Last updated 23 September 2009
1. Information that we collect from you
You can visit parts of this Site without telling us who you are or revealing any information about yourself. In order to visit other parts of this Site we may need to collect personally identifiable information in order for you to register on the Site, to enable you to use our online ordering service or to send you offers or information that you request. We may collect information from you through the use of online forms and through email, telephone, fax and mail correspondence which we have with you. The information collected from you may include but is not limited to:
Douglas Stewart Inc may:
- Your name, address, landline or mobile telephone numbers, fax number and e-mail address
- Company name and contact details
- Credit or debit card information
- Details of the ways in which you are happy to receive information from us and/or selected third parties
- Offer contests and other promotional activities that may require online registration. Persons wishing to participate in those activities will be asked to provide certain personal information. Some of the information requested for this purpose is optional, but other information, such as email address, is mandatory because it will be needed to notify and identify winners.
- Require the selection of a user ID and password for the use of some of its services or activities.
- Offer you the opportunity to receive email updates and announcements concerning our services and special promotions. Personal information you have provided to us may be used to facilitate those communications.
- Collect information about you from e-mails, letters, telephone calls, customer satisfaction forms or from any other communications you send to or have with us.
- Collect information from you in order to provide customised business information to you.
- Collect additional information automatically about your visit to our Site.
You will find that it is not compulsory to provide us with any additional information we request which is not necessary or reasonable in order to provide you with the services you have requested. Furthermore, please note that our policy is not to ask for sensitive personal data - that is, data relating to race or ethnic origin; political opinion; religious or other similar beliefs; trade union membership; physical or mental health; sexual orientation; criminal records. We recommend that you do not provide such information to us. If you choose to do so for any reason, this will mean that you have given (and we accept) your explicit consent for us to use that information for the reasons described in this policy, or as explained at the time you provide the information.
The personally identifiable information we collect may change from time to time, but can only be collected when you voluntarily give it to us.
In addition, we may track your domain name or IP address to assist our efforts to gather and track the information described above. For some computers, the IP address is a globally unique identifier of your computer. Multiple users of the same computer will share the same IP address. However, in most cases your ISP (or network server, if a business user) will allocate you an IP address only for the duration of your online session (about 80% of all surfers are using "temporary" IP addresses). This means that even when your IP address is noted, it is unlikely you will have the same IP address next time you use the internet. IP addresses are never shared with third parties.
2. Opt-In and Opt-Out
The Site always requires users to actively select that they wish to receive promotional communications from Douglas Stewart Edu Limited or its partners. We will never assume acceptance. Once our account and services systems are in place users will be able to opt-in or opt-out by adjusting their account preferences. Every promotional email sent out by Douglas Stewart EDU will contain instructions on removing that email address from lists for further mailings.
3. Use of information collected
Domain name information that we collect is not used to personally identify you and instead is aggregated to measure the number of visits, average time spent on the Site, pages viewed, etc. We use this information to measure the use of our Site and to improve its content.
When other personal information, such as your name and e-mail address, is collected from you with your consent (for example, through the use of on-line forms or via e-mail etc.) we generally let you know at the time of collection how we will use that personal information. We may also use the personal information you provide or which we collect via this Site for the purposes of:
- Providing any goods or services that you have requested from us.
- Billing you and contacting you where necessary concerning your orders.
- Responding to your inquiries or to process your requests in relation to your information.
- Providing and personalising our services generally.
- Administering records of our subscription services.
- Carrying out market research campaigns.
- Maintaining information as a reference tool or general resource.
- Making the site easier for you to use and providing you with access to all parts of the site.
- Helping you to quickly find services and information on the site.
- Where necessary, crime prevention and prosecution of offenders.
Except with your permission or as provided herein, Douglas Stewart Edu Limited will not sell, trade or rent personal information about you to unaffiliated third parties.
We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes or use and analyse the information we collect so that we can administer, support, improve and develop our business.
In particular, we may use your information to contact you for your views on our services and to notify you occasionally about important changes or developments to the Site or our services. Further we might also use your information to contact you by post, telephone, fax, or by e-mail (where you have consented to us doing so) to let you know about other products and services:
- Which we offer and which may be of interest to you.
- Which are offered by other companies within Douglas Stewart Edu Limited.
- Which are offered jointly with or on behalf of other organisations.
If you change your mind about being contacted in the future, please let us know.
By using the Site you consent to us using your personal information for the purposes described above.
Douglas Stewart Edu Limited may use "cookie" technology in the Site to collect anonymous traffic data to improve site usability. The cookie is never associated with any personally identifying information you may provide.
- Disclose personal information you have provided through our Site to persons or companies that we retain to carry out promotions and other activities for which you have registered or in which you have otherwise asked to participate.
- Pass aggregate information on the usage of our Site (e.g. we might disclose the numbers of visitors to our Site that come from different geographic areas) to third parties but this will not include information that can be used to identify you personally.
- Allow carefully selected third parties, including other companies in our group, to contact you occasionally about products and services which may be of interest to you. They may contact you by post, telephone or fax, as well as by e-mail. If you change your mind about being contacted by these companies in the future, please let us or them know.
Finally, if our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.
Countries outside the European Economic Area do not always have strong data protection laws. However, we will always take steps to ensure that your information is used by third parties in accordance with this policy.
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
6. Other Web Sites Not Covered
The Site may contain links to other web sites. Douglas Stewart Edu Limited does not control, and is not responsible for, the privacy practices or the content of such web sites. Please check with those web sites to determine their privacy policies.
7. Users 16 and Under
If you are aged 16 or under, please get your parent or guardian's permission before you provide any personal information to us. Users without this consent are not allowed to provide us with personal information.
8. Data retention, security of information collected, internet based transfers and disclaimer
We will retain your information for a reasonable period or as long as the law requires. In accordance with the UK's Data Protection Act 1998, we employ strict physical, electronic, and administrative security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both on-line and off-line.
Given that the Internet is a global environment, using the Internet to collect and process personal information necessarily involves the transmission of data on an international basis. Therefore by browsing this Site and communicating electronically with us, you acknowledge and agree to our processing of personal information in this way.
Whereas Douglas Stewart Edu Limited employs reasonable measures to protect against viruses and other harmful components, the nature of the internet is such that it is impossible to ensure that your access to the Site will be uninterrupted or error-free, or that this Site, its servers or emails which may be sent by us are free of viruses or other harmful components.
The contents of this Site are designed to comply with the general obligations of the European Directives on Data Protection and E-Privacy. We cannot be responsible for non-compliance with any local advertising or other laws in relation to this Site or its contents.
Data Protection Act 1998
According to the Government Data Protection web site:
"Processing" is broadly defined and takes place when any operation or set of operations is carried out on personal data. The Data Protection Act 1998 requires that personal data be processed "fairly and lawfully". Personal data will not be considered to be processed fairly unless certain conditions are met. A data subject must be told the identity of the data controller and why that information is to be processed.
Processing may only be carried out where one of the following conditions has been met:
- The individual has given his or her consent to the processing.
- The processing is necessary for the performance of a contract with the individual.
- The processing is required under a legal obligation.
- The processing is necessary to protect the vital interests of the individual.
- The processing is necessary to carry out public functions.
- The processing is necessary in order to pursue the legitimate interests of the data controller or third parties (unless it could prejudice the interests of the individual).
The European Union Privacy Directive
The European Union (EU) encourages the free movement of goods, people, services and capital throughout the Union. It recognises that facilitating this requires the free flow of data from one Member State to another, but also that "fundamental rights of individuals should be recognised". In October 1998 the EU adopted the Directive on Data Protection, which sets forth strict rules for companies which handle personal data about EU citizens.
The Directive instructs Member States to pass laws that specifically include the following terms:
- Companies must notify both employees and consumers about how information collected about them will be used.
- Companies can only use data for its intended purpose.
- Companies cannot transfer data on employees and consumers to countries with inadequate privacy protection laws.
- Consumers will have a right to access data collected about them.
- Consumers will have a right to have inaccurate data rectified.
- Consumers will have a right to know the origin of data about them (if this information is available).
- Consumers will have a right of recourse in the event of unlawful processing of data about them.
- Consumers will have a right to withhold permission to use their data (e.g. the right to opt-out of direct marketing campaigns for free without providing a reason).
- Companies need explicit permission of consumers to process sensitive information, including information on racial origin, political or religious beliefs, trade union membership, medical data, and sexual life.
Fundamentally this means companies must ask customers if they can collect personal data; disclose how any information will be collected and used; and provide customers with free access to data about themselves.
9. Accessing and updating
Under the Data Protection Act 1998, you are entitled to see the personal information we hold about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to correct or update the personal information that you have provided to us or if you choose to opt out of any communications that you may have initially agreed to receive, please contact us by e-mail on firstname.lastname@example.org. We are entitled by law to charge a small administrative fee to meet our costs in providing you with details of the information we hold about you and we may require proof of your identity before we supply the information to you.
10. Contacting the Web Site
11. Changes to this Policy