Privacy and Data Protection Policy
At Sterling English we are committed to respecting and protecting your privacy and personal data. We understand that you are aware of and care about your own personal privacy interests, and we take that seriously.
This Notice describes the information that Sterling English collects about you; how we use and protect this information and the choices you can make about how we use this information.
We recognise that information privacy is an ongoing responsibility, and so we will from time to time update and amend this Notice. So please check our website www.sterlingenglish.com occasionally to ensure that you are aware of and satisfied with any changes.
1. Who are we?
We are Sterling English. We are a leading publisher of ELT materials for all levels from A1 through to C2 level of the CEFR. We have one objective: to offer the best possible materials together with the best possible service.
At Sterling English we understand the needs of teaching professionals. Throughout all stages of the editorial process, we consult and collaborate with teachers from all over the world. Without their help, it would be impossible to create practical materials that really work in the classroom. The key to Sterling English’s success lies in the quality of our publications, the high service we offer and the belief that Sterling English users deserve only the very best.
2. What type of information is collected from our clients?
Name. We collect the given names (first name, family name) of clients, and of contacts when they express interest in our services.
Email address. We collect the email address of clients, and of contacts when they express interest in our services.
Postal address. We collect the postal address of clients for billing purposes, and of customers who order products or services or wish to receive free sample copies of our books and invitations to our seminars.
Telephone numbers. We collect the phone numbers of clients to better provide them with our services.
We collect the tax identification number of clients to provide them with our services.
We try to minimize the risk to your rights and freedoms by not collecting or storing sensitive information about you.
3. Where do we obtain the information?
We obtain information about you when you use our website, for example when you contact us about products and services, when you place an order, or if you register to receive invitations to our seminars or free sample books and promotional material. We obtain information from you during your visit to our seminars, to our stands at book exhibitions or when you are visited by our educational representatives. We do not obtain any information about you from other sources or third parties. We do not sell your information to anyone and only share it with third parties who are facilitating the delivery of our services to you.
4. How do we use (process) the information?
We use your information for the following purposes:
Provision of service(s), such as sending educational products purchased i.e. books, CDs, informational emails and/or calls etc.
Marketing and/or other promotion actions, such as: sending samples, providing access to digital material, sending promotional mailings, information about books, information about competitions, sending information about special offers etc. We may also add e-mails that we obtain from general inquiries to this list. Within each e-mail, an opt-out (unsubscribe) link is provided.
5. What is our legal basis for the processing?
The processing of your information, which is used for the provision of our service(s), is based on the performance of a contract.
The processing of your information, which is used for marketing and/or other promotion actions, is based on your consent.
If and when we process your information on the basis of our legitimate interests, we clearly and fully communicate and explain this to you.
6. How long and where do we store your information?
We retain your information for the duration of our business relationship. We store specific client and customer information for as long as needed to be able to meet our obligations to keep accurate records for tax or other administrative authorities.
We store subscribers’ information until such subscriber indicates that he/she no longer wants to receive marketing information.
For more information on where and how long your information is stored, and for more information on your rights of erasure and portability, please contact us at [email protected].
7. What safeguards have we taken to protect your information?
When you give us personal information, we take steps to ensure that it’s treated securely. To help protect the privacy of your information, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your information to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
Among other things, we have implemented the following measures and procedures designed to protect your information from loss, misuse or alteration:
Electronic Access Control
Physical Access Control
Data Transfer Control
Internal Access Control (permissions for user rights of access to and amendment of data)
8. When and how do we share information with others?
We rely on third-party service providers to perform a variety of business operations on our behalf. In so doing, we may need to share your information with them. We provide our service providers with only the personal information they need to perform the services we request, and we require that they protect this information and not use it for any other purpose. The information we collect from you is stored in one or more databases hosted by third parties located in the European Union. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval. We engage third parties to mail information or deliver products to you, including books you may have purchased or material from an event sponsor.
9. Your Rights
You have the right to request access to your personal information that we process. You also have the right to:
Rectify incorrect personal data or erase it under certain circumstances.
Restrict or object to the processing of your personal data.
Receive your data so that you can use it elsewhere
Where we process data based on your consent, you also have the right to withdraw your consent at any time but this does not affect the lawfulness of the processing before the date that you withdrew your consent.
Finally, you have the right to lodge a complaint with a supervisory authority. If you do not know who your supervisory authority is, please contact us and we will help you.
10. Transferring of information outside the EU
Information we collect from you might be transferred or processed outside the EU. Such transfer takes place on the basis of a European Commission’s adequacy decision as set forth in Article 45 of the GDPR. In particular, we collect and transfer personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Sterling English in a manner that does not outweigh your rights and freedoms. Sterling English endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Policy.
Our website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of our website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyse trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
12. How to contact us?
13. Version information - Changes and Updates
This policy was last updated on 21-May-2018.
We reserve the right to amend this Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy and Data Protection Notice at our website. We may e-mail periodic reminders of changes to and updates of this Policy, but you should check our website frequently to see the current Privacy and Data Protection Policy that is in effect.