STUDENT PRIVACY POLICY 

1. Introduction

LP Language Professional ("we"/"us"/"our") are committed to preserving your privacy. This page explains what information we collect about you, while you are a student or having been a student of LP Language Professional, how we use it and the way we protect it. Our use of your personal data is subject to your instructions, the EU General Data Protection Regulation ("GDPR"), other relevant Maltese and EU legislation and our professional duty of confidentiality.

For the purposes of the GDPR, the Data Controller, is:
LP Language Professional
IL-Kapanna Dahlet il-Gibjun
Naxxar NXR 2352
Malta

Phone: +356 99868479
Email: lorrainepirotta@gmail.com   

Contact us

If you wish to request any clarification or additional information in relation to this privacy policy, or you may wish to exercise any of your rights in relation to your personal data, please send us an email on lorrainepirotta@gmail.com.

This privacy policy is effective as of 19/01/2019. In the event that we modify this privacy policy, we will post a clear notice of this update in the homepage of our website. 

Key terms

Data Controller: The person that determines the purposes and means of the processing of personal data
Personal data: Any information relating to an identified or identifiable natural person 
Processing: Any operation which is performed on personal data such as collection, storage, use and erasure 
Sensitive Personal Data: Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic and biometric data and data concerning health, sex life or sexual orientation 

2. Personal Data that we collect, may process and what we may use it for

The personal data we collect and process about you is given to us by you directly. This includes all personal information that you have provided us with when exchanging communications prior to the commencement of your tutoring sessions and any other information and documentation that you have submitted to us. We also maintain a record of your studies at LP Language Professional. 

The table below sets out the types of personal data that we may process, what we may use it for and our legal bases, that is our reasons, for processing:

ActivityPersonal data we may processWhat we may use your personal data forOur legal bases
Your registration as a student of LP Language Professional

All the details that you provide to us together with all the supporting documents and any additional details which we may record during, a face to face or online, meeting or interview process.

These include your name and contact information, information relating to your education and employment.

A record of your studies. This includes information about the exams you have taken, assessments you submitted and your results.

Your registration as a student at LP Language Professional.

To deliver and administer your education. This relates to all academic matters while you are a student at LP Language Professional and includes the provision of our teaching services to you, as set out in our student agreement.

To deal with any queries you may have.

To meet our compliance and regulatory obligations, such as compliance with anti-money laundering regulations.

To carry out teaching and research.

To promote our services. When we require legal advice or any other advice relating to our rights and obligations.

To recover money you owe to us.

To operate any governance, audit and quality assurance processes.

Performance of contract
It is necessary for the performance of a contract with you.

Performance of a legal obligation
To comply with our legal and regulatory obligations.

For our legitimate interest and for the performance of our tasks we carry out in the public interest.

For administrative purposes and to improve the overall management of the tutoring sessions.

Consent
On the basis of the consent that you have provided us, where this is required.
You are consenting us to process your personal data upon the submission of your personal data in the context of your student contract with us.

3.  Who do we share your data with

We will share your personal data internally with your tutor at LP Language Professional. We do not share your data with third parties, except where we are strictly required in response to any requests made from law enforcement agencies, government entities or public authorities, to comply with court orders, to obtain legal remedies and/or limit our damages, to protect your rights as well as our rights and where we deem necessary or appropriate under applicable laws and regulations.

4.  Where your personal data is held

We hold your personal data at our offices.

5. Transfers of your personal data outside the EEA

We do not share your personal data outside the European Economic Area (EEA).

6. Personal Data retention period

We retain your personal data which will form part of your student record throughout the duration of your tutoring sessions at[LP Language Professional  and we will also retain your personal data after you have completed your tutoring sessions at [ LP Language Professional] . We will need to keep your personal data after your association with us has come to an end in order to comply with our record keeping requirements in terms of the law and to be able to respond to any questions, complaints or claims made by you or on your behalf. 

We will not collect more data than we require or retain your data for longer than necessary to fulfil the purposes outlined in this policy.

7. Your rights with respect to your Personal Data

You have the following rights:

Right of Access 
The right to access and be provided with a copy of your personal data.
 
Right to Rectification
The right to require us to correct any inaccurate personal data about you.

Right to be forgotten
The right to require us to delete your personal data in certain circumstances.

Right to restriction of processing
The right to require us to restrict processing your personal data in certain circumstances.

Right to data portability
The right to receive your personal data which you provided to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another data controller in certain circumstances.

Right to object
The right to object to the processing of your personal data in certain circumstances which include processing for direct marketing purposes and continued processing of your data carried out for the purpose of our legitimate interests.

Right not to be subject to automated processing
The right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you.

Should you require any further information on each of the above rights or would like to exercise any of them, please contact us on privacy at lorrainepirotta@gmail.com

8. Protecting your personal data

We have implemented security measures to protect your personal data that we collect from being used or accessed unlawfully or accidentally lost. We keep your personal data separate from any other data and retain it in secure files. Access to your personal data is only granted to your tutor who has a genuine need to access it and is subject to the duty of confidentiality.

9. Complaints

We would like to resolve any concern that you may have about the processing of your personal data directly with you. However, you have the right to lodge a complaint with a supervisory authority, in the EU state in which you work, reside or where the alleged infringement of data protection laws took place. The supervisory authority in Malta is the Office of the Information and Data Protection Commissioner which may be contacted at idpc.org.mt/en/Pages/contact/complaints.aspx. 

Use of Google Analytics

(1) This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, in the event of activation of IP anonymisation on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website usage and internet usage to the website operator.

(2) The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data.

(3) You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible. You may also prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by using the browser plug-in available under the following link in download and install tools.google.com/dlpage/gaoptout or manually by clicking the following link:  Deactivate Google Analytics

(4) This website uses Google Analytics with the extension "_anonymizeIp ()". As a result, IP addresses are processed shortened, a person-relatedness can be excluded. Insofar as the data collected about you is assigned a personal reference, it will be immediately excluded and the personal data will be deleted immediately.

(5) We use Google Analytics to analyze and regularly improve the use of our website. With the statistics we can improve our offer and make it more interesting for you as a user. For the exceptional cases in which Personal Information is transferred to the US, Google has submitted to the EU-US Privacy Shield, www.privacyshield.gov/EU-US Framework. The legal basis for the use of Google Analytics is Art. 6 para. 1 sentence 1 lit. f GDPR/DSGVO.

(6) Third-party information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.

Terms of Use:
www.google.com/analytics/terms/en.html

Privacy Policy:
www.google.com/intl/de/analytics/learn/privacy.html,
www.google.com/analytics/learn/privacy.html
www.google.de/intl/de/policies/privacy.

(7) This website also uses Google Analytics for a cross-device analysis of visitor flows, which is carried out via a user ID. You can disable the cross-device analysis of your usage under My Data, Personal Information in your customer account.

Last updated on 08/04/2019