PRIVACY POLICY

1. Introduction

The Career Academy respects your privacy and is committed to protecting your personal data in accordance with our obligations under the General Data Protection Regulation ((EU) 2016/679) and the Data Protection Act 2018 (referred to in this privacy policy as “Data Protection Law”). This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. For the purpose of this policy, the term “websites” shall refer to all websites owned by The Career Academy. This privacy policy aims to give you information on how the Career Academy collects and processes your personal data through your use of our services and this website including any data you may provide through this website or by email or call when you avail of our service. We encourage our future and current students to read our privacy policy.

2. Who we are

The Career Academy is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy policy). Contact details Full name of legal entity: THE CAREER ACADEMY INTERNATIONAL LIMITED. If you have any questions about this privacy policy or our privacy practices, please contact us via email at [email protected]. You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues (https://www.dataprotection.ie/). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

3. Scope of the policy

 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

4. The Data we collect about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, date of birth, phone number, email, and gender.
• Contact Data includes address, email address and telephone numbers [and next-of-kin contact details].
• Financial Data includes bank account and payment card details.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website and our services.
• Transaction Data includes details about payments from you and other details of other services you may have availed of.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Technical Data to calculate the number of users in a specific territory or region. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. Special Categories of Personal Data is personal data of a particularly sensitive nature, and includes information concerning a person’s health, sexual orientation, or their religious and philosophical beliefs.  Due to the nature of our work, we may handle your health information and other special categories of personal data when carrying out our services and functions.  For the purpose of this privacy policy, the types of personal data detailed in this paragraph are referred to as “Sensitive Data”. Like all other types of personal data, we only handle Sensitive Data when we have a lawful basis for doing so (as described in more detail in section 4 below) and strictly in compliance with all of our obligations under Data Protection Law. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (to provide our services to you). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

5. How we collect information

We use different methods to collect data from and about you including through: Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise.

• When you complete surveys, contests or promotions, request support or otherwise communicate with our staff.
• When you give us feedback.
• When you refer someone to us.
• When you request marketing or other information from us,

Third Parties We may receive personal data about you from certain third parties in circumstances including:

• Contact and Identity Data from third parties who obtain contact details of potential students through social media and online or print advertising as lead providers of potential students who would like to study a course with The Career Academy
• Contact and Identity Data, Financial Data from your employer or entity who is discharging the fee to partake in our services.
• Technical Data from analytics providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We use cookies to see where the most interaction is on our websites so we can improve our services. We collect information predominantly through Google services such as Google Analytics. These services provide information about website users such as their general location, estimated age, what devices are used and which pages are accessed. This information is generalised and does not provide us with personal information about users.

6. How we use your personal data

 We will only use your personal data when we have a lawful basis to do so. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract to deliver services to you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Most commonly, we will use your Sensitive Data in the following circumstances:

• Where it is necessary for the purpose of delivering the service that we have agreed to provide to you.
• Where you have consented to us using your Sensitive Data for specified purposes.

Where consent is the lawful basis we rely upon to handle your personal data, you may withdraw such consent at any time free of charge. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new student	The Career Academy [email protected]	To provide you with the best course for your needs.
To respond to queries, schedule any calls necessary and provide support	Student Services [email protected] Tutors [email protected]	To provide you support for your course
To provide appropriate services to you and to monitor your academic performance	Student Services [email protected]	Information about the progress of your course
To process and deliver our service: (a) Manage payments, fees and charges (b) Collect money owed to us	The Career Academy Payment Services [email protected]	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you (or whomever paid the fees for our service on your behalf) which will include: (a) Notifying you about changes to our terms and conditions or privacy policy (b) Asking you to leave a review	The Career Academy [email protected]	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to monitor how clients use our services)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	The  Career Academy [email protected]	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security.) (b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	The  Career Academy [email protected]	Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, client relationships and experiences	The  Career Academy [email protected]	Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	The  Career Academy [email protected]	Necessary for our legitimate interests (to develop our services and grow our business)

Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from us We may use your Identity, Contact, Technical and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. Opting out You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at [email protected] with the subject line containing the word ‘unsubscribe’. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase of a service, warranty registration, service experience or other transactions. Change of purpose 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. Disclosure of your personal data

We may share your personal data with third party service providers who perform services and functions at our direction and on our behalf.  Such third-party services providers may include administrative service providers, accountants, legal advisers, IT service providers, financial services service providers, payment service providers, debt collection agencies and security services providers engaged by us as well as providers of financial services to offer you payment plans. We also engage other education providers who offer services that we do not provide. Where we use an education third-party provider, this is explicitly stated on our websites. We may share your personal data with your employer or the person who paid the fees for our services on your behalf. We may share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the confidentiality and security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions. Police force, government or quasi-government bodies, courts and tribunals We may share your personal data with these organisations and bodies where we are required to do so by law. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the safety of any person. Testimonials We may request our students who are happy with our services to leave a review of our services. Content from such reviews may be posted on our website, including the student’s name and their testimonial. If you would like this removed, please email [email protected]. Referrals If you decide to refer a friend to us please contact that friend and tell them about us. If that friend then decides they would like to hear from us, we will contact them as requested, providing they have given us their consent to contact them.  If your friend does not wish us to retain their personal information, they can have it removed by emailing [email protected].

8. International transfers

We might transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as an area that provides for an equivalent level of protection for personal data as is provided for in the European Union. If, and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission. If you would like to receive further details of the measures that we have taken in this regard, please contact us at [email protected]

9. Data security

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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period if we have a legitimate interest in retaining such information that is not outweighed by your fundamental rights and freedoms, where we have statutory or regulatory obligations to retain personal data for a longer period, or where we may need to retain the information in the event of a legal claim. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

11. Your legal rights

You have a number of rights under data protection law in relation to how we use your personal data.  These include the right, free of charge, to:

• Be informed about the personal data we hold about you and how we use that information.
• Obtain access to your personal data we hold.
• Have any personal data that we hold about you that you believe is incorrect, incomplete or inaccurate updated or corrected.
• Have your personal data erased.
• Have our processing of your personal data restricted.
• Object to our processing of your personal data.
• Request the transfer of your personal data to you or to a third party.
• Not be subject to wholly automated decisions, including profiling, which produce legal effects or which could have a similarly significant effect on you.
• Lodge a complaint with the Data Protection Commission.

These rights are in some circumstances limited by law.  If you wish to exercise any of these rights, you can contact us using the details set out in section 1. We endeavour to respond to all legitimate requests within one month.  Occasionally it could 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.

12. Updates

We may update this privacy policy from time to time.  Any updates will be made available and, where appropriate, notified to you.