Privacy Policy

1. Introduction

Faint Gleam ("we," "our," or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website faint-gleam.com or use our IELTS preparation services.

This policy applies to all information collected by Faint Gleam through our website, email communications, and in-person interactions. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site or use our services.

2. Information We Collect

2.1 Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Register for our IELTS preparation courses
• Contact us through our website or email
• Subscribe to our newsletter
• Participate in surveys or feedback forms
• Visit our physical location

This information may include:

• Full name and contact details (address, email, phone number)
• Date of birth and nationality
• Educational background and English language proficiency level
• IELTS target scores and test dates
• Payment information (processed securely through third-party providers)
• Emergency contact information

2.2 Automatically Collected Information

When you visit our website, we may automatically collect certain information about your device and browsing behaviour, including:

• IP address and browser type
• Operating system and device information
• Pages visited and time spent on our website
• Referring website and search terms used
• Cookies and similar tracking technologies

3. How We Use Your Information

We use the information we collect for the following purposes:

• Service Delivery: To provide IELTS preparation courses, assess your needs, and track your progress
• Communication: To respond to your enquiries, send course updates, and provide customer support
• Administration: To process payments, maintain records, and manage our business operations
• Marketing: To send newsletters, course promotions, and educational content (with your consent)
• Improvement: To analyse usage patterns and improve our website and services
• Legal Compliance: To comply with applicable laws and regulations
• Safety and Security: To protect against fraud and ensure the safety of our students and staff

4. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

• Contract: To perform our contractual obligations in providing IELTS preparation services
• Consent: When you have given explicit consent for marketing communications or cookies
• Legitimate Interests: For business operations, fraud prevention, and service improvement
• Legal Obligation: To comply with legal requirements and regulations

5. Information Sharing and Disclosure

We do not sell, trade, or otherwise transfer your personal information to third parties except in the following circumstances:

• Service Providers: Trusted third parties who assist us in operating our website and conducting business (e.g., payment processors, email service providers)
• Legal Requirements: When required by law, court order, or government regulation
• Business Transfer: In the event of a merger, acquisition, or sale of assets
• Consent: When you have given explicit consent for specific disclosures
• Safety: To protect our rights, property, or safety, or that of our users or others

6. Data Security

We implement appropriate technical and organisational security measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive data in transit and at rest
• Regular security assessments and updates
• Access controls and staff training
• Secure payment processing through PCI DSS compliant providers
• Regular backups and disaster recovery procedures

However, please note that no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

7. Your Rights

Under GDPR and UK data protection laws, you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you
• Rectification: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your personal data in certain circumstances
• Restriction: Request limitation of processing in certain situations
• Portability: Request transfer of your data to another organisation
• Objection: Object to processing based on legitimate interests or for marketing purposes
• Withdraw Consent: Withdraw consent for specific processing activities

To exercise these rights, please contact us at [email protected] or use the contact details provided below.

8. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. Specifically:

• Student Records: Maintained for 7 years after course completion for academic and administrative purposes
• Marketing Data: Retained until you unsubscribe or withdraw consent
• Website Analytics: Typically retained for 26 months
• Financial Records: Retained for 6 years as required by UK law

9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience. For detailed information about our use of cookies, please refer to our Cookie Policy.

10. Third-Party Links

Our website may contain links to third-party websites, social media platforms, or services. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

11. International Data Transfers

Your personal information may be transferred to and processed in countries outside the UK and EEA. When we transfer data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or adequacy decisions by the relevant authorities.

12. Children's Privacy

Our services are intended for individuals aged 16 and above. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information promptly.

13. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. Your continued use of our services after any changes constitutes acceptance of the updated policy.

14. Contact Information

If you have any questions, concerns, or requests regarding this privacy policy or our data practices, please contact us:

15. Supervisory Authority

If you believe we have not handled your personal data in accordance with this policy or applicable data protection laws, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection:

Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Website: ico.org.uk
Phone: 0303 74 1113