessary or appropriate:

1. under applicable law, including laws outside your country of residence;
2. to comply with any legal process, investigation or proceedings, including legal process associated with national security and law enforcement;
3. to respond to requests from public and government authorities including public and government authorities outside your country of residence;
4. to carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes or enforcement of our agreements with our users;
5. to protect our operations or those of any of our affiliates;
6. to protect our rights, privacy, safety or property, and/or that of our affiliates, our customers, you or others;
7. to respond to claims asserted against AtoZ;
8. customer support, investigation, product development and de-bugging purposes;
9. to protect the rights, property or personal safety of AtoZ, its users or members of the public and
10. to allow us to pursue available remedies or limit the damages that we may sustain. This includes exchanging information with other companies and organisations where reasonably necessary for the purposes of fraud protection, risk assessment and credit risk reduction.

We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:

• providing notice is prohibited by the legal process itself, by court order we receive or by applicable law; or
• we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon AtoZ’s property, its platform, application or Services.

In instances where AtoZ complies with legal requests for user data without notice to the user for the reasons described above, AtoZ will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios (as indicated above)  apply.

For any other purpose disclosed by us when you provide the information or with your consent.

 

Third Party Services

This policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any non-customer third party operating any site or service to which the Services or Website link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

These other websites or third parties may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites or third party service providers that you visit.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other non-customer organisations, such as Facebook, Apple, Google, Microsoft, BlackBerry, or any other company, including app developers, app providers, social media platform providers, operating system providers, wireless service providers or device manufacturers, including any Personal Information you disclose to other organisations through or in connection with the Applications.

 

Cookies and Similar Technologies

We and our service providers may collect information about Website visitors’ online activities over time and across our Websites, third-party websites or other online services, and we may collect similar information about the online activities of customers and end-users within our Applications.  As you navigate through and interact with our Websites and Applications, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Services, such as the date and time you access our Services, length of time you spend on our Services, websites you visited before or after our Services, the resources and content that you access and use on the Services, and whether your interaction with our Services results in your requesting information about AtoZ or making a purchase.
• Information about your computer and internet connection, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, language, Internet browser type and version and the name and version of the Services (such as the Application) you are using. The technologies we use for this automatic data collection may include:
• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting you may be unable to access or receive certain parts of our Services.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites or receive our Services.
• Session Cookies and Persistent Cookies. A “session” cookie lasts for a single browser session only and is deleted when the user closes the web browser.  A “persistent” cookie remains on the user’s device (even while powered off) until it expires or is deleted.  A persistent cookie will be reactivated when a user returns to the website which posted the cookie. Cookies cannot read or access other cookies or any data from a user’s hard drive.  Cookies alone will not personally identify a user, however a cookie may recognize a user’s individual web browser or device through an IP Address, browser version, operating system and other information, and end users of our Services who log in to their AtoZ accounts may be individually identifiable to particular Services using session cookies.
• Web Beacons. Pages on our Services and our e-mails may now or in the future contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs).  Web beacons differ from cookies in that the information is not stored on your hard drive, but invisibly embedded on web pages or in email.  Web beacons permit us to track online movements of web users — for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).  This enables AtoZ to provide a website experience more tailored to your preferences and interests.

You can learn about how you can adjust your browser’s settings to limit or disable cookies and other tracking technologies by visiting the section below titled “Choices about How We Use and Disclose Your Information.”

 

Advertising and Analytics

When you access and use the Services and other websites, we may serve you advertisements regarding goods and services that may be of interest to you (or in some cases, to users who our service providers deem to have characteristics similar to our customers) based on information relating to your access to and use of the Services and other websites.  To do so, we or our service providers may place or recognize a unique cookie on your browser (alone or in conjunction with web beacons, pixel tags or other tracking technologies).

We may use third party analytics providers, including Quantcast, Google and others, to collect information about your use of the Services and enable us to improve how the Services work.  The information allows us to see the overall patterns of usage on the Services, helps us record any difficulties you have with the Services, shows us whether our advertising is effective or not, and allows us to use responses to advertisements to optimise ad performance.  Google Analytics, Adobe and Mixpanel use cookies and other, similar technologies to collect information about the Services use and to report website trends to us, without identifying individual end-users or Visitors to us.  See below for more information, or to opt out of these practices:

You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

You may opt-out of Quantcast interest-based content and advertisements by clicking on the Quantcast “Opt Out” link at https://www.quantcast.com/company/opt-out.

 

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us.  We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You may set your web browser to restrict or to entirely block cookies, to configure cookie notification settings and/or to delete cookies already present on the browser or device.  Information on how to do this should be provided in the web browser’s help/reference section.  Visitors who block cookies may be able to access a Website but will not be able to use some of the content, applications and services available on that site.  Limiting or restricting certain types of cookies may also prevent a customer or end-user from using certain portions of the Applications, depending on how the browser settings are configured.  For example, emails cannot be tracked or secure areas cannot be accessed.
• Promotional Offers from AtoZ. If you do not wish for AtoZ to use your email address to send you promotional messages, or would like us to prevent a customer from using the Applications to send you emails to promote its own or third parties’ products or services, you can:
  1. opt-out by checking the relevant box located on the form on which your data is collected (or, in some jurisdictions, by failing to opt-in),
  2. adjust your email preferences on the profile page which is accessible by clicking the unsubscribe link provided at the bottom of emails you receive from us (or from our Customer), or
  3. at any other time by sending an email stating your  request to abuse@atozeducationalservices.com or info@atozeducationalservices.com.  We will try to comply with your request(s) as soon as reasonably practicable.Please also note that if you, as a Website wisitor or customer, opt-out of receiving marketing-related emails from us (or as an end-user opt-out of receiving marketing-related emails from one of our customers), we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

 

Accessing and Correcting Your Information

If you are a registered user of one of our Services, you can review and change your personal information and/or email marketing preferences by logging into the Services and visiting your preference page.  For example, users may update or correct their personal information, other profile settings and user preferences in any registered profile.

You may also send us an e-mail at admin@atozeducationalservices.com or to info@atozeducationalservices.com to request access to, correct or delete any personal information that you have provided to us.

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information that you have provided to us.

For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.  There may also be residual information that will remain within our databases and other records, which will not be removed.

For a list of all your rights, please refer to the ICO website: https://ico.org.uk/for-organisations/dataprotection-reform/overview-of-the-gdpr/individuals-rights/

 

Children Under the Age of eighteen (18)

Our Services on the Websites are not intended for children under eighteen (18) years of age.  We do not knowingly collect personal information directly from children under eighteen (18), but do so from their parent or guardian in connection with our tutoring services.  If you are under eighteen (18), do not directly:

1. use or provide any information on these Services or on or through any of its features,
2. register to use any of our Services,
3. make any purchases through our Services,
4. use any of the interactive or public comment features of our Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.

If you believe we might have directly obtained any information from or about a child under eighteen (18), please contact us using one of the means provided below (see Contact Information).

Privacy Concerns 

You can also report Privacy Right concerns to the ICO here: https://ico.org.uk/concerns/

 

Cross-Border Transfer

The Website and Services are controlled and operated by us from the United Kingdom, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United Kingdom.

Your personal information may be accessed by AtoZ personnel providing Services in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United Kingdom, which may have different data protection rules than those of your country.

 

Data Security

We seek to use reasonable organisational, technical and administrative measures to protect Personal Information within our organisation.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Information” section below.

Please see our Security Policy. 

Data Security Policy

We control physical security in relation to the information and personal data that is contained at our facilities and restrict access to the site, buildings, computer rooms, office desk, technology areas, equipment and other facilities where unauthorised access by people could compromise our security.

All proprietary or confidential information, including personal data, is contained or stored on computer and any that is contained and stored on manual files is locked up and secure.

We control access to information and personal data, including existing procedures for authorising and authenticating users as well as software controls for restricting access and techniques for protecting data such as encryption.

We maintain a business continuity plan as a contingency plan which identifies our business functions and assets (including personal data) which would need to be maintained in the event of disaster and set out the procedures for protecting and restoring them if necessary.

In respect of detection and investigation of breaches where they occur, we have in place relevant controls which should alert us to a breach in security. We endeavour to investigate every breach of security.

AtoZ cannot guarantee the security of any personal information or data disclosed to it or collected by it.

Retention Period

We will retain your personal information for the period reasonably necessary to fulfil the purposes outlined in this policy unless a longer retention period is required or permitted by law.

Changes to Our Policy

We may change this policy from time to time.  Please take a look at the “Last Modified or Updated” section at the top of this page to see when this policy was last revised.

Any changes to this policy will become effective when we post the revised policy on the Services or Website.

Your use of the Services and Website following these changes means that you accept the revised Policy.