1. Introduction
Gira Vinter English Learning ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us in any way.
By using our website or services, you consent to the practices described in this Privacy Policy. If you do not agree with this policy, please do not use our website or services.
2. Information We Collect
2.1 Personal Information
We may collect the following types of personal information:
- Contact Information: Name, email address, phone number, mailing address
- Academic Information: English proficiency level, learning goals, educational background
- Course Information: Course enrollment details, progress reports, attendance records
- Payment Information: Billing address, payment method details (processed securely through third-party providers)
- Communication Records: Emails, messages, and other communications with our staff
2.2 Technical Information
We automatically collect certain technical information when you visit our website:
- Device Information: IP address, browser type, operating system, device identifiers
- Usage Data: Pages visited, time spent on pages, click-through rates, referral sources
- Cookies and Tracking: Session cookies, preference cookies, analytics cookies
2.3 Information from Third Parties
We may receive information about you from third parties, such as:
- Social media platforms when you interact with our social media accounts
- Marketing partners and referral sources
- Public databases and directories
3. How We Use Your Information
We use your personal information for the following purposes:
3.1 Service Provision
- Provide English language courses and educational services
- Process course registrations and manage student accounts
- Deliver course materials and track academic progress
- Facilitate communication between students and instructors
3.2 Communication
- Respond to inquiries and provide customer support
- Send course updates, schedules, and important announcements
- Deliver newsletters and educational content (with your consent)
- Notify you about new courses, services, or promotional offers
3.3 Business Operations
- Process payments and manage billing
- Improve our services and develop new offerings
- Conduct research and analytics to enhance learning outcomes
- Ensure security and prevent fraud
3.4 Legal Compliance
- Comply with applicable laws and regulations
- Respond to legal requests and government inquiries
- Protect our rights and the rights of our students
4. Information Sharing and Disclosure
We do not sell, rent, or lease your personal information to third parties. However, we may share your information in the following circumstances:
4.1 Service Providers
We may share information with trusted third-party service providers who assist us in:
- Payment processing and billing services
- Email marketing and communication platforms
- Website hosting and technical support
- Analytics and performance monitoring
- Customer relationship management
4.2 Legal Requirements
We may disclose your information when required by law or when we believe in good faith that disclosure is necessary to:
- Comply with legal obligations or court orders
- Protect and defend our rights and property
- Prevent or investigate possible wrongdoing
- Protect the safety of our students, staff, or the public
4.3 Business Transfers
In the event of a merger, acquisition, or sale of all or part of our business, your information may be transferred to the new owner as part of the transaction.
5. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:
- Encryption: Sensitive data is encrypted both in transit and at rest
- Access Controls: Limited access to personal information on a need-to-know basis
- Regular Audits: Periodic security assessments and updates
- Staff Training: Regular privacy and security training for all employees
- Incident Response: Established procedures for handling security breaches
However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.
6. Your Rights and Choices
You have the following rights regarding your personal information:
6.1 Access and Correction
- Request access to the personal information we hold about you
- Request correction of inaccurate or incomplete information
- Update your contact preferences and account settings
6.2 Data Portability and Deletion
- Request a copy of your personal information in a portable format
- Request deletion of your personal information (subject to legal requirements)
- Withdraw consent for processing (where applicable)
6.3 Marketing Communications
- Opt out of marketing emails by clicking unsubscribe links
- Update your communication preferences in your account settings
- Contact us directly to modify your preferences
6.4 Cookies and Tracking
- Manage cookie preferences through our cookie banner
- Adjust browser settings to control cookie acceptance
- Opt out of third-party analytics tracking
7. Data Retention
We retain your personal information only as long as necessary for the purposes outlined in this Privacy Policy or as required by law:
- Student Records: Maintained for 7 years after course completion for academic record purposes
- Marketing Data: Retained until you opt out or withdraw consent
- Website Analytics: Typically retained for 26 months
- Communication Records: Retained for 3 years for customer service purposes
- Financial Records: Maintained for 7 years in accordance with accounting requirements
8. International Data Transfers
Your information may be transferred to and processed in countries other than Singapore. When we transfer information internationally, we ensure appropriate safeguards are in place to protect your personal information in accordance with applicable data protection laws.
9. Children's Privacy
Our services are primarily designed for adults and students over 16 years of age. We do not knowingly collect personal information from children under 16 without parental consent. If we become aware that we have collected information from a child under 16, we will take steps to delete such information promptly.
10. Third-Party Websites
Our website may contain links to third-party websites. This Privacy Policy does not apply to those websites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party websites you visit.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by:
- Posting the updated policy on our website
- Sending an email notification to registered users
- Displaying a prominent notice on our website
Your continued use of our services after any changes indicates your acceptance of the updated Privacy Policy.
12. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
We will respond to your inquiry within 30 days of receipt.
