SCULIN ONLINE LANGUAGE EDUCATION

DATA PROTECTION POLICY

(UK GDPR & Data Protection Act 2018 Compliant)

Effective Date: 11.03.2025

Last Updated: 14.03.2025

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1. Introduction

Sculin Online Language Education ("Sculin," "we," "our," or "us") is committed to protecting the personal data of our students, parents, tutors, and employees, following the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This policy explains how we collect, use, and safeguard personal data.

2. Principles of Data Protection

We adhere to the following principles to ensure that personal data is:
✔️ Processed lawfully, fairly, and transparently
✔️ Collected for specified, explicit, and legitimate purposes
✔️ Limited to what is necessary for processing
✔️ Accurate and kept up to date
✔️ Stored securely and retained only as long as necessary
✔️ Processed with integrity and confidentiality

3. Personal Data We Collect

We may collect and process the following categories of personal data:
- Identity Data: Name, surname, date of birth, nationality.
- Contact Data: Email address, phone number, home address.
- Educational Data: Student learning progress, language preferences, test scores.
- Financial Data: Payment details (processed through third-party providers, not stored by us).
- Technical Data: IP address, browser type, and website usage data.

4. Legal Basis for Processing Data

We process personal data under the following lawful bases:
- Consent: When you voluntarily provide your data (e.g., registering for a course).
- Contractual Obligation: When data is necessary to provide our services.
- Legal Obligation: When required by law.
- Legitimate Interest: To improve our services and security.

5. How We Use Personal Data

We use personal data for the following purposes:
✔️ To provide and manage language education services.
✔️ To communicate with students, parents, and tutors.
✔️ To process payments and manage accounts.
✔️ To improve our services and user experience.
✔️ To comply with legal and regulatory obligations.

6. Data Storage and Retention

We retain personal data only as long as necessary for:
- Service provision and contractual obligations.
- Compliance with legal and tax requirements.
- Business and security purposes.
After the retention period expires, data is securely deleted or anonymized.

7. Data Security Measures

We implement the following security measures:
- Encryption & pseudonymization of sensitive data.
- Access controls to restrict unauthorized access.
- Regular security audits and data protection training for employees.
- Secure data storage systems to prevent breaches.

8. Data Subject Rights

Under UK GDPR, you have the following rights:
✔️ Right to Access: Request a copy of your personal data.
✔️ Right to Rectification: Request correction of inaccurate data.
✔️ Right to Erasure: Request deletion of your data.
✔️ Right to Restrict Processing: Limit how we use your data.
✔️ Right to Data Portability: Obtain a copy of your data in a structured format.
✔️ Right to Object: Object to processing for marketing purposes.
✔️ Right to Withdraw Consent: If processing is based on consent.
✔️ Right to Complain: Lodge a complaint with the ICO (Information Commissioner's Office) if you believe we have mishandled your data.

9. Sharing Personal Data

We do not sell or rent personal data. We may share data with:
- Educational Partners & Tutors: To provide language lessons.
- Payment Processors: Secure payment transactions.
- Legal Authorities: If required by law.
- Service Providers: For IT, hosting, and security services.

10. International Data Transfers

If we transfer personal data outside the UK, we ensure appropriate safeguards are in place, such as:
✔️ UK Standard Contractual Clauses (SCCs)
✔️ Adequacy decisions by the UK government
✔️ Encryption and security protocols.

11. Data Breach Management

In the event of a data breach:
- We will assess the impact and take corrective actions.
- We will notify affected individuals and the ICO if necessary.

12. Contact Information

For data protection inquiries, contact us at:
📧 Email: info@sculin.com
📍 Address: Headquarters, Trafalgar Way Bar Hill, Cambridge, CB23 8SQ, United Kingdom

13. Updates to This Policy

We may update this policy periodically. Any changes will be posted on our website, and significant updates will be communicated to users.
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Sculin Online Language Education is committed to protecting your personal data and ensuring compliance with the UK GDPR & Data Protection Act 2018.