|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|
|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:
Country of residence
Browser and device information
Server log file information
Information collected through cookies
Demographic information and other information provided by you
|HOW DO WE COLLECT YOUR PERSONAL INFORMATION?|
We may collect your data:
Through your interaction with our website.
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 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.|
date of birth
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.
date of birth
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|
flight details (in form of travel information)
|PROOF OF PAYMENT FORM|
proof of payment (in form of file/attachment)
|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|
|DATA COLLECTED VIA PAYPAL|
|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 email@example.com, we will be more than happy to assist you and evaluate a tailor made experience.
|RETENTION PERIOD OF YOUR PERSONAL 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 firstname.lastname@example.org.|
|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 email@example.com.
|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:
Rua António Aleixo no19 2dt 2855-229, Corroios Portugal
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/