Please see Section 10 for contact details of the Data Controller.
1. Information We Collect
There are three general categories of information we collect.
1.1 Information You Give to Us
1.1.1 Information that is necessary for the use of upenglishcamp.com.
We ask for and collect the following personal information about you when you use upenglishcamp.com. This information is necessary for the adequate performance of the contract between you and us, and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all requested services.
Communications with upenglishcamp.com:When you communicate with upenglishcamp.com, we collect information about your communication and any information you choose to provide.
Payment Information: To use certain features of upenglishcamp.com, we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
1.1.2 Information you choose to give us
You may choose to provide us with additional personal information in order to obtain a better user experience when using upenglishcamp.com. This additional information will be processed based on your consent.
You may choose to provide us with information when you fill in a form, respond to surveys, post to community forums, participate in promotions, or use other features of upenglishcamp.com.
1.1.3 Information that is necessary for the use of the Payment Services
The Payments Data Controller needs to collect the following information, as it is necessary for the adequate performance of the contract with you and to comply with applicable laws (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:
Payment Information: When you use Payment Services, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable laws.
Identity Verification and Other Information: The Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card, or driver’s license) or other authentication information, your date of birth, your home address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable laws.
1.2.Information We Automatically Collect from Your Use of upenglishcamp.com and Payment Services
When you use the upenglishcamp.com site and the Payment Services, we automatically collect data, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of upenglishcamp.com and Payment Services.
Geo-location Information: When you use certain features of upenglishcamp.com, we may collect information about your precise or approximate location as determined by data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. upenglishcamp.com may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
Usage Information: We collect information about your interactions with upenglishcamp.com such as the pages or content you view, your searches, bookings you have made, and other actions on the upenglishcamp.com site.
Log Data and Device Information: We automatically collect log data and device information when you access and use upenglishcamp.com. That information includes, among other things: details about how you’ve used upenglishcamp.com (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using upenglishcamp.com.
Payment Transaction Information: upenglishcamp.com collects information related to your payment transactions through upenglishcamp.com, including the payment method used, date and time, payment amount, payment method expiration date and billing postcode, IBAN information, your billing address and other related transaction details. This information is necessary for the adequate performance of the contract between you and upenglishcamp.com and to allow the provision of the Payment Services.
1.3. Information We Collect from Third Parties
upenglishcamp.com may collect information, including personal information, that others provide about you when they use upenglishcamp.com and the Payment Services, or obtain information from other sources and combine that with information we collect through upenglishcamp.com and the Payment Services. We do not control, supervise, or answer for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off upenglishcamp.com through partnerships, or about your experiences and interactions from our partner ad networks.
2. How We Use Information We Collect
We use, store, and process data, including personal information, about you to provide, understand, improve, and develop upenglishcamp.com, create and maintain a trusted and safer environment and comply with our legal obligations.
2.1. Provide, Improve, and Develop the upenglishcamp.com Platform
- Enable you to access and use the upenglishcamp.com site.
- Operate, protect, improve, and optimize the upenglishcamp.com experience, such as by performing analytics and conducting research.
- Provide customer service.
- Send you service or support messages, updates, security alerts, and notifications.
- If you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection.
- To operate, protect, improve, and optimize the upenglishcamp.com experience, and personalize and customize your experience (such as making Listing school suggestions or ranking search results), we conduct profiling based on your interactions with the upenglishcamp.com site, your search and booking history, your profile information and preferences, and other content you submit to upenglishcamp.com.
We process this information given our legitimate interest in improving upenglishcamp.com and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.
2.2. Create and Maintain a Trusted and Safer Environment
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide).
- Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required.
- Comply with our legal obligations.
- Resolve any disputes with any of our Members and enforce our agreements with third parties.
- Enforce our Terms of Service and other policies.
- In connection with the activities above, we may conduct profiling based on your interactions with upenglishcamp.com, your profile information and other content you submit to upenglishcamp.com, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to upenglishcamp.com if such processes detect a Member or activity that we think poses a safety or other risk to upenglishcamp.com, other Members, or third parties.
We process this information given our legitimate interest in protecting upenglishcamp.com, to measure the adequate performance of our contract with you, and to comply with applicable laws.
2.3. Provide, Personalize, Measure, and Improve our Advertising and Marketing
- Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about upenglishcamp.com or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google).
- Personalize, measure, and improve our advertising.
- Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by upenglishcamp.com or its third party partners.
- Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with upenglishcamp.com, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.
2.4. How the Payments Data Controller uses the Information Collected
- Enable you to access and use the Payment Services.
- Detect and prevent fraud, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Conduct checks against databases and other information sources.
- Comply with legal obligations (such as anti-money laundering regulations).
- Enforce the Payment Terms and other payment policies.
- With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
The Payments Data Controller processes this information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
3. Sharing & Disclosure
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your upenglishcamp.com or when you participate in promotional activities conducted by upenglishcamp.com partners or third parties.
Based on our legitimate interest to promote upenglishcamp.com we may display parts of upenglishcamp.com using technologies such as widgets or APIs. If your Listings of schools are displayed on a partner’s site, information from your public profile page may also be displayed.
Information you share publicly on upenglishcamp.com may be indexed through third party search engines. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
3.1. Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights
upenglishcamp.com may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against upenglishcamp.com, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of upenglishcamp.com, its employees, its Members, or members of the public.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping upenglishcamp.com secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.
Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon upenglishcamp.com’s property, its Members and upenglishcamp.com. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
3.2. Service Providers
upenglishcamp.com uses a variety of third party service providers to help us provide services related to the Payment Services. Service providers may be located inside or outside of the European Economic Area («EEA»). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.
upenglishcamp.com will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
3.3. Corporate Affiliates
To enable or support us in providing upenglishcamp.com, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.
Sharing with UP English Camp: Even if your Country of Residence is not the United States, your information may be shared with UP English Camp., which provides the technical infrastructure for upenglishcamp.com, product development and maintenance, customer support, trust and safety. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing upenglishcamp.com globally.
Sharing with Payments Services: In order to facilitate payments on or through the upenglishcamp.com site, certain information as described above in Section 1.1.3, may be shared with the relevant Payments Services entity. The data sharing is necessary for the performance of the contract between you and us.
Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve upenglishcamp.com and our affiliates’ services.
3.4. Social Media Platforms
Where permissible according to applicable law, we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or upenglishcamp.com. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you.
The social media platforms with which we may share your personal data are not controlled or supervised by upenglishcamp.com. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to said provider.
Please note that you may, at any time ask upenglishcamp.com to cease processing your data for these direct marketing purposes by sending an e-mail to firstname.lastname@example.org..
3.5. Business Transfers
3.6. Aggregated Data
We may also share aggregated information (information about our users that we combine so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. Other Important Information
4.1. Analyzing Your Communications
We may review, scan, or analyze your communications on upenglishcamp.com for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
These activities are carried out based on upenglishcamp.com’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
4.2. Google Maps/Earth
5. Third Party Partners & Integrations
upenglishcamp.com may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services («Third Party Partners»). upenglishcamp.com doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, upenglishcamp.com, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. Your Rights
You may exercise any of the rights described in this section before your applicable upenglishcamp.com Data Controller and Payments Data Controller by sending an email to email@example.com. Please note that we may ask you to verify your identity before taking further action on your request.
6.1. Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you in your upenglishcamp.com system.
6.2. Data Access and Portability
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.3. Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide upenglishcamp.com to you, you can request that we erase your personal information and close your upenglishcamp.com system. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, upenglishcamp.com may keep some of your information for tax, legal reporting and auditing obligations.
- Information you have shared with others (e.g., reviews) may continue to be publicly visible on upenglishcamp.com.
- Because we maintain upenglishcamp.com to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.4. Withdrawing Consent and Restriction of Processing
Where you have provided your consent to the processing of your personal information by upenglishcamp.com you may withdraw your consent at any time by sending a communication to upenglishcamp.com specifying which consent you are withdrawing.
Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of upenglishcamp.com override your own.
6.5. Objection to Processing
In some jurisdictions, applicable law may entitle you to require upenglishcamp.com not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, upenglishcamp.com will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may at any time ask upenglishcamp.com to cease processing your data for these direct marketing purposes by sending an e-mail to firstname.lastname@example.org.
6.6. Lodging Complaints
You have the right to lodge complaints about the data processing activities carried out by upenglishcamp.com before the competent data protection authorities.
7. Operating Globally
We will provide further information on the means to ensure an adequate level of data protection on request.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls.
10. Contact Us