DATA PRIVACY

STATEMENT

1. Introduction

Thanks for choosing Brightwings!

Our privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, use and transfer your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data. That is our objective, and this Privacy Policy (“Privacy Policy”) will explain how Brightwings Education, our subsidiaries and affiliates collect, share, and use your personal information. Brightwings Education Limited (which may be referred to in this document as ‘we’, ‘ourselves’, ‘us’ and ‘our’) has ownership of this website and its various functions, and also trades as “Brightwings Education”, “Brightwings Malaysia” and “Brightwings”. Through the access and usage of Brightwings.co.uk, including when referred to as the ‘website’ or ‘site’, you are in agreement with this Privacy Policy and the various aspects that are listed within. Please read this Privacy Policy carefully to understand your rights. We welcome you to contact our team if you require more information or have any queries.

 

2. Important information

a. To assist you further in understanding this Privacy Policy, we have set out in Part 5 of Schedule 1 an appendix of terms used, different types of personal information we collect, how we use this information, the legal basis for processing such information and further specifics in relation to your rights.

b. The controller of your personal information is the Brightwings entity in the country in which you use our Services.

c. If you have any queries about this Privacy Policy, or any wishes to exercise your information protection rights, please contact us by email to info@brightwings.co.uk (all jurisdictions) or if you are using our services in the UK, you can also write to us by post to The Controller, Brightwings Education Limited, 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom. We will get back to you as soon as possible.

d. You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, like the opportunity to deal with your concerns before you contact the ICO so we encourage you to contact us first and we will look to resolve the matter.

e. Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.

f. All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

g. All content of this website is the property right of Brightwings Education Limited. Our website may have links to third-party websites, plug-ins and apps. By connecting or clicking on these links please be aware that you may be allowing third parties to share or gather your personal information. We do not have any control over these third-party websites, plug in or apps and we will not be responsible for their privacy policies – please make sure to read their privacy policies to recognise what personal information they collect about you and the way in which this information is used.

3. Your responsibility to inform us of updates

a. It is imperative that the information we have about you is correct and up to date, please ensure we are aware of any changes to your personal information.

 

4. The information we collect about you

a. Part 1 of Schedule 1 provides you with the types of personal information we are likely to collect, use, store and transfer.

b. We also gather, store, use and transfer aggregated information. However, if we combine aggregated information with your personal information so that it can directly or indirectly identify you, we treat this as your personal information.

c. We do not collect any special classes of personal information.

 

5. Failure to provide personal information

a. If we are required by regulation, or under the terms of an agreement we have with you, to collect your personal information and you fail to provide the required information, we may not be able to enter into the agreement with you and therefore we may have to terminate a product or service. We will notify you of this at the appropriate time.

 

6. How personal information is collected

a.  When you visit the site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the site, and information about how you interact with the site. We refer to this automatically-collected information as “Device Information.”

b. We collect Device Information using the following technologies:

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

  • “Log files” track actions occurring on the site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the site.

c.  Additionally, when you make a purchase or attempt to make a purchase through the site, we may collect certain information from you, including your name, billing address, shipping address, payment information (including credit/credit card, PayPal and other payment options), email address, and phone number. We refer to this information as “Order Information.”

d. When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

 

7. How we use your personal information

a. We will only use your personal information where there is a lawful basis to do so. Usually, we will use your personal information:

i. to achieve the agreement, we are to enter into or have entered into with you;

ii. to ensure we are complying with a legal requirement; and

iii. where it is essential to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

b. Part 2 of Schedule 1 sets out the legal basis we will rely on to process your personal information.

c. We usually only rely on consent as the legal basis for processing your personal information to send email and other social media marketing material and you have the right to remove your consent at any time by getting in touch with us. Please be aware that we may process your personal information for more than one lawful basis depending on the precise purpose for which we are using your information.

 

8. Marketing

a. From time to time, we may examine your personal information to ascertain what products and or services we think may be of interest to you. You will only receive marketing messages from us, if you have requested information from us or purchased services from us, if you provided consent to marketing at the time we collected your personal information and you have not since opted out or removed your consent or if we have another basis to send you the marketing communications.

b. We will not share any of your personal information with other parties for marketing reasons. We do not sell any customer lists, accept advertising or profit from any third-party revenue based on the information gathered on this website.

 

9. How to opt-out /remove consent

a. You can remove your consent from receiving marketing emails by clicking the unsubscribe button within the specific marketing message. You can also remove your consent to marketing at any time by contacting us via email (info@brightwings.co.uk) or via our 'Contact Us' page on our website.

b. Even if you remove your consent from receiving marketing messages, we may still use your personal information for other purposes as long as we have a legal grounding to do so.

 

10. Change of purpose

a. Your personal information will only be used for the reason it was initially collected for. We will only use your personal information for another reason if that reason is connected to the initial reason.

b. If use of your personal information is required for an unconnected reason, we will inform you and will explain the lawful basis which allows us to use your personal information in this way.

c. Where this is required or allowed by law, we may process your personal information without your knowledge or consent.

 

11. Disclosure of your personal information

a. We may have to share your personal information with third parties, more details on this can be found in Part 4 of Schedule 1. All third parties are required treat your personal information in accordance with data protection regulations and to respect the security of your personal information. Third party service providers are not authorised to use your personal information for their own aims. Your personal information can only be processed within the specific instructions and for the specified reasons that we prescribe.

 

12. International transfers

a. When sharing your data with third parties as specified in Part 4 of Schedule 1, we may transfer your data outside the European Union (EU).

b. Brightwings Education may share your personal data globally with other companies in the Brightwings Education Group in order to carry out the activities specified in this Policy. This currently includes the Brightwings Education entity in Malaysia.

c. We may work with intermediaries based outside the EU, therefore their processing of your personal data will involve a transfer of data outside the EU.

d. In these circumstances, we will ensure your data is protected by ensuring at least one of the following safety mechanisms is in place:

i. Our personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;

ii. We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe with our services providers;

iii. We may transfer data to US based service providers under the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

e. Please contact us if you require further information on the specific methods used by us in situations where your personal data out of the EU.

 

13. Information security

a. Your personal data is held in the highest regard and we do our utmost to ensure it is kept secure. Nonetheless, please note that no security system, however advanced, can provide guaranteed safety all of the time. Brightwings Education is dedicated to protecting and securing your personal data, but we are unable to fully promise or license our server security. Also, there may be unfortunate instances where personal data that you provide on this website is seized during Internet communications. We adhere to the qualified industry standards to always protect the personal data.

b. Brightwings Education personnel, agents, contractors and other third parties will only be allowed access to your personal information if they require access in order to perform their core business function – we will take steps to limit access to those that do not require access to your personal information. Those accessing your personal information will be subject to a duty of confidentiality.

c. We have procedures in place to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

14. Information retention

a. Brightwings Education will only store your personal information for as long as necessary to fulfil the purposes we collected your personal information for. This includes for the purposes of fulfilling our legal, accounting, or reporting requirements.

b. Details of retention periods for different aspects of your personal information are available in our retention policy which you can request from us. However, we are legally obligated to keep rudimentary information about our customers (including contact, identity, financial and transaction information) for six years after our business relationship ends, for tax reasons.

c. We may also anonymise your personal information (so that it can no longer be linked to you) for research or statistical purposes. We can use anonymised information indeterminately without further notice to you.

 

15. Children

a. We do not knowingly collect information which relates to children under the age of thirteen (13) and our website is not intended for children. We encourage parents and legal guardians to monitor their children’s internet usage. However, in some countries, stricter age limits may apply under local law.

b. We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the website, and do not provide any personal data to us.

c. If we offer online services directly to children over the age of 13, we only seek consent if we have age-verification measures (and parental-consent measures) in place.

d. We do not knowingly collect information which relates to children under the age of thirteen (13) and our website is not intended for children. We encourage parents and legal guardians to monitor their children's internet usage.

e. If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data.

 

16. Your legal rights

a. You have certain rights in certain situations under data protection law. These are set out in full in Part 3 of Schedule 1. Please contact our us if you wish to exercise any of your legal rights.

b. You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.

c. We may request specific information from you to help us confirm your identity when you contact us. This is a security measure to ensure that personal information is not disclosed to any person who does not have the right to receive it.

d. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

17. Changes to this Privacy Policy

a.   Brightwings Education Limited has the right to amend this Privacy Policy when it is legally required or when we believe it is essential. If and when any changes or updates are made on this Privacy Policy, it will be posted on our website. We may notify you in advance and we therefore recommend you read any such notice carefully.

Schedule 1

Part 1: Categories of personal information

Part 2: Lawful base for processing and processing activities

The lawful basis upon which we may rely on to process your personal information are:

Set out below are specific details of the processing activities we undertake with your personal information and the lawful basis for doing this.

Part 3: Your legal rights

 You have the following legal rights in relation to your personal information:

Part 4: Third Parties

Part 5: Appendix

 

Thank you for reading our Privacy Policy.

 

Kind regards,

Brightwings Education Limited

Policy last reviewed: 25 April 2019

 

Copyright 2019 © Brightwings Education Limited, trading as Brightwings Education, registered in England and Wales at 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX

Company Registration No: 11338610

VAT Registration No: 296 2160 89

 

Copyright 2019 © Brightwings Malaysia Sdn. Bhd., trading as Brightwings Education, registered in Malaysia at Block C-18-01, Suite R, 289 The Scott Garden Soho, Jalan Klang Lama, 58000 Kuala Lumpur

Company Registration No: 1276663-W