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Personal Information We Collect
For the purposes of this policy, “Personal Information” means information about an identifiable individual or information that permits an individual to be identified and which is collected by Comfort Education through the use of our services, including our website and any other online platforms that may be offered or operated from time to time. Personal Information does not include business contact information, such as name, title, business address and business telephone number when used for business communications.
Depending on the nature of your interactions or relationship with Comfort Education, we may collect such Personal Information as your first and last name, postal and email addresses, telephone number(s), social network data, information concerning your social circumstances, including age, date of birth, marital status, employment details and job title, education/qualification information, gender, religion, race, health details and other sensitive Personal Information. For the purposes of certain services we offer, including the facilitation of international visas, with your consent, we may also collect Personal Information pertaining to your dependents, who may be minors. We may also collect certain technical information about your use of our website and online platforms, including your IP address, the type of browser you use, access times, pages viewed and the referring link through which you accessed our website or platform. If you choose to engage in the purchase of any service from us, we or our third-party payment processors will collect your payment information.
Technologies such as cookies, beacons, tags and scripts, which are identifying technologies that your computer receives when you visit certain websites are used by Comfort Education. In certain circumstances, we may match or correlate this information with personal information that you may have previously submitted to Comfort Education to improve our service offerings to you. Most browsers can be set to reject all cookies but features of our website may not work as intended if that option is chosen. We use permanent cookies to analyze website usage. We use temporary (session based) cookies to improve performance and to determine web trends. Temporary cookies disappear when you close your browser window. We use your IP address to help diagnose problems with our server, and to administer our website. Your IP address is used to help identify you for the purposes of gathering broad demographic information. We also use Google Analytics, Google Tag Manager, Google AdWords (Conversion Tracking), LinkedIn (Conversion Tracking), Optimize, Unbounce, Hotjar, Intercom and Hubspot. Some or all of these tools may be used to track information about your behavior on our website depending on your region.
Comfort Education takes responsibility for maintaining and protecting Personal Information under our control. We have appointed a Data Protection Officer who can be contacted directly by the public and who is responsible for our day to day compliance. We review this policy and our personal data protection practices regularly to ensure that we are in compliance with applicable legislation and current best practices.
How we collect, use and disclose personal information
We only collect personal information as required to meet the purposes that we have identified. We do not indiscriminately collect or retain personal information.
Comfort Education typically collects personal information that is voluntarily provided by the individual in question. At times, however, personal information is obtained from other sources, such as government bodies or third parties such as employers, references and service providers, as permitted by law. Where the purpose for the collection of personal information is unclear, you can ask the Comfort Education representative with whom you are dealing to provide an explanation of the purpose for the data collection. If required by applicable law, we will seek your explicit consent to process your Personal Information collected by Comfort Education and/or volunteered by you. The granting of such consent is entirely voluntarily; however, if you do not grant the requested consent, your use of the services provided by Comfort Education including our website and any other online platform that we may offer from time to time may not be possible.
Our reason for collecting Personal Information about job candidates, clients, staff and consultants is to establish and maintain the employment, contractual or other business relationship.
The purpose for collecting Personal Information about prospective placement candidates is primarily to provide recruitment services and representation, to maintain client and candidate relationships, communicate effectively with our clients and candidates and maintain mailing lists.
We may also use your Personal Information to:
Respond to your comments, questions and requests and provide customer service;
Communicate with you about services, offers and promotions and provide news and information we think will be of interest to you;
Manage your account and send you technical notices, updates, security alerts and support and administrative messages;
Monitor and analyze trends, usage and activities;
Link or combine with information we get from others to help understand your needs and provide you with better service; and
Carry out any other purpose for which the information was collected.
As appropriate, Comfort Education will ask for specific consent to collect, use and disclose Personal Information, including for the purposes of completing or arranging for the completion of background checks and searches. This may be in writing or orally. In some cases, consent can be implied through an individual relationship or conduct with us, depending on the sensitivity of the information.
Personal information supplied to us is confidential and we do not disclose the information to any third party except with actual or implied consent, or as permitted or required by law. We do not exchange or sell personal information.
We may share Personal Information about you as follows:
- with international hiring bodies for whom we provide recruitment services, consultants and other service providers who need access to such information to carry out work on our behalf, including our legal and financial advisors;
- in response to a request for information from a court, law enforcement agency or other government agency or department if we believe disclosure is in accordance with any applicable law, or as otherwise required by any applicable law;
- if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third party;
- in connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another entity; and
- otherwise with your consent or at your direction.
We may also share aggregated or de-identified information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) which cannot reasonably be used to identify you. If you have given your consent, we may also use your Personal Information that we collect to send you marketing or other commercial communications.
If you receive commercial emails from us, you may opt-out or unsubscribe at any time by following the instructions contained within the email or by sending an email to email@example.com Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the any service or online platform that Comfort Education operates and with which you maintain a current user account.
Any personally identifiable information you elect to make publicly available through the use of our websites or any other Comfort Education service or online platform, such as posting comments on our blog page or in forums, will be available to others. If you remove information that you have made public, copies may remain viewable in cached and archived pages of our website or other online platforms, or if other users have copied or saved that information.
We display personal testimonials on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Comfort Education will never rent or sell your Personal Information to others. However, we may use third party service providers from time to time to carry out certain functions for us such as data storage on servers or databases with hosting providers, printing, storage, shredding or document scanning. Where we use such outside service providers, we require those third parties to protect personal information in the same manner in which we protect it and to not use or disclose it for any purposes except as directed by Comfort Education.
Comfort Education may transfer, process and store Personal Information to affiliated entities or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world, and your Personal Information may therefore be disclosed, transferred, stored (including electronically) or processed in such other jurisdictions for the purposes described herein.
In particular, by accessing or using our website, services or online platforms or otherwise providing Personal Information to us, you specifically acknowledge the processing and transfer of Personal Information in and to the United States of America (“U.S”) and that any personal information which is disclosed, transferred, stored or processed in the U.S. may be subject to legal requirements of that jurisdiction, including the United States USA PATRIOT Act, which facilitates, among other things, the ability of U.S authorities to conduct searches and to seize or compel the disclosure of records which may contain Personal Information.
if you choose to use the Comfort Education website or any of the services or online platforms we operate from the EU or EEA or other regions of the world with laws governing data collection and use that may differ from UK or U.S. law, then please note that you may be transferring your Personal Information outside of those regions to the U.S. for storage and processing by our service providers listed below. We will comply with GDPR requirements providing adequate protection for the transfer of personal information from the EU/EEA to the U.S. or Canada.
Comfort Education Data Processors:
- ZOHO Corporation
Collecting and storing
- Bluehost Inc
Collecting and storing
Information you disclose publicly
By connecting with the Comfort Education through our social media pages or accounts, or by posting content using Comfort Education -created hashtags or other identifiers, you are providing your consent for Comfort Education to use any Personal Information or other content you submit or make available through such sites for marketing and promotional purposes, including, but not limited to, incorporation into our marketing materials, without further notice or compensation.
Comfort Education may also collect and process any Personal Information that you volunteer in our website forms, including when you sign up to receive newsletters or other information from Teach Away.
Our website contains links to third party web sites. Comfort Education is not responsible for the privacy practices or the content of such web sites nor does Comfort Education warrant the quality, accuracy or completeness of information contained in these sites.
For individuals located in the European Economic Area (EEA), all processing of Personal Information is performed in accordance with privacy rights and regulations following the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and Comfort Education’s processing of the Personal Information of such individuals will take place in accordance with the GDPR.
Comfort Education processes Personal Information both as a “Processor” and as a “Controller”, as defined in the GDPR; however, where you have volunteered personal information with respect to the creation of a user account under any of the services or online platforms offered by Comfort Education from time to time, you will be the Controller and Comfort Education will be the Processor.
All data collected by Comfort Education will be stored exclusively in secure hosting facilities provided by Bluehost Inc. Comfort Education has a data processing agreement in place with this provider, ensuring compliance with the GDPR. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.
Protecting your personal information
Regardless of your geographic location, we strive to maintain personal information in as accurate, complete and up-to-date a form as necessary to fulfil the purposes for which it was collected. We protect personal information by adopting reasonable physical, technical and organizational security processes and safeguards appropriate to the sensitivity of the Personal Information, regardless of format, which prevents accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of Personal Information. Our security safeguards include premises security and restricted access to files containing personal information. Depending upon the information under our control, we also use technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access, internal passwords and security policies. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. Comfort Education will promptly notify individuals in the event of any known unauthorized access to or use of that individual’s Personal Information.
Retention and Deletion
Comfort Education will not retain data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws. For certain data pertaining to a user account registered to one of Comfort Education’s online platforms, you have control over the Personal Information collected and the duration for which your Personal Information is kept. Users of Comfort Education’s online platforms with an active account will therefore have the responsibility to delete data as and when required. If you have an active user account with a service or online platform operated by Comfort Education we will retain your information for so long as your account is active or as needed to provide you with services. If an account of a user of one of Comfort Education’s online platforms is terminated or expires, all Personal Information collected through that platform will be deleted, as required by applicable law.
Accessing your personal information
If you maintain a current account with Comfort Education or one of the services or online platforms we operate, you can review, correct, update, amend or delete Personal Information about you by writing to our Data Protection Officer to request such access. Comfort Education will acknowledge your request within seventy-two (72) business hours and handle it promptly. If requested, we will inform you if we are holding Personal Information about you, as well as details about the Personal Information. We reserve the right to confirm your identity before complying with any access request. In responding to an access request, we may charge a reasonable copying or retrieval fee, the amount of which we will provide in advance. Access to Personal Information may be denied if required or authorized by law. If a request for access is denied, Comfort Education will provide an explanation of the reasons for the refusal. If you are a resident of the EEA or the EU, the GDPR gives you a range of rights in connection with our processing of your personal data. In this regard, you have the right to request that we rectify or delete your Personal Information or restrict the processing of your Personal Information, if you think it is inaccurate. Furthermore, you have the right to object to the processing based on our legitimate interests as a legal basis. We are required to assess and act on your request. Additionally, you also have the right to data portability if it should become relevant.
If you choose to withdraw your consent to continued collection, use or retention of your Personal Information, we will explain the consequences of such withdrawal. You may also challenge the accuracy of Personal Information about you in our custody and Comfort Education Ltd will amend Personal Information where appropriate.
You agree, through your use of any forum operated by Comfort Education through our website or any other online platform that we operate from time to time, that you will not post any material which is false, defamatory, inaccurate, abusive, vulgar, hateful, harassing, obscene, profane, sexually oriented, threatening, invasive of a person’s privacy, adult material, or otherwise in violation of any International law. You also agree not to post any copyrighted material unless you own the copyright or you have written consent from the owner of the copyrighted material. Spam, flooding, advertisements, chain letters, pyramid schemes, and solicitations are also forbidden on this forum. You agree to abide by the Terms of Service (TOS) provided on the forum boards.
Note that it is impossible for the staff or the owners of this forum to confirm the validity of posts. Please remember that we do not actively monitor the posted messages, and as such, are not responsible for the content contained within. We do not warrant the accuracy, completeness, or usefulness of any information presented. The posted messages express the views of the author, and not necessarily the views of this forum, its staff, its subsidiaries, or this forum’s owner. Anyone who feels that a posted message is objectionable is encouraged to notify an administrator or moderator of this forum immediately. The staff and the owner of this forum reserve the right to remove objectionable content, within a reasonable time frame, if they determine that removal is necessary. This is a manual process, however, please realize that they may not be able to remove or edit particular messages immediately. This policy applies to member profile information as well.
You remain solely responsible for the content of your posted messages. Furthermore, you agree to indemnify and hold harmless the owners of this forum, any related websites to this forum, its staff, and its subsidiaries. The owners of this forum also reserve the right to reveal your identity (or any other related information collected on this service) in the event of a formal complaint or legal action arising from any situation caused by your use of this forum.
With this user account you are about to register, you agree to never give your password out to another person except an administrator, for your protection and for validity reasons. You also agree to NEVER use another person’s account for any reason.
Acceptance of this Policy
How to contact us
Data Protection Officer
Comfort Education Ltd
20-22 WENLOCK ROAD
If you have a concern about the Personal Information handling practices of Comfort Education, a complaint, in writing, may be directed to our Privacy Officer. Upon verification of your identity, we will act promptly to investigate the complaint and respond within 60 days.
If you are dissatisfied with the finding of and corresponding action taken by our Privacy Officer, you may bring a complaint to the The Information Commissioner’s Office, United Kingdom using the details below:
The Information Commissioner’s Office, United Kingdom— Website: https://ico.org.uk
Helpline: 0303 123 1113