Native Speaker Data Privacy Summary
At Native Speaker , we take your privacy seriously. It is important that you know exactly what we do with personal information that you and others provide to us, why we gather it and what it means to you. This document is being provided to you in line with our obligations under the General Data Protection Regulation (GDPR), which will come into force on 25 May 2018. From that date, the GDPR, together with applicable Irish requirements, will amend existing data protection law and place enhanced accountability and transparency obligations on organisations when using your information. The GDPR will also introduce changes which will give you greater control over your personal information, including a right to object to processing of your personal information where that processing is carried out for our business purposes.
Please take time to read this notice carefully. If you are under 16 years of age, please read this summary with a parent or guardian and ensure you understand it. If you have any questions about how we use your information, please contact our Data Protection Officer at the details below.
This summary explains the most important aspects of how we use your information and what rights you have in relation to your personal information. You can get more detailed information by viewing our full Data Privacy Notice at www.nativespeaker.ie/privacy, in-office, by mail to Native Speaker, Native Speaker Ltd, Innovation Centre, IT Sligo, Ballinode, Sligo, Ireland or by phoning 071 9147728.
1. Who we are
Throughout this document, 'we', 'us', 'our' and 'ours' refer to Native Speaker Ltd. Your information is held by The Director and Company of Native Speaker Ltd. For more information about us, see our web-site Native Speaker.ie.
Your product or service terms and conditions will specify which of our courses is providing the relevant product or service to you. Some of our courses may have their own Data Privacy Notices. If you are a student on one of these courses, you should read the relevant Data Privacy Notice.
2. The information we collect about you
We will hold:
- data to identify you, including your contact information
- in some cases, your attendance to class which may be given to INIS (Irish Naturalisation and
Immigration Service) and or GNIB Garda National Immigration Bureau.
- any financial details/financial circumstances that you supplied to us in your application.
- your image - this may include your passport, and it could also include your image in marketing or
- your marital status - if you supplied it to us and it is relevant to your engagement in our course,
for example, in the event of accident or illness occurring in our premises, we would be able to
contact your spouse or next of kin.
- names of parents or guardians of students under 18.
- information about you provided by others e.g. academic references, exam results, academic performance, character reference, employer’s reference, Garda vetting, etc.
- information which you have consented to us using; and other personal information such as:
- criminal conviction
- telephone recordings
- CCTV images at our premises and information provided when exercising your rights
under Section 10 below.
-Sometimes we may use your information even though you are not our client. For example, you may be a beneficiary, guarantor, director, cardholder or representative of a client of ours or be a potential customer applying for one of our products or services. We undertake to treat this information with the necessary respect and confidentiality.
3. When we collect your information
- We collect information: - (i) you give us;
- (ii) information from your use of our products, services or our websites and any mobile apps;
- (iii) information provided to us by third parties, e.g. parents, agencies, government sponsoring agencies.
4. How we use your information and the legal basis
We use, and share, your data where:
- you have agreed or explicitly consented to the using of your data in a specific way (you may withdraw your consent at any time);
- use is necessary in relation to a service or a contract that you have entered into (e.g. to provide
you with language teaching services when you join a course) or because you have asked for something to be done so you can enter into a contract with us (e.g. you have asked us to provide you with a course offer or quote when you apply to us for a course);
- use is necessary because we have to comply with a legal obligation (e.g. complying with our “know your client” obligations and reporting to the regulatory authorities and law enforcement); use is necessary to protect your “vital interests” in exceptional circumstances;
use for our legitimate interests (which you may object to) such as adherence to INIS regulations, managing our business including providing service information, conducting marketing activities, training and quality assurance, academic management and strategic planning and the purchase or sale of services.
5. How we use automated processing or ‘analytics'
We may analyse your information using automated means to:
- help us understand your needs and develop our relationship with you;
- help us to offer you products and service information we believe will be of interest to you;
- make assessments where you apply for a learning product (e.g. an online course, a standard course, a translation service). We may make commercial or academic decisions based solely on an automated analysis of your information. The types and sources of the information we process by automated means about you are listed above in Sections 2 and 3.
We also use automated processing to assist in compliance with our legal obligations in connection with prevention of illegal immigration, money laundering, fraud and terrorist financing, for example, to screen for suspicious behaviour.
6. Who we share your information with
When providing our services to you, we may share your information with:
- your authorised representatives;third parties with whom: (i) we need to share your information
to facilitate transactions you have requested, and (ii) you ask us to share your information;
- service providers who provide us with support services;
- statutory and regulatory bodies (including central and local government) and law enforcement
- third parties in connection with a service provided by us: persons making an enquiry or complaint, GNIB, INIS, Third Level Institiutions, Language Schools, and equivalent in other jurisdictions.
- healthcare professionals and medical consultants;
- business or joint venture partners.
7. How long we hold your information
How long we hold your data for may in certain cases be subject to legislation and regulatory rules we must follow, set by authorities such as QQI, INIS and the type of course or service provided to you.
8. Implications of not providing information
If you do not provide information we may not be able to:
- provide requested products or services to you;
- continue to provide and/or renew existing courses or services
- assess suitability; and where relevant, give you a recommendation for a further course or service provided by us.
We will tell you when we ask for information which is not a contractual requirement or is not needed to comply with our legal obligations.
9. Using companies to process your information outside the European Economic Area (EEA)
In some cases, we may transfer information about you and your products and services with us to our service providers and other organisations outside the EEA. We will always take steps to ensure that any transfer of information outside of the EEA is carefully managed to protect your privacy rights. Full details of transfers can be ascertained by contacting the school.
10. How to exercise your information rights including the right to object
From 25 May 2018, you will have several enhanced rights in relation to how we use your information, including the right, without undue delay, to:
- find out if we use your information, access your information and receive copies of your information;
- have inaccurate/incomplete information corrected and updated;
- object to particular use of your personal data for our legitimate business interests or direct marketing purposes*;
- in certain circumstances, to have your information deleted or our use of your data restricted*;
- in certain circumstances, a right not to be subject to solely automated decisions and where we make such automated decisions, a right to have a person review the decision*;
- exercise the right to data portability (i.e. obtain a transferable copy of your information we hold to transfer to another provider)*; and
- to withdraw consent at any time where processing is based on consent.
*These rights will be available from 25 May 2018
If you wish to exercise any of your data rights, you can contact us at firstname.lastname@example.org, at our premises, by mail to Native Speaker Ltd, Innovation Centre, IT Sligo, Ballinode, Sligo, Ireland, or by contacting 071 9147728.
If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests) we may extend this period by a further two calendar months and shall explain the reason why. If you make your request electronically, we will try to provide you with the relevant information electronically.
You also have the right to complain to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner at:
Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231
Fax: +353 57 868 4757
Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois.
From 25 May 2018, you will have several enhanced rights in relation to how we use your information, including the right, without undue delay, to:
11. How to contact us and/or our Data Protection Officer
If you have questions about how we use your information, you can reach our Data Protection Officer at www.nativespeaker.ie/privacy, by mail at email@example.com or on 071 91 47728.
We will update our Data Privacy Notice from time to time. Any updates will be made available and, where appropriate, notified to you by, e-mail or when you log onto www.nativespeaker.ie.
13. Web-Site Usage
We don't ask you for personal information on our web-site, unless we truly need it.
We don't share your personal information with anyone except to comply with the law, develop our products, or protect our rights.
We don't store personal information on our servers unless required for the on-going operation of one of our services.
We aim to make it as simple as possible for you to control what's visible to the public, seen by search engines, kept private, and permanently deleted.
Native Speaker is a language school based in Sligo, Ireland. This is the privacy statement of Native Speaker for the purposes of complying with the Data Protection Acts and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations. By visiting the website, you are deemed to be on notice of, and to agree with, the manner in which we collect and process personal data which we receive via this website. If you do not agree with the manner in which we collect and process personal data, you should stop using this website now and not revisit. Native Speaker is committed to respecting the privacy rights of visitors of nativespeaker.ie (“the Site”)
Like most website operators, Native Speaker collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Native Speaker's purpose in collecting non-personally identifying information is to better understand how Native Speaker visitors use its website. From time to time, Native Speaker may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website. Native Speaker also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on Native Speaker websites. Native Speaker only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below, except that blog commenter IP addresses and email addresses are visible and disclosed to the administrators of the blog where the comment was left.
Gathering of Personally-Identifying Information
Certain visitors to Native Speaker's websites choose to interact with Native Speaker in ways that require Native Speaker to gather personally-identifying information. The amount and type of information that Native Speaker gathers depends on the nature of the interaction. For example, we ask visitors who send a contact mail to provide a name, phone and email address. This is for the
purpose of returning communication only to fulfil the purpose of the visitor's interaction with Native Speaker. Native Speaker does not disclose personally-identifying information other than as described below. Visitors can always refuse to supply personally-identifying information, though this may limit Native Speaker’s ability to fully address and respond to your communication.
Protection of Certain Personally-Identifying Information
Native Speaker discloses potentially personally-identifying information only to those of its employees, contractors and affiliated organizations that;
(i) need to know that information in order to process it on Native Speaker's behalf or to provide services available at Native Speaker's websites, and
(ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using Native Speaker's websites, you consent to the transfer of such information to them. Native Speaker will not knowingly rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, Native Speaker discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when Native Speaker believes in good faith that disclosure is reasonably necessary to protect the property or rights of Native Speaker, third parties or the public at large.
If you have supplied your email address to us, Native Speaker may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what's going on with Native Speaker and our products. We primarily use our various product blogs to communicate this type of information, so we expect to keep this type of email to a minimum. Native Speaker takes all measures reasonably necessary to protect against the unauthorized and damaging access, use, alteration or destruction of potentially personally-identifying and personally- identifying information.
Obtaining Copies of Your Data
If your right of access to the data which you have requested is not restricted by an exemption under the Data Protection Acts, and is correctly requested, we will supply a copy of any personal data relating to you which we have received from you via this website. We are entitled to destroy any personal data which you submit to us at our discretion and will do so for security and/or data minimisation reasons where appropriate. In the event that we have destroyed any personal data which you have supplied to us we will not have any obligation to supply you with copies of this destroyed data or verification of the destruction. We will endeavour to provide you with a personal data destruction date if available.
If you wish to obtain copies of any personal data which we hold, you must email us at firstname.lastname@example.org You should include any personal identifiers such as your name, address, phone number, e-mail address etc. For obvious data security reasons, we may require that you provide us with a valid photo identification to facilitate the access request. Indeed, we reserve the right to require, see and confirm photo identification before passing any personal data to a requestor.
If you make a request in respect of your personal data, we will try to comply with this request within thirty days of receiving it in writing.
Special categories of Personal Data
This is data that may reveal information about you such as data concerning health, religious or philosophical beliefs in order to assist tailoring our service to your specific requirements. Such information is only collected from you if you voluntarily submit it to us and we only keep as long as necessary to complete the business surrounding it.
If Native Speaker, or substantially all of its assets, were acquired, or in the unlikely event that Native Speaker goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Native Speaker may continue to use your personal information as set forth in this policy.