Introduction and contents
Our values guide everything that we do – including our editorial approach and how we use personal data. We are strongly committed to keeping your personal data safe. This commitment exists throughout the lifecycle of your personal data, from the design of any QEA service which uses personal data to the deletion of that data.
We think carefully about our use of personal data, and below you can find the details of what we do to protect your privacy. This policy covers, among other topics:
- Information about your rights, the choices available to you, and our obligations in the China, in USA, in EU, and elsewhere
- Transparency about how we collect and use your personal data, including when and how it is shared
- Information on how we protect your personal data
- Information on how we will facilitate your rights and respond to your questions
Personal data is any information about you by which you can be identified or be identifiable. This can include information such as:
- your name, date of birth, email address, postal address, phone number, mobile number, financial details, such as payment cards you use to purchase products, subscriptions or support our journalism
- information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based)
- information relating to how you use and interact with our sites, apps and services
When we refer to “personal data” in this policy, we are also referencing “personal information”.
Who we are and how to contact us?
Queen’s English Academy Limited, Brighter Place, 88 This is the Way, Shenzhen 518000 is the data controller in respect of your personal data. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us directly, you can find our contact details in the “How to contact us” section below.
The types of personal data we collect about you
We collect your personal data when you visit our websites and apps, subscribe for products or services, contribute to the QEA or when you interact with us. We will only collect your personal data in line with applicable laws. We collect your personal data in various ways:
- directly from you, when you sign up for our services and when you browse our sites or use our apps
- personal data we generate about you, e.g., personal data we use to authenticate you, or personal data in the form of your IP address or your preferences
- personal data we collect from third parties, e.g., personal data that helps us to combat fraud or which we collect, with your permission, when you interact with your social media accounts
More detail about these three categories of personal data is provided below.
The personal data we collect when you register for a QEA account
When you register for a QEA account on queensenglishacademy.com, we collect:
- your name
- your email address
- other details such as your residential or billing address when you sign up for membership or a subscription
- some limited data from your social media profile (further information on this is below), if you have signed in to queensenglishacademy.com using your social media details
- Payment details such as credit card details or other forms of online payment details
- your photograph, if you add one to your profile page
You can change or remove these details using the profile and settings area of your QEA account.
Personal data we generate about you
When you register for a QEA account, we assign you a unique ID number that we use to recognize you when you are signed in to our services. This will recognize you if you sign in using the same account on a new device or through a different application such as the QEA app on mobile devices.
- your IP address – a numerical code to identify your device, together with the country, region or city where you are based
- your geolocation data – your IP address can be used to find information about the latitude, longitude, altitude of your device, its direction of travel, your GPS data and data about connection with local Wi-Fi equipment
- information on how you interact with our services
- your browsing history of the content you have visited on our sites, including how you were referred to our sites via other websites
- details of your computer, mobile, TV, tablet or other devices, for example, the unique device ID, unique vendor or advertising ID and browsers used to access our content
We will not collect special categories of data from you – such as personal data concerning your race, political opinions, religion, health or sexual orientation – unless you have chosen to provide that type of personal data to us.
When you use our apps
The QEA apps use personal data based on the content you have viewed. Information on bugs and crashes is also sent to us when you use our apps. A list of the courses that you have recently viewed is also cached in the local storage on your mobile device. You can delete this reading history in the settings of the app. You can choose to receive notifications on your mobile device via the app, and manage these notifications in the settings of the app.
Using your social media details to sign into your QEA account
When you sign in to our sites or apps using your Facebook login details, you give permission to Facebook to share with us your email address and certain aspects of your Facebook profile if you have made these public on your Facebook profile. This only includes your first and last name, age range, link to your Facebook profile and profile picture. We do not have access to updates on your Facebook profile. If you use your Google login details, you give Google permission to share the personal data that you have made public in your Google profile. This only includes your first and last name, your email address and whether your email address has been validated, your age range, a link to your Google profile and, if you have one, your profile picture. If you register or sign in with your Apple ID, you give Apple permission to share your personal data with us. You can also choose to hide your email and Apple will create a random email address so your personal email can stay private. This email address will be linked to your QEA profile and will be used to retrieve your subscribed content.
We will then use this personal data to form a profile for your QEA account. If you remove the QEA app from your Facebook settings, or from your Google settings, or your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your QEA account using your Facebook, Google login, or Apple ID.
Personal data when you post comments about the QEA on other social media sites
If you have mentioned the QEA in posts on social media sites, then we may collect your social media handles. For example, when you mention the QEA in a tweet, we may collect your Twitter handle.
When you post publicly (comments) on our sites
When you post on a discussion board or comment publicly on an article on one of our sites, the personal data you post, including your username and other information about yourself, are publicly accessible. This personal data can be viewed online and collected by other people. We are not responsible for the way these other people use this personal data. When contributing to a discussion, we strongly recommend you avoid sharing any personal details, including information that can be used to identify you directly such as your name, age, address and name of employer. We are not responsible for the privacy of any identifiable information that you post in our online community or other public pages of the site.
How we collect personal data
We collect personal data when you:
- become a supporter or register for an account on queensenglishacademy.com
- make contributions to fund and support QEA
- pay for a subscription or purchase any other products/services
- attend our events
- enter our competitions and surveys
- sign up for our editorial emails
- post in our online community
- sign up for marketing communications
- use mobile devices to access our content
- access and interact with any of our sites and app
- through cookies and other similar technology
- when you contact us via email, social media, our apps or similar technologies or when you mention us on social media
How we use your personal data
We use personal data collected through our sites and apps only when we have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which we have collected your personal data.
Legal grounds for using your personal data
The legal ground may be one of the following:
- Consent: For example, where you have provided your consent to receive marketing emails from us. You can withdraw your consent at any time. In the case of marketing emails, you can withdraw your consent by clicking on the “unsubscribe” link at the bottom of the email or through your email preferences in the “emails and marketing” tab, when signed into your QEA account.
- Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a subscription from us and we need to use your contact details and payment data in order to process your order and deliver your subscription.
- Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
- Our legitimate interests: Where it is necessary for us to understand our readers, promote our services and operate our sites and apps efficiently for the creation, publication and distribution of news, media and related journalistic content both online and in print form, globally. Examples of when we rely on our legitimate interests to use your personal data include:
- when we analyze what content has been viewed on our sites and apps, so that we can understand how they are used and improve our content
- to carry out marketing analyses to better understand your interests and preferences so that we can make our marketing more relevant to your interests and preferences. This includes when we promote our own products and services. For example, we look at what you have viewed on our sites and apps and what products and services you have bought (including what you have looked at and what products or services you have bought on our other platforms, for example QEA SCHOOL). You can opt out from having your personal data used for marketing analyses by going into your account to the tab “emails and marketing”
- t0 show you personalized advertising by identifying your interests and to create “segments” of particular types of audiences so that we may show you advertisements that may be more relevant to your interests and the ‘’segments’’ you may be in. These ‘’segments’’ are also used to inform the building of custom audiences so that we can identify our audience across third party websites, such as social media platforms like Facebook.
- for internal administrative purposes related to when you use our services – such as our accounting and records – and to make you aware of any changes to our services
- to collect and log IP addresses to improve the website and monitor website usage
- to personalize our services (for example, so you can sign in) by remembering your settings, and recognizing you when you sign in on different devices
- enabling you to share our content with others using social media or email
- when responding to your queries and to resolve complaints
Access permissions when you are using the QEA app
When you use the QEA app, we ask for the following permissions to access particular functions of your mobile device:
- For the Android version, we ask for permission to access your contact details/profile on your mobile device, so that we can add or find your QEA account on your phone. We also ask for permission to access the storage on your mobile device, so that you can store content and read when offline
- For the iOS version, we ask for permission to save pictures to your photo library, so that you can save pictures that you find in our articles on your mobile device
Updating your personal data and your profile page on our sites
When you register for an account with queensenglishacademy.com, you have access to a profile page. Under “edit profile” you can review and update what personal data is public when you comment on our articles, or if people look up your profile.
You may also update your marketing preferences in the “emails and marketing” tab in your account.
Personal data that we receive about you from other organizations
Adding to or combining the personal data you provide to us
When you sign up to our services, we may add to the personal data you give us by combining it with other personal data shared with us by other trusted organizations. This includes, for example, the region that you are located in, so that we can show you the prices for subscriptions or other products in your local currency. We may also add personal data to improve the accuracy of your delivery address when we send out mail. We may also obtain your personal data from partners whose offers we include in some of our marketing communications and we use this personal data to ensure that we do not send you irrelevant marketing.
Personal data shared by event partners
When you register or book a ticket for a QEA event organized by an event partner, your registration data may be shared with us by the event partner.
Using children’s personal data
We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal data about children under 13. Some of our services may have a higher age restriction and this will be shown at the point of registration. We also note that California law prohibits sale of personal data of consumers between 13-16 years of age unless the legal guardian has authorized the sale. We comply with this requirement.
Security of your personal data
We have implemented appropriate technical and organizational controls to protect your personal data against unauthorized processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending any information, including personal data, via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.
When we share or use your personal data
Within the QEA group of companies
Depending on where you live, we may share your personal data within the QEA group of companies in the CHINA, US, or UK. We may share it in order to perform a contract with you, for administrative purposes, or when we have a legitimate interest in doing so. For example:
- If you book an event held in Australia, at first, we may hold your data on our systems in the UK and then we may share it with the QEA in Australia for administration purposes
- If you are going to one of our events hosted by an event partner, we may share your personal data with that partner for event administration purposes
- Sometimes we may receive a letter, email or another form of communication from you that we consider to be significant to the history of the QEA. We may decide to share this with the QEA Share Foundation run by the QEA company for historic and archiving purposes
- We may share your data to understand how you interact across our group products or to tailor and offer relevant advertising to you.
With external organizations
We share your personal data with other organizations that are not directly linked to us under the following circumstances:
Service providers – We may share your data with other organizations that provide services on our behalf. We may do this to perform a contract we have entered into with you, where it is in our legitimate interests or with your consent. Examples of when we may share your data with service providers include sharing with:
- companies that help deliver advertisement and subscription vouchers, such as Mailchimp
- online payments processors who process credit and debit card transactions on our behalf
- fraud management providers that help us to identify and prevent online fraud
- internet and cloud hosting services providers, such as Ali Cloud
- life-cycle engagement platforms such as Braze, to help us build and manage our campaigns
- software service providers such as Salesforce that assist us with our customer relationship management
- communications services providers, such as our online meeting service provider called Zoom
- error tracking software providers, such as Sentry and Google Firebase, to help us diagnose and fix errors and optimise the performance of our website and apps
- service providers that help us carry out analytics, facilitate audience creation and segmentation and to measure our audience engagement.
- service providers that help provide us with insights and analytics that help us to improve our products and services. For example, we use Google Analytics to understand how visitors engage with our sites or apps. If you don’t want Google Analytics to be used in your browser, you can install the ‘Google Analytics Opt-Out Browser Add-On’, provided by Google
- data management companies, such as but not only Formstack, that help us collect data via online forms and surveys
Agencies and authorities if required by law – We may reveal your personal data to any law enforcement agency, court, regulator, government authority, or in connection with any legal action if we are required to do so to meet a legal or regulatory obligation, where the request is proportionate, or otherwise to protect our rights or the rights of anyone else (for example, in response to valid and properly served legal process such as subpoena or warrant). We will attempt to notify you prior to disclosing your data unless (i) prohibited by applicable law from doing so, or (ii) there are clear indications of unlawful conduct in connection with your use of GNM services.
Event sponsors and partners – we may share your personal data with sponsors of QEA events and partners who we hold events with for marketing purposes when you have given your permission for us to do so.
Social media organizations – We may share your personal data with other organizations when our web pages use social plug-ins from these organizations (such as the “Facebook Recommend” function, Twitter’s retweet function, Weibo+ function or Wechat Moments). These other organizations may receive and use personal data about your visit to our sites or apps. If you browse our site or view content on our apps, personal data they collect may be connected to your account on their site. For more information on how these organizations use personal data, please read their privacy policies.
Any organizations which access your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards.
International data transfers
Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure similar protection and put in place at least one of these safeguards:
- We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data.
- We may also use specific approved contracts that use Standard Contractual Clauses for the protection of personal data where appropriate, with our service providers that are based in countries outside the EEA, including those based in the CHINA, US and UK. These contracts give your personal data the same protection it has in the EEA.
If you are located in the EEA, you may contact us for a copy of the safeguards which we have put in place for the transfer of your personal data outside the EEA.
How long we keep your personal data
How we may contact you
From time to time, we may send you service emails, for example, telling you your subscription is coming to an end or thanking you when you contribute or place an order with us.
Marketing communications and editorial newsletters
If we have your permission, we may send you materials we think may interest you, such as new QEA offers and updates. Depending on your marketing preferences, this may be by email, phone, SMS or post.
We offer a range of editorial newsletters. You can manage your subscription to these emails through your profile page when you are signed in to your QEA account.
You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email or through your email preferences in the tab “emails and marketing” when you are signed in to your QEA account.
Sometimes we may contact you for market research purposes, for example about a survey. You can opt out from being contacted in this way by signing into your QEA account and going to the tab “emails and marketing”.
Responding to your queries or complaints
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
Cookies and similar technologies
When you visit our sites or when you use our apps, we may collect personal data from you automatically using cookies or similar technologies. A cookie is a small file that can be placed on your device that allows us to recognize and remember you.
Contact us for information about how we use your personal data
If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact the Data Protection Officer at Queen’s English Academy Limited, Brighter Place, 88 This is the Way, Shenzhen 518000. Or, email email@example.com.
Complaints will be dealt with by the Data Protection Team, and will be responded to within 30 days.
If you are not satisfied with the way your concern has been handled, you can refer your complaint to the Information Commissioner’s Office.
If you have a question about anything else, please see our Contact us page here.
- 26 February 2021