Privacy statement summary:
|Who will use my data?||Witega Ltd. trading as Examagram|
|What for?||We will store and process your data in order to allow us to provide our ‘English testing services’ to you which in this document will be commonly referred to as ‘products and/or services’. We may also send you offer details that we think you will be interested in. This may include a range of our related products and services. We may also use your data to process financial products and services. We will only process your data in relation to financial service with your explicit consent.|
|What will happen if I contact you?||If you contact us we will use your information send you the information you have requested and updates, offers and other information that we think you will be interested in.|
|What data will be stored?||We will store your personal details in order to provide our services to you. We will store details of purchase enquiries, purchases, and related financial information as required.|
|What data will be shared?||We will not share your data with any third parties other than as described here. We will share your information with any regulator or legal body that requests it.|
|How long?||Your data will be stored only for 7 years after which time your data will be deleted.|
|Who can access my data?||We will never sell, share or otherwise distribute your data to any other third party.|
|How is my data kept secure?||We will store your data on secure UK based servers which will be processed in the UK. We use industry standard security protocols/technology to secure data.|
We take your privacy seriously and will only use your personal information to provide the products and services you have requested from us and to send you information about products and services you may be interested in. We will never sell, share or use your personal information other than as described here.
This policy sets out how we will use and share the information that you give us. This policy describes your relationship with Witega Ltd. trading as Examagram.
The General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principals. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than is necessary
- Processed in accordance with the rights of the data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area, unless that country or territory also ensures an adequate level of protection
We take these responsibilities seriously, this document describes our approach to data protection.
This policy helps to protect us from data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Who we are and how to contact us
Examagram is a trading name of Witega Ltd. that is registered in UK and is registered with the Information Commissioner’s Office. The data controller is: Kristan POLLEY. You can contact us in any of the following ways:
Email: [email protected]
Phone: 01772 217800
Post: Witega Ltd, 27 – 29 North Street (First Floor), Brighton, United Kingdom, BN1 1EB
Witega Ltd. trading as Examagram is an English Language Testing Services. This policy relates to users of Witega Ltd. trading as Examagram. Processing of your data is required in order to offer you these services. This policy applies to individuals who have shared their data or data they process with Witega Ltd. trading as Examagram as either a customer, employee, supplier or in any other capacity.
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
- Names of Individuals
- Postal addresses
- Email Addresses
- Telephone numbers
What this policy applies to
This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:
- The Information you provide when you contact us
- When you contact us in order to discuss using our services
- Information we collect about how you use the website
- Information relating to products and services we offer to you and other transactions including financial and other personal information required to complete these transactions
- Information that is given and stored as part of our ongoing relationship
We do not collect or process sensitive data about you.
How your information will be used
We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new customer||(a) Identity, (b) Contact||(a) Performance of a contract with you|
|To process and deliver the products and services you request including managing payments, fees and charges, and to collect and recover money owed to us||(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications||(a) Performance of a contract with you, (b) Necessary for our legitimate interests to recover debts owed to us|
|To process and deliver the products and services to you requested by a third party who you have given permission or has permission to process your data||(a) Identity, (b) Contact, (e) Marketing and Communications||(a) Performance of a contract with you|
|To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity, (b) Contact, (c) Technical||(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, (b) Necessary to comply with a legal obligation|
|To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising||(a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical||Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical, (b) Usage||Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile||Necessary for our legitimate interests to develop our products/services and grow our business|
We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), product and service details, purchase history and data collected as part of any finance application or payment (including previous addresses, employment details and bank account details). We may take personal information from:
- Information that you provide to us when registering with our website (including your email address)
- Information that you provide when completing your online profile (including your name, gender, date of birth and any educational details and employment details you provide)
- Information that you provide to a third party who uses us as a service (including your name, email address and employment details)
- Information that you provide to us when signing up to any distribution lists to receive correspondence from us
- Information relating to any purchases you make of our goods or services, including any other transaction details made via any of our websites (including your address, telephone number and payment details)
Personal data we receive will be used for the purposes it was provided, including:
- To respond to queries from you regarding the possible purchase of goods or services
- To carry out our obligations arising from any contracts entered into between you and us including the provision of services, and to respond to queries from you regarding those contracts
- To carry out our obligations arising from any contracts entered into between us and our users who process your data, including the provision of services, and to respond to queries from them regarding those provisions of service which may include your data
- To manage and administer the relationships between you and us
- To notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us
- To obtain feedback from you regarding us
In accordance with your preferences, we may also use your personal information to provide you with information about products, services, promotions and offers that may be of interest to you. We may use your personal information in order to ascertain the services, promotions and offers that are likely to be of particular interest to you. This document explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any purchases you make or services you use.
How to change your preferences
We operate in line with EU GDPR (May 2018) data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office. Any requests or objections should be made in writing to the Data Controller or you can visit our website, call, or email us to contact us to change your preferences at anytime.
Scope of agreement
We may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about goods and services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.
Opting out at a later date
Where you give your consent for us to process your data, for example when you agree to us sending you marketing information or where you agree to us processing financial data, you can contact us to amend or withdraw your consent at anytime. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please contact us.
How we store and process your data
Your data will be collected stored and processed primarily in the UK and North Macedonia. When data is transferred outside of the UK or the EU we will ensure we protect the data to the same level as you would expect for data stored within the UK and within the EU. Your data will be stored for up to 7 years to ensure we have records of service, payments, and other interactions we have with you.
In order to provide our services to you, we use recognised third parties to take payment, conduct credit reports and other checks, manage our company accounts and provide banking services. We will store transactions, payment and order data for up to 7 years or for as long as required by UK financial and company regulations. These third parties may operate outside the EU, if this is the case we will ensure precautions are in place to protect your data.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
You will only receive marketing communications from us if you have:
- Requested information from us, purchased goods or services from us or signed up to use our service in any way
- Provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications
- Not opted out of receiving marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Our Article 27 EU Representative
If you are based in the EU you can contact us via our EU Representative at:
Company Name: Instant EU GDPR Representative Ltd
Name: Adam Brogden
Email: [email protected]
Tel: + 353 15 549 700
EU Address: INSTANT EU GDPR REPRESENTATIVE LTD 69 Esker Woods Drive, Lucan Co. Dublin, Ireland
We are a data controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR (2018) in the way we use and share your personal data. Among other things, this means that we will only use your personal data:
- Fairly and lawfully
- As set out in the legislation and this policy
- To the extent necessary for these purposes
- We will take steps to ensure your data is accurate and rectify data as necessary
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may have to share your personal data with the parties set out below for the purposes described in this document:
- Service providers who provide IT and system administration services.
- Our clients / customers in order to meet our obligations to them, however this is always with your consent.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We use a number of compliant third parties to provide our services, including [but not limited to]:
|Amazon – AWS
|AWS||https://aws.amazon.com/privacy/||USA – Global storage||Privacy shield
EEA specific terms
|Microsoft – Azure||Cloud hosting services||https://www.microsoft.com/en-gb/trust-center/privacy||USA – Global storage||https://azure.microsoft.com/en-gb/overview/trusted-cloud/|
|Invoice management and processing||https://www.chargify.com/privacy-policy/||USA||Privacy shield
Security information reviewed.
|Stripe||Payment processing||https://stripe.com/gb/privacy||Global||Privacy shield
Transfers – https://stripe.com/gb/privacy
|Hubspot||CRM||https://legal.hubspot.com/privacy-policy||Ireland and/or USA||Privacy shield and DPA –
|Mailchimp||Email marketing and user updates||https://mailchimp.com/legal/privacy/||USA||Privacy shield|
|Docusign||Document signature management||https://www.docusign.co.uk/company/privacy-policy||Outside EEA||Binding corporate rules – https://www.docusign.com/trust?_ga=2.206988048.2042348260.1611239719-1058278533.1600777889
Privacy shield – https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
|Apple||icloud services||https://www.apple.com/uk/legal/privacy/en-ww/||Outside EEA||SCCs
|Hello Sign||Document signature management||https://gb.hellosign.com/privacy||Outside EEA||Binding corporate rules –
|Woo Commerce||Online shop platform||https://automattic.com/privacy/||Outside EEA||https://woocommerce.com/gdpr/|
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
We use a number of cookies to provide our services, including [but not limited to]:
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
|__cfduid||Used by the content network, Cloudflare, to identify trusted web traffic.||examagram.com||HTTP||29 days|
|To help facilitate purchases from the Woo Commerce platform||examagram.com||HTML||Persistent|
|wc_fragments_#||To help facilitate purchases from the Woo Commerce platform||examagram.com||HTML||Session|
Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
|ss||Necessary for the functionality of the website’s chat-box function.||va.tawk.to||HTTP||Session|
Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
|_dc_gtm_UA-#||Used by Google Tag Manager to control the loading of a Google Analytics script tag.||examagram.com||HTTP||1 day|
|_ga||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||examagram.com||HTTP||2 years|
|_gid||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||examagram.com||HTTP||1 day|
|This cookie is used to count how many times a website has been visited by different visitors – this is done
by assigning the visitor an ID, so the visitor does not get registered twice.
|_hjFirstSeen||This cookie is used to determine if the visitor has visited the website before, or if it is a new visitor on the website.||examagram.com||HTTP||1 day|
|_hjid||Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes.||examagram.com||HTTP||1 year|
|_hjid||Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes.||examagram.com||HTML||Persistent|
|_hjIncludedInPageviewSample||Determines if the user’s navigation should be registered in a certain statistical place holder.||examagram.com||HTTP||1 day|
|collect||Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across de vices and marketing channels.||google-analytics.com||Pixel||Session|
|TawkConnectionTime||Allows the website to recoqnise the visitor, in order to optimize the chat-box functionality.||examagram.com||HTTP||Session|
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
|ads/ga-audiences||Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor ‘s online behaviour across websites.||google.com||Pixel||Session|
Under the GDPR, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).
Contacting us, exercising your information rights and complaints
If you remain dissatisfied then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:
Information Commissioner’s Office
End of document.