PRIVACY POLICY

INTRODUCTION

This policy (“Privacy Policy”) is intended to be read along with the Impact Academy site Terms of Service. It is also incorporated by reference in the Terms of Service. The terms "we", "us", "our", and “GVI” refer to GVI World Limited, a limited company, and its subsidiaries and affiliates.


We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about the privacy rights that may apply to you and how the law protects you. You must accept the Terms of Service as well as this Privacy Policy in order to use the site and Service. Please note that the Terms of Service and this Privacy Policy are subject to change. Any changes to the Privacy Policy will be made available on this webpage.


PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how GVI, and in certain cases collects and processes your personal data through your use of this website, including any data you may provide through this website when you use the Service, such as when you fill out a form or otherwise provide your personal data through this site.


This website is not intended for children and we do not knowingly collect data relating to children. If you are below the age of 16 then you must have your parent’s or legal guardian’s consent to submit any personal data at all. We will promptly delete any personal information relating to minors where we are informed that parental or guardian consent has not been granted. Should you be a concerned parent or guardian of a minor who has submitted their personal data without your consent please write to our Data Protection Officer for assistance.


CONTROLLER

This Privacy Policy is issued on behalf of the GVI family of companies so when we mention GVI, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the GVI family of companies responsible for processing your data. The Company controlling your data when you use the Service is GVI World Limited. Experiential Education Employees Pty Ltd processes your data on behalf of GVI World Limited in the provision of the Service. There are also additional processors or sub-processors associated with the cloud-based services and other information services used in providing the Service. 


By using the Site or the Services, you are authorizing us to gather and retain data related to the provision of the Site and Service as per this Privacy Policy.


THIRD-PARTY LINKS

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 Policy of every website you visit.
 

CONTACT INFORMATION

If you have any further questions about this Privacy Policy or our privacy practices please contact us on the details below.
 
The Data Protection Officer
GVI World Limited
1 Emperor Way, Exeter Business Park, Exeter, EX1 3QS
Email address: dpo@gviworld.com
 

THE DATA WE COLLECT ABOUT YOU

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).
 
We may collect, use, store and transfer different kinds of personal data about you. Some of the data may constitute Personal Information only when combined with personal identifiers. We have grouped the data for your reference as follows:

  • Identity Data may include first name, maiden name, last name, or similar identifier where applicable.

  • Contact Data may include email address, phone numbers, addresses (physical, postal or billing).

  • Technical Data may include internet protocol (IP) address, 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 site.

  • Usage Data may include information about how you use our website, products and services.

  • Marketing and Communications Data may include your preferences in receiving marketing from us and our third parties and your communication preferences.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
 

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. In this case, we may have to cease provision of the Services and terminate your contract with us. We will notify you of this in advance should it ever arise.
 

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

 

  • Direct interactions. You may give us your identity and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: request to be contacted; request marketing to be sent to you; provide any other personal data to us directly by post, phone, email or in person, respond to a survey or enter into our promotions and competitions, engage with us via social media.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties (and public sources) as set out below:
    - Technical Data from the following parties:
    (a) analytics providers such as Google Analytics
    (b) advertising networks such as Google Adwords, Facebook and Bing

     

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we have been requested to do so by your entering your personal data on a contact form on the site

  • Where we need to perform the contract we are about to enter into or have entered into with 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 or regulatory obligation.
    Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We will only collect and process personal data about you where we have one or more lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, vital interests and where relevant “legitimate interests”.
 

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.:
 

PROMOTIONAL OFFERS FROM US

You will receive marketing communications from us if you have opted to do so while requesting other information from us or when registering for and or using the Service.
 

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the GVI family of companies for marketing purposes.
 
OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by using the unsubscribe link included in the footer of all marketing messages. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of registering on the site or Service or enrolling in a Course.
 

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
 

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.
 

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes of providing services to you or performing our contract with you.
 

  • Suppliers: such as web hosting services, and other entities we work with in order to fulfill any contract with you.

  • Third-party vendors: who provide services or functions on our behalf, such as credit card processing, business analytics, support and fraud prevention. Such vendors are not permitted to share or use the information for any other purpose other than performing the specific functions they provide.

  • 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 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 only permit them to process your personal data for specified purposes and in accordance with our instructions.

  • Where required by law: there may be circumstances where disclosure is required by law. In such instances we may process and disclose your personal data to comply with the legal request received.

  • Social Media and Similar websites: in some instances the site may you to post information to social media sites. Please familiarise yourself with the privacy policies of these social media sites. We do not control their use of data shared with them.

  • Where your express consent is given: we may disclose your information with your consent. Such consent may be withdrawn by you by contacting us.

 

To California Residents: We do not rent, sell, or share Personal Information about you with third parties who are not our partners or affiliates for their own direct marketing purposes unless you have opted in to such a disclosure or were offered the opportunity to opt out of such a disclosure at the time you provided your Personal Information and elected not to opt out.

Please note that third parties may, however, collect personal information about your online activities over time and across different websites when you visit our Site or use the Service.


INTERNATIONAL TRANSFERS

Users based in the European Union are advised as follows: 


GVI has operations in various locations across the world including all the international locations where the practical component of the Impact Academy are offered. As part of the process of performing our contract with you your personal data may be transferred outside the European Economic Area (EEA). This could include places whose laws may provide for a lesser standard of protection for your personal data than that provided under European Law. In order to meet the data protection standards of European Law we will only transfer your data using one of the safeguards listed below.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it via at least one of the following safeguards:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

  • Where we use service providers based in the US (such as Amazon Web Services), we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the European Union and the US. For further details, see European Commission: EU-US Privacy Shield.

  • We ensure your personal data is protected by requiring our entire family of companies to follow the same rules when processing your personal data. Transfers to suppliers and partners based outside the EEA may also be required. Suppliers and partners are required to adhere to the same standards as GVI when dealing with personal data.

 


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.


DATA RETENTION AND INFORMATION SECURITY
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Depending on the laws applicable to you in your region, in some circumstances you can ask us to delete your data.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
 
Though we do our best to protect your information, transmission of information via the internet is not completely secure, and we cannot guarantee our security measures. We are not responsible for any unauthorized access to or acquisition of your information.
 

YOUR LEGAL RIGHTS

 

Users based in the European Union are advised as follows:
 
Under certain circumstances, you have rights under data protection laws in relation to your personal data.


You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


If you wish to exercise any of the rights set out above, please Contact us.


NO FEE USUALLY REQUIRED

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.
 

WHAT WE MAY NEED FROM YOU

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.
 

TIME LIMIT TO RESPOND

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.
 

GLOSSARY
LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

COOKIE POLICY

Information about our use of cookies

This Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. By continuing to browse the Site, you are agreeing to our use of cookies.

 

A cookie is a small file placed onto your device that enables our site’s features and functionality. Cookies are common and won't do anything to harm your device - they simply store or gather information. They help you to get the most out of your visit to our Websites. 

 

We may collect information about your computer including, where available, your IP address, operating system and browser type for system administration as part of our audit trail process. Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that. You are not obliged to accept cookies and you can adjust your browser's setting to prevent it from accepting cookies on your computer - go to www.allaboutcookies.org for instructions on how to disable cookies. However, you may not be able to take full advantage of our Websites if you do so. 

We use the following cookies: 

 

  • Strictly necessary cookies. These are cookies that are required for the normal operation of our Site. 

  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. 

  • Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. 

 

Tracking Options and California Do Not Track Disclosures. You may adjust your browser or operating system settings to limit this tracking or to decline or delete Cookies, but by doing so you may be unable to access or use certain areas of the Websites. Check the “Help” menu of your browser or operating system to learn how to change your tracking settings or Cookie preferences. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.


Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.


You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) the site may not perform as expected.

IMPACT ACADEMY

225 Franklin Street, 26th Floor, Boston, MA, 02110 
Learning Provider Number (LPN): 10002692
Centre Number: 17067

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617 674 1635

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