1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of
our website visitors and service users; in other words, where we determine the purposes and means
of the processing of that personal data.
visit our website.
1.4 Our website incorporates privacy controls which affect how we will process your personal data.
By using the privacy controls, you can specify whether you would like to receive direct marketing
communications and limit the publication of your information.
1.5 In this policy, “we”, “us” and “our” refer to Infinity Learning Limited.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific
categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data
may include your IP address, geographical location, browser type and version, operating system,
referral source, length of visit, page views and website navigation paths, as well as information
about the timing, frequency and pattern of your service use. The source of the usage data is our
analytics tracking system. This usage data may be processed for the purposes of analysing the use of
the website and services. The legal basis for this processing is our legitimate interests, namely
monitoring and improving our website and services.
2.3 We may process your account data (“account data“). The account data may include your name
and email address. The source of the account data is you or your employer. The account data may be
processed for the purposes of operating our website, providing our services, ensuring the security of
our website and services, maintaining back-ups of our databases and communicating with you. The
legal basis for this processing is our legitimate interests, namely the proper administration of our
website and business.
2.4 We may process your information included in your personal profile on our website (“profile
data“). The profile data may include your name, address, telephone number, email address, profile
pictures, gender, date of birth, relationship status, interests and hobbies, educational details and
employment details. The profile data may be processed for the purposes of enabling and monitoring
your use of our website and services. The legal basis for this processing is our legitimate interests,
namely the proper administration of our website and business.
2.5 We may process information contained in any enquiry you submit to us regarding goods and/or
services (“enquiry data“). The enquiry data may be processed for the purposes of offering,
marketing and selling relevant goods and/or services to you. The legal basis for this processing is
2.6 We may process information relating to our customer relationships, including customer contact
information (“customer relationship data“). The customer relationship data may include your name,
your employer, your job title or role, your contact details, and information contained in
communications between us and you or your employer. The source of the customer relationship
data is you or your employer. The customer relationship data may be processed for the purposes of
managing our relationships with customers, communicating with customers, keeping records of
those communications and promoting our products and services to customers. The legal basis for
this processing is consent OR our legitimate interests, namely the proper management of our
2.7 We may process information relating to transactions, including purchases of goods and services,
that you enter into with us and/or through our website (“transaction data“). The transaction data
may include your contact details. The transaction data may be processed for the purpose of
supplying the purchased goods and services and keeping proper records of those transactions. The
legal basis for this processing is the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract and our legitimate interests, namely the proper
administration of our website and business.
2.8 We may process information that you provide to us for the purpose of subscribing to our email
notifications and/or newsletters (“notification data“). The notification data may be processed for
the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this
processing is consent
2.9 We may process information contained in or relating to any communication that you send to us
(“correspondence data“). The correspondence data may include the communication content and
metadata associated with the communication. Our website will generate the metadata associated
with communications made using the website contact forms. The correspondence data may be
processed for the purposes of communicating with you and record-keeping. The legal basis for this
processing is our legitimate interests, namely the proper administration of our website and business
and communications with users.
2.10 In addition to the specific purposes for which we may process your personal data set out in this
Section 3, we may also process any of your personal data where such processing is necessary for
compliance with a legal obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person.
2.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our
subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary
for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as
reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing
risks, obtaining professional advice, or the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably
necessary for proper administration of our website and business and communications.
3.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose
your personal data where such disclosure is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital interests of another
4. Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help
ensure that we comply with our legal obligations in relation to the retention and deletion of
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is
necessary for that purpose or those purposes.
4.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where
such retention is necessary for compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of another natural person.
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We may notify you of significant changes to this policy by email.
6. Your rights
6.1 In this Section 6, we have summarised the rights that you have under data protection law. Some
of the rights are complex, and not all of the details have been included in our summaries.
Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a
full explanation of these rights.
6.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
6.3 You have the right to confirmation as to whether or not we process your personal data and,
where we do, access to the personal data, together with certain additional information. That
additional information includes details of the purposes of the processing, the categories of personal
data concerned and the recipients of the personal data. Providing the rights and freedoms of others
are not affected, we will supply to you a copy of your personal data. The first copy will be provided
free of charge, but additional copies may be subject to a reasonable fee.
6.4 You have the right to have any inaccurate personal data about you rectified and, taking into
account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances you have the right to the erasure of your personal data without undue
delay. Those circumstances include: the personal data are no longer necessary in relation to the
purposes for which they were collected or otherwise processed; you withdraw consent to consent-
based processing; you object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have been unlawfully
processed. However, there are exclusions of the right to erasure. The general exclusions include
where processing is necessary: for exercising the right of freedom of expression and information; for
compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.6 In some circumstances you have the right to restrict the processing of your personal data. Those
circumstances are: you contest the accuracy of the personal data; processing is unlawful but you
oppose erasure; we no longer need the personal data for the purposes of our processing, but you
require personal data for the establishment, exercise or defence of legal claims; and you have
objected to processing, pending the verification of that objection. Where processing has been
restricted on this basis, we may continue to store your personal data. However, we will only
otherwise process it: with your consent; for the establishment, exercise or defence of legal claims;
for the protection of the rights of another natural or legal person; or for reasons of important public
6.7 You have the right to object to our processing of your personal data on grounds relating to your
particular situation, but only to the extent that the legal basis for the processing is that the
processing is necessary for: the performance of a task carried out in the public interest or in the
exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by
us or by a third party. If you make such an objection, we will cease to process the personal
information unless we can demonstrate compelling legitimate grounds for the processing which
override your interests, rights and freedoms, or the processing is for the establishment, exercise or
defence of legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing
purposes (including profiling for direct marketing purposes). If you make such an objection, we will
cease to process your personal data for this purpose.
6.9 You have the right to object to our processing of your personal data for scientific or historical
research purposes or statistical purposes on grounds relating to your particular situation, unless the
processing is necessary for the performance of a task carried out for reasons of public interest.
6.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in
order to take steps at your request prior to entering into a contract, and such processing is carried
out by automated means, you have the right to receive your personal data from us in a structured,
commonly used and machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.
6.11 If you consider that our processing of your personal information infringes data protection laws,
you have a legal right to lodge a complaint with a supervisory authority responsible for data
protection. You may do so in the EU member state of your habitual residence, your place of work or
the place of the alleged infringement.
6.12 To the extent that the legal basis for our processing of your personal information is consent,
you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
6.13 You may exercise any of your rights in relation to your personal data by written notice to us.
7. About cookies
7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web
server to a web browser and is stored by the browser. The identifier is then sent back to the server
each time the browser requests a page from the server.
7.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be
stored by a web browser and will remain valid until its set expiry date, unless deleted by the user
before the expiry date; a session cookie, on the other hand, will expire at the end of the user
session, when the web browser is closed.
7.3 Cookies do not typically contain any information that personally identifies a user, but personal
information that we store about you may be linked to the information stored in and obtained from
8. Cookies that we use
9. Cookies used by service providers
9.1 We use Google Analytics to analyse the use of our website. Google Analytics gathers information
about website use by means of cookies. The information gathered relating to our website is used to
10. Managing cookies
10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for
doing so vary from browser to browser, and from version to version. You can however obtain up-to-
date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10.3 If you block cookies, you will not be able to use all the features on our website.
11. Our details
11.1 This website is owned and operated by infinity Learning Limited.
11.2 We are registered in Jersey with registered office
11.3 Our principal place of business is at at 3rd Floor, De la Poste House, 59 King Street, St Helier,
Jersey, JE2 4WE.
11.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.
12. Data protection officer
12.1 Our data protection officer’s contact details are:
3rd Floor, De la Poste House
59 King Street