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Privacy Policy (LAST UPDATED 24 Gen 2019)

By visiting the website, you are accepting and consenting to the practices described in this Privacy Policy. If you do not agree with any of the terms of this Privacy Policy, please do not use the website or submit any personal information.

INTRODUCTION With the intent to meet to the best of our possibilities the guidelines of the General Data Protection Regulation (GDPR) (EU) 2016/679 on data protection and privacy for all individuals within the European Union, we have carefully reviewed our privacy policies with the aim of giving the simplest and clearest information possible about our use of your personal data.
FULL-IMMERSION IS AN INTERMEDIARY WEB AGENCY
Full-immersion is an intermediary web agency that provides support and intermediary services to individuals over the age of 18 who are interested in attending a language learning program within one or more Partner Schools in an English Speaking country. Full-immersion is run by Mr. Giuliano Mischi (VAT n PT269349472), with the help of a number of collaborators. Full-immersion is based in Rua António Aleixo no19 2dt 2855-229, Corroios Portugal.
ABOUT OUR PARTNERS
You should read and understand the Privacy Policies of our Partner Schools, before booking one of THEIR courses promoted via OUR website. You may find a list of our Partner Schools and the links to their websites containing their Privacy Policies within the section “Partner Schools” at the bottom of this page. Before enrolling to any course, provided by the Partner Schools, via our website, you will be required to explicitely consent to pass on the personal information that are strictly required to fulfill your booking request on to the relevant Partner School.
WHAT IS FULL-IMMERSION.COM(WEBSITE)?
full-immersion.com is the domain name and the website through which the web agency Full-immersion offers its online services. The website is currently property of Marco Guiotto, who founded the site in 2011 and who now takes care of the technical aspects of the website, on behalf of the agency as a full-time collaborator.
The 8 key points of the General Data Protection Regulation
1-THE RIGHT TO BE INFORMED When you use our website, you can be sure that your personal information is treated in a fair and transparent way. We collect the minumum data necessary for the specific purpose you enquire for, and maintain that information for the minimum time necessary, always in your own interest, with no negative effects on your individual rights and freedoms. Because of the very nature of our service, the purpose for which you siubmit your personal information submissions may vary, hence we have listed and described in detail the diverse data submission “forms” and “methods” within the relevant sections in this page.
HOW DO WE COLLECT EXPLICIT CONSENT TO TREAT YOUR PERSONAL INFORMATION

When you enter our website, you are asked to tick a box and accept our Cookie Policy (via Cookie Policy banner, where you have the option to read more about the cookies we use, and about the suppression of them using your browser). Please bare in mind that we do not use profiling cookies, but we use Google Analytics to build and maintain our statistics relevant. All the data collected through cookies is maintained in an anonymum form.

When you use our site to contact us or to send us administrative or logistical information, you are asked to tick a box and accept our Terms and Conditions, Privacy Policy and Cookie Policy. Please bare in mind that you’re using one of the following forms, that are detailed in the relevant section: Contact form, Flight Details form, Proof of Payment form.

When you use our site to send autonomously a quote to your email, you are asked to tick a box and accept our Terms and Conditions, Privacy Policy and Cookie Policy. Please bare in mind that you are using the “Quotation form”, and you will receive some email reminders for your quote with the sole purpose of avoiding the typical issues connected to last minute booking, please findo more detailed information in the relevant section.

When you use our website to enroll to a language programme that is provided by one of our partner school,you have to accept and agree that we may transmit some or all of your personal information on to the admissions personnel of the relevant partner school, as this is the only way your request can be fulfilled. Please refer to the section Partner Schools for more info on their Privacy Policies. The transmission of your data from Full-immersion to the partner school can be deployed either via email or via particular agency portals that some Partner Schools and institutes have created for this purpose, said portals run within a secure and encrypted environment. Before your personal information is transmitted and your booking processed, you have to explicitly consent the transmission of it by ticking the box “I accept Terms and Conditions, Privacy Policy and Cookie Policy”, located in the last step of our online booking system. Please bare in mind that you’re using the Booking form in this case, more info in the relevant section.

HOW DO YOU VERIFY THAT YOU HAVE GIVEN US EXPLICIT CONSENT TO TREAT YOUR PERSONAL INFORMATION?
When you use our online forms and tick the consent to the use of the personal information you provide, you receive an automatic reply that shows, within its text, that you’ve given explicit consent.
WHAT PERSONAL INFORMATION DO WE COLLECT?

“Personal Information” is information or pieces of information that could allow you to be personally identified, such as:

Name

Surname

Telephone number

Email address

Country of residence

IP Address

Browser and device information

Server log file information

Information collected through cookies

Demographic information and other information provided by you

Location information

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We may collect your data:

Through your interaction with our website.

Via email.

Through a telephone call.

When you contact us via our social media channels.

When you visit our Partner Schools.

When you meet us in person, from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties.

Through your browser or device: Certain information is collected by most browsers or automatically through your device. We use this information for statistical purposes as well as to ensure that the Sites function properly.

Through server log files: Your “IP Address” is a number that is automatically assigned to the computer or device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Sites, along with the time of the visit and the page(s) that were visited.Using cookies: Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit the Cookies Information page provided by the Information Commissioner’s Office (ICO). For detailed information about the cookies we use and the purposes for which we use them, please see our cookies policy.

Through your use of an App. When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

From you: Information such as date of birth, gender and zip code, as well as other information, such as your preferred means of communication, may be collected when you voluntarily provide this information.

Physical Location: We may collect the physical location of your device.

Please find a list of the forms and the data we collect as follows.
CONTACT FORM

name

surname

email address

telephone number

date of birth

acceptance of our Terms and Conditions, Privacy Policy, Cookie Policy

IMPORTANT: by using this electronic form you consent to the use and maintainment of your personal information for and until the fulfillment of this specific request, as detailed on our Privacy Policy.

QUOTATION FORM

name

surname

email address

residency country

acceptance of our Terms and Conditions, Privacy Policy, Cookie Policy

IMPORTANT: by using this electronic form you consent to the use and maintainment of your personal information for and until the fulfillment of this specific request, as detailed on our Privacy Policy.

IMPORTANT: After receiving the quotation you may receive a limited number of reminders (between 1 and 5 in total, depending on the start date of the course you have enquired for). The reminders are sent in form of an email, in your interest as they avoid issues connected to last minute bookings. If you do not wish to receive these reminders, simply avoid the “send me a quote” section, all the quotations and prices are available instantly on our site even before sending them to your email address. Sending a quotation to your email address is a completely optional step and won’t stop you from using our services including the enrollment/booking service. If you have received a reminder, but you don’t want to receive any more, please click on the link “STOP EMAILS” that you find on the reminder itself, to completely stop receiving them.

BOOKING FORM

name

surname

email address

residency country

nationality

telephone number

date of birth

acceptance of our Terms and Conditions, Privacy Policy, Cookie Policy

IMPORTANT: by using this electronic form you consent to the use and maintainment of your personal information for and until the fulfillment of this specific request, as detailed on our Privacy Policy.

IMPORTANT: This information is transmitted via email to our staff analyzed and transmitted to the admissions department or to the representative in charge of the partner school or institute that you have chosen for your language studies. The institute will hence process your booking and provide us with the documents that confirm your enrollment. We will then send those confirmation documents to you via email, along with other useful information.

FLIGHT DETAILS FORM

name

surname

email address

flight details (in form of travel information)

acceptance of our Terms and Conditions, Privacy Policy, Cookie Policy

IMPORTANT: by using this electronic form you consent to the use and maintainment of your personal information for and until the fulfillment of this specific request, as detailed on our Privacy Policy.

PROOF OF PAYMENT FORM

name

surname

email address

proof of payment (in form of file/attachment)

acceptance of our Terms and Conditions, Privacy Policy, Cookie Policy

IMPORTANT: by using this electronic form you consent to the use and maintainment of your personal information for and until the fulfillment of this specific request, as detailed on our Privacy Policy.

We collect other information in an anonymous way through cookies, please read the following:
DATA COLLECTED IN AN ANONYMUS WAY VIA COOKIES

We collect certain data through cookies. For detailed information, please visit our relevant page that you may find linked to the footer of the website. Cookies are collected in an anonymus way, they include: IP address of the visitor, operating system of the visitor, visited pages and requests, hour and date of connection. These files allow us to improve our service, give our visitors a personalised experience and maintain our statistics relevant. If you don’t want us to collect this information you can change the parameters of your internet browser and/or suppress any current cookies. Please be advised taht in certain cases this might result in the site’s functionality to be partially or totally reduced.

Some cookies such as the Google Analytics cookies are “first-party cookies” and allow us to collect useful information to achieve more targeted marketing objectives when promoting our products online.

DATA COLLECTED IN AN ANONYMUS WAY VIA GOOGLE ANALYTICS
We use Google Analytics to keep track in an anonymus way of the behavior and interactions between the users and the site Full-immersion.com. We have set the data retention time to 38 months before automatic expiration, in order to maintain relevant statistics. All the Google Analytics data that we collectare not related to specific users/persons via User-ID parameters, as we use those data in a completely anonymus form.
We collect other information via your interaction with our live chat system, and via PayPal please read the following:
DATA COLLECTED VIA ZENDESK CHAT
Our website includes a third party Live Chat support system called Zendesk Chat, please follow this link (https://www.zendesk.com/chat/) to see their Privacy Policy. The Company Zendesk Inc. (https://zendesk.com – based in San Francisco, United States, operating worldwide and 100% GDPR compliant) owns the chat system that we have chosen to integrate to our website after comparing the most secure and modern chat systems available on the market. Please note that Zendesk Chat’s own Terms and Conditions and Privacy Policy are available for reading before engaging with the chat via a link placed on top of the chat box (the chat box is to be found on every page of the site, in the bottom right corner). Zendesk Chat is a data processor that stores in an encrypted environment your conversations with our support team. You can, at any time, contact our DPO by writing an email to admin@full-immersion.com to check, rectify or suppress the personal information stored within the database of Zendesk Chat.Any personal information collected via Zendesk Chat is kept for the minimum necessary time to fulfil the specific request, this means that if during a conversation with us you state that you find that you don’t need or don’t want to utilize our services, we will immediately delete your personal information from the chat, while if you enquire for a language course that is supposed to start after 12 months, we will keep the chat log containing any of your personal informations for 12 months.
DATA COLLECTED VIA PAYPAL
In order to book a course on full-immersion.com we ask for a monetary deposit to be submitted electronically, viaPayPal (https://paypal.com – company based in the United States, operating worldwide, 100% GDPR compliant). Full-immersion has chosen the PayPal secure payment system to ensure that the transactions are processed in the most secure environment currently available in the online world. Your payment is processed directly on the PayPal website in an encryption mode (SSL encryption). Before entering your data on the PayPal system you will be shown PayPal own Privacy Policy and you will have to read and accept it before proceeding.
WHY DO WE NEED YOUR PERSONAL INFORMATION?

Your Name and Surname is necessary to identify you as an individual for contact and administration purposes.

Your email is necessary to send you messages of administrative nature and to communicate with you in a non invasive way.

Your telephone number is necessary in case some important emails about your booking or request fail to deliver, in case you mistyped your email making it impossible for us to reach you, in case of emergency, in case we need to inform you about any changes or important/urgent updates inherent to your booking and in case you request a telephone/voice contact (for example but not limited to visually impaired people).

Your date of birth lets us and the partner school know your age and lets us address you to the most suitable course. We currently promote some courses that are exclusive for students who are 30 years old or more.

Knowing your country of residence lets us and the school properly set the correct market discount applicable to your quotation or booking. We use this information also to show you the approximate total in the currency of your own country.

Knowing your nationality is essential for us and for the school, to inform you about special Visa procedures you may incour into when booking certain combinations of courses, lengths and/or destinations.

Your PayPal registered email is necessary for us only (Full-immersion) to refund your initial deposit as soon as you complete the payment of your course to the relevant partner school. This email is sent to us automatically by PayPal, when you pay the deposit online, as per PayPal own policies that you must accept before confirming the booking.

Having access to other information such as your custom request/message, your flight details and your proof of payment is necessary to help you before and/or during and/or after your booking online. For no reason will we ever discose such information with entities that are not strictly related to the fulfilment of your request.

IMPORTANT: If you believe the above does not apply to you, for any reason, please do not hesitate to contact our Responsible at admin@full-immersion.com, we will be more than happy to assist you and evaluate a tailor made experience.

RETENTION PERIOD OF YOUR PERSONAL INFORMATION
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy.This been guaranteed, please bare in mind that the process of booking a language course abroad passes through a number of stages, approaching, scouting, selecting a course, organizing the flight/journey, choosing an accommodation, etc. It’s a time consuming process that often involves multiple contacts with our support team. In order to maintain a relevant and useful thread of communication with the users, we may keep some personal information for 12 months or more in certain specific cases (for example when you enquire for a course that starts in over 12 months). This is not optional but necessary, to ensure that if you come back to the chat system, you still find our support thread and we can continue our conversation even though some time has passed. After the request for which you applied is concluded, your personal information is manually deleted by the responsible of the data treatment.
SENSITIVE INFORMATION
We ask that you neither send us nor disclose any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health or medical condition, criminal background or trade union membership) on or through the website or otherwise to us. If we learn that we have collected such information, we will delete it as soon as possible.
2-RIGHT TO ACCESS Please click on https://www.full-immersion.com/delete-user-data/ to receive a copy of your data via email, you may simply read them or you can read and delete them.
3-RIGHT TO RECTIFICATION We undertake to respect your right to rectify your personal information, to exercise your right write to admin@full-immersion.com.
4-RIGHT TO BE FORGOTTEN

To access and/or completely delete your personal data from the database of Full-immersion, and be forgotten, click on the link: https://www.full-immersion.com/delete-user-data/. The link takes you to a page from where you will be able to receive an email with a copy of all the data stored on our database. You may then click on a link within said email to proceed with the complete data removal. Please bare in mind that deleting your personal information while your booking process is active/ongoing, may interrupt the fulfillment of your booking request.

IMPORTANT: Please note that the personal information that is generally included on the invoices, needs to be maintained and cannot be deleted for legal reasons. Please be assured that the invoices are stored in the most secure environment, accessible only by the finance delartment of the Partner School you’ve chosen for your studies.

5-RIGHT TO RESTRICT PROCESSING You may ask us to restrict processing of your personal information at any time, to exercise your right please write to our DPO.
6-RIGHT OF PORTABILITY The right of portability allows you to obtain a list of all your personal information, and to have it transmitted from a data controller (us) to a different data controller of your choice (another agency). Please note that, where technically feasible, this right will be satisfied directly by our DPO, please write to our DPO to request data portability.
7-HOW TO OBJECT THE USE OF YOUR PERSONAL INFORMATION You may ask us to stop specific uses of your personal information, for example but not limited to the use of your (volountarily provided) telephone number for urgent matters, to exercise your right write to the DPO.
8-RIGHT RELATED TO AUTOMATED DECISION MAKING AND PROFILING We ensured that all the crucial or potentially damaging decisions are always made with human intervention, so to exercise your right or to ask for more information at this regard, please write to the DPO.
Other important considerations and information
SECURITY AND RISKS ASSOCIATED TO OUR WAY OF TREATING DATA

We have implemented the best possible methods, within our possibilities, to guarantee the safety of your personal information. The personal information we collect from you via our website and via email is stored securely in the servers of the hosting company SiteGround (https://siteground.com – the Company is based in the Netherlands, EU, is operating worldwide and is 100% GDPR compliant), within an encrypted environment under SSL Protocol, Secure Sockets Layer, with access control, authorised person, backup file, strong username/password.

The personal information can be accessed only by our highly trusted team, and under the control and supervision of our DPO.

Although we use all the reasonable organizational, technical and administrative measures to protect Personal Information, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting our DPO at admin@full-immersion.com.

USE OF FULL-IMMERSION.COM BY MINORS If you are over the age of 16 but under the age of 18, you should review the terms of this Privacy Policy with your parent or guardian to make sure you both understand them. If we learn that we have collected information from an individual under the age of 16 without parental consent, we will delete that information as soon as possible.
WHAT HAPPENS IN CASE OF DATA BREACHES?

In the remote case of verified data breaches that have to do with your personal data, the DPO will notify within 72 hours the authorities and will put in place the following procedure:

1-The DPO will immediately inform the authorities via their official channels https://idpc.org.mt/en/Pages/Home.aspx.

2-The DPO will then make sure that the hosting company that hosts the leaked data has a direct line with the authorities and will help in every way possible the interaction between the Authorities and the Hosting Company, offering support, information and explaining in the most clear way possible the situation.

3-The DPO will then proceed to inform the users whose data were leaked about the status of the situation, and communicate what personal information was leaked.

4-During the whole process the DPO will use its channels (website and/or social media channels) to keep an updated and public log of the actions that are being taken to sort out the issue.

DPO – DATA PROTECTION OFFICER The DPO (Data Protection Officer) of the agency Full-immersion is Mr. Marco Guiotto (VAT n MT22447919). The DPO has provided the necessary GDPR information to all the support team of the agency and to the Partner Schools, to guarantee the maximum discretion and protection of your personal information within every single and specific phase of the service. A list of agency agreements (containing non disclosure clauses) signed by the agency and by the Partner Schools is available for consultation upon request of the authorities.
ANY OTHER REQUEST

For any other request you can contact the DPO or the Agency to exercise your right:

Full-immersion,

Rua António Aleixo no19 2dt 2855-229, Corroios Portugal

Email: it@full-immersion.com

Website: www.full-immersion.com

CHANGES TO THIS PRIVACY POLICY We may change this Privacy Policy. Please take a look at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on a the website. Your use of the website following these changes means that you accept the revised Privacy Policy.
PARTNER SCHOOLS

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of our Partner Schools, including any third party operating any site to which Full-immersion website contains a link. The inclusion of a link on full-immersion.comwebsite does not imply endorsement of the linked site by us or by our partners. Our partners own privacy policies, are valid for direct bookings and enquiries via their websites as well as for booking performed through full-immersion.com.

Please, before you decide to book a course with Full-immersion, make sure you visit, read and understand the Privacy policy of our partners, visit their websites for more information:

EC English Language School (Malta) https://www.ecenglish.com

Eurocentres English Language Centres (Malta) http://eurocentres-malta.com/

Linguatime English Language School (Malta) http://linguatime.com/

Easy School of Languages (Valletta) https://easysl.com/

Institute of English Language Studies (Malta) http://www.ielsmalta.com/en

Cork English College (Ireland) https://corkenglishcollege.ie/

Galway Cultural Institute (Ireland) https://www.gci.ie/

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