Privacy and Cookies Policy

TEFL PROFESSIONAL NETWORK LTD

PRIVACY AND COOKIES POLICY

As the operators of the website www.tefl.com (“ Website ”), TEFL Professional Network Ltd.  (" We ", “ Us ”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“ Policy ”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (“ GDPR ”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “ Data Protection Laws ”) the Data Controller is TEFL Professional Network Ltd., also trading as TEFL.com.

YOUR PERSONAL INFORMATION

Information we collect from you

We collect and process some or all of the following types of information: 

• Information that you provide by filling in forms on the Website or filling in forms as part of the registration process. This includes information provided when you register as a user on the website www.tefl.com . 

• Specifically, personal details such as name, email address, date of birth, geographical address/location, IP addresses,  or any information input or contained in any attachments you upload (e.g. your resume)  when using the Website, completing our survey forms, using our services. 

• If you contact Us, We may keep a record of that correspondence. 

• We may also receive information about you from third parties if you login or register for an account with a third party service (e.g., Facebook, Twitter), the third party service may send us information such as your registration and profile information from that service. 

• We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them. 

• Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access. 

If you have provided us with the personal data of another person you confirm that they consent to the processing of their personal data and that you have informed them of our identity and the purposes (as set out above or elsewhere) for which their personal data will be processed.  

The provision of your name, email address and address are required to enable Us to register you as a user of Our Website. 

The provision of your job title, details of the company you work for including name, type of organisation and address are also required to enable Us to register you as a “Recruiter” user of Our Website. 

The provision of your current employment details, country and town of birth, date of birth, nationality, gender, confirmation regarding whether or not you hold a passport, employment preferences, confirmation regarding whether or not you have a degree are also required to enable Us to register you as a “Jobseeker” user of Our Website. 

We will inform you at the point of collecting information from you, whether you are required to provide the information to Us. 

USES MADE OF YOUR INFORMATION 

Lawful basis for processing

- We process your data in order to perform our obligations pursuant to the Terms and Conditions , as displayed on our Website. This is the lawful basis on which We collect and use your personal data. 

In instances where you have activated your resume/cv to be searchable by registered employers, We rely on “consent” as the lawful basis on which the We use and share this personal data.  

We rely on your consent as the lawful basis where you have agreed to participate in a survey, and for the processing of such personal information as has been collected through that survey. 

We rely on “legitimate interest” where: 

-    We collect, use and share (in accordance with this policy only) your personal data in order to provide our services pursuant to an agreement with an organisation that has engaged you. 

-        We use and process your contact details to correspond with you to build a potential business relationship or when providing you with materials and information we feel may be of interest to you. 

-        You navigate and access resources and services on our website, to ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website.  

  Purposes of processing  

We use information held about you in the following ways: 

• To provide you with our services. 

• To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website; 

• To alert you to any news and/or service changes; 

• To provide you with information and offers that you request from us or which we feel may interest you. 

• To carry out our obligations arising from any contracts entered into between you and Us. 

• To allow you to participate in interactive features of our service, when you choose to do so. 

• To notify you about changes to our service. 

• To send you our surveys.

DISCLOSURE OF YOUR INFORMATION 

We may pass your name, email address, date of birth, geographical address/location, IP addresses, or any information input or contained in any attachments you upload (e.g. your resume) information to our third party service providers, agents and subcontractors for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).  

We may also disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable). 

We may also disclose your personal data to third parties: 

• in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or 

• if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or 

• if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or 

• to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website; or 

• in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you. 

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.  

STORING YOUR PERSONAL DATA  

Security  

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so. 

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access. 

Keeping your personal data up to date  

If your personal details change you may update them by accessing your profile on the Website, or by contacting us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact us by sending a request by email to the contact details below. 

How long w e keep your personal data  

We will hold any information you input or contained in any attachments you upload (e.g. your resume) such as your name, email address, date of birth, geographical address/location for as long as you have registered an account with Us, unless you notify Us otherwise or terminate your account. 

Any financial data (where you have made payment to us for our services) will be retained for 7 years in accordance with applicable tax laws. 

Data such as IP addresses will be retained for a period of 1 year from its first entry into our logs. 

Data collected in relation to your interaction (such as ‘clicks’) with content on our website shall be retained indefinitely and aggregated into non-personal and statistical data on expiry of the retention period for the IP address associated to such data. 

Where you use our resume parsing functionality, and where you delete any information from your account (e.g. your resume), system data (e.g. IP address, Username) collected in relation to these will be retained for 365 days. Please note that any personal data you upload using our resume parsing functionality will be retained for 90 days.  

Where we store your personal data  

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. 

In particular, your data may be stored by TEFL’s hosting service provider on servers in the USA as well as in the EU.  The USA does not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to the EU- US Privacy Shield Framework. This framework is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data. Details of the EU – US Privacy Shield Framework are available (here: https://www.privacyshield.gov/welcome. 

If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS 

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Policy is already designed to address
• require Us to correct any mistakes in your information which We hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws .

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation . 

If you would like to exercise any of those rights, please:

• please contact Us (see ‘Contact’ below).
• let Us have enough information to identify you,
• let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let Us know the information to which your request relates .  

HOW TO COMPLAIN 

We hope that We can resolve any query or concern you raise about our use of your information. 

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner’s Office (ICO). 

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied privacy policy.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES 

We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services. 

Our Website uses cookies to distinguish you from other users of our Website. This helps Us to provide you with a good experience when you browse our Website and also allows Us to improve the Website. By using our Website you agree to our use of cookies as more specifically set out below. 

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. 

You can find more information about the individual cookies We use and the purposes for which We use them in the table below: 

 Please note that third parties affiliates, such as advertisers may also use cookies, over which We have no control. 

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website. 

Except for essential cookies, all cookies will expire after 6 months. 

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

Facebook
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Our app includes Facebook’s Software Development Kit (SDK).

We currently do not use this SDK for any purpose within the app.

Further information about the Facebook SDK within iOS can be found here: https://developers.facebook.com/docs/ios. For Android, please refer to: https://developers.facebook.com/docs/android.

Firebase by Google
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We use the Firebase service from Google LLC. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) in order to derive application behavioural analytics. We use that information to see how users interact with our app.

Currently, we use the following Firebase services:

Google Analytics for Firebase:
Google Analytics uses the data to provide analytics and attribution information. The precise information collected can vary by the device and environment. You can find more information via this link: Data collection - Firebase Help. and on Google’s partner policy.

Google Analytics retains ID-associated data for 60 days, and retains aggregate reporting and campaign data without automatic expiration, unless the Firebase customer changes their retention preference in their Analytics settings or deletes their project.

CONTACT

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to info@tefl.com .