At English Studies Institute, we are concerned about privacy and want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practice in connection with information that we collect through our web site, currently located at www.esi.edu (the “Site”). By downloading, accessing or using the Site, or providing information to us in connection with the Site, you implicitly agree to the terms and conditions of this Privacy Policy. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third-party, any third-party service providers, and any other third-party operating any software application or website to which the Site contains a link. The inclusion of a link within the Site does not imply endorsement by us of the linked software application or website. We may change this Privacy Policy at any time. Any changes to this Privacy Policy will become effective when we make the revised Policy available on or through the Site. Your use of the Site or the submission of any information through the Site following such changes means that you have accepted the revised Privacy Policy.
1.0 JURISDICTIONAL ISSUES
The Site is controlled by us from the United States of America (the "United States"); accordingly, this Privacy Policy, and our collection, use and disclosure of your information, is governed by United States law, and not the laws of any country, territory or jurisdiction other than the United States. We do not represent or warrant that the Site, or any functionality or feature thereof, are appropriate or available to us in any particular jurisdiction. Those who choose to download, access or use the Site do so on their own independent initiative and at their own risk; and are responsible for complying with all local laws, rules and regulations. By downloading, accessing, using or submitting any information to the Site, users from outside the United States acknowledge that this Site is subject to United States law, and consent to the transfer of their information to the United States and any other jurisdiction, which may provide a different level of data security than in their country of residence, and waive any claims that may arise under their own national laws.
2.0 PERSONAL INFORMATION
2.1 Personal information we may collect: “Personal Information” is information that identifies you as an individual. In addition to Personal Information, Other Information (as defined below) may be collected in connection with the Site; the collection, use and disclosure of Other Information is defined separately below, under the heading “OTHER INFORMATION”. We and our third-party service providers may collect the following Personal Information from you:
* Name
* Postal address
* Telephone number
* E-mail address
* IP address
We do not request, solicit or intend to collect any other personally identifiable information, and you should not disclose any such information to us in connection with the Site.
IF YOU SUBMIT ANY PERSONAL INFORMATION OF OR RELATING TO THIRD-PARTIES TO US OR OUR THIRD-PARTY SERVICE PROVIDERS IN CONNECTION WITH THE SITE, YOU REPRESENT THAT YOU HAVE THE LEGAL AND LEGITIMATE AUTHORITY TO DO SO.
2.2 How We May Use Personal Information:
We and our third-party service providers may use Personal Information:
* To respond to your inquiries and fulfill you requests, such as to send newsletters to you and operate the system.
* To send to you administrative information, including information regarding the Site and changes to our terms, conditions and policies
* For our business purposes, such as quality assessment, data analysis, audits, developing new products, improving the Services, identifying usage trends and determining the effectiveness of our Services.
* As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or governmental authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, service providers, you or others, including through credit-fraud protection and risk reduction; (g) to allow us to pursue available remedies or limit the damages that we may sustain.
2.3 How Personal Information My Be Disclosed:
* By you, through messages (including files, video, audio and text messages), chats, message boards, forums, public profile pages, user directories and blogs and other functionality with which you are able to share or post information and materials. Please note that any information and materials that you post or disclose using such functionality may be available for other users of the Site and the general public to other individuals or social networking sites such as, but not limited to, Facebook or YouTube. We are not responsible for such recording, access, use, alteration, manipulation or disclosure. We encourage you to be very careful and thoughtful when deciding to disclose your Personal Information, or any other information, in connection with the Site.
* To a third-party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding).
* As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or governmental authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, service providers, you or others, including through credit-fraud protection and risk reduction; (g) to allow us to pursue available remedies or limit the damages that we may sustain.
3.0 OTHER INFORMATION
3.1 Other Information We May Collect: “Other Information” is any information that does not reveal your specific identity such as: Browser information Server log files Statistics concerning messages (including files, video, audio and text messages) sent or received through the Site, such as the length of such messages, the IP Addresses involved and other technical parameters Information collected through cookies, pixel tags and other technologies Demographic information Aggregated information
3.2 How We May Collect Other Information: We and our third-party service providers may collect Other Information in a variety of ways, including, but not limited to:
* Through your device: Certain information is collected automatically through your device, such as your operating system name and version, device manufacturer and model, language, and the name and version of the software application you are using. We may also generate a unique device identifier for use by English Studies Institute to operate the Site.
* Through server log files: Your “IP Address” is a number that is automatically assigned to the device that you are using by your Internet Service Provider (the "ISP"). An IP Address is identified and logged automatically in our server log files whenever a user uses the Site, along with the time of the use and the pages of areas visited within the Site. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites. We and our third-party service providers use IP addresses for purposes such as helping to calculate usage levels of the Site, diagnose service problems and administer the Site.
* Using Cookies: Cookies allow a server to transfer data to devices for recordkeeping and other purposes. We and our third-party service providers use cookies and other technologies to, among other things, better serve you with better tailored information and facilitate your ongoing access to and use of the Site, as well as for online tracking purposes. If you do not want information collected through the use of cookies there is a simple procedure in most devices that allows you to decline the use of cookies. To learn more about cookies please visit allaboutcookies.org or a resource of your choice. If you choose to decline cookies, some of all of the features, functionality and promotions available through the Site may not be available to you.
* Google Analytics: To better serve our clients, we implement Google Analytics Demographics and Interest Reporting. We use this information to assist us in improving our website and in the content that we offer. Anyone can opt-out of analytics by visiting Google Analytics' currently available opt-outs for the web and utilize their plug-in.
* Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) and other similar technologies may be used in connection with some pages and areas of the Site and HTML formatted e-mail messages to, among other things, track the actions of users of the Site and e-mail recipients, measure the success of our internal campaigns and compile statistics about usage and response rates of the Site.
* Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what features or pages you viewed and other information we collect. In some instances you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we may not be able to provide you with applicable personalized services and content.
* From you: We may collect demographic information such as your location, as well as other information, such as your preferred means of communication, when you voluntarily provide such information to us. Unless combined with Personal Information, this information does not personally indentify you or any other user of the Site.
* By aggregating information: Personal Information does not personally identify you or any other user of the Site. For example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code.
3.3 How We May Use and Disclose Other Information: Because Other Information does not personally identify you, we may use and disclose Other Information for any purpose. In some instances, we may combine Other information with Personal Information (such as combining your zip code with your name). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is so combined.
4.0 SECURITY
We seek to use within the Site reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system is guaranteed to be one hundred percent (100%) secure. Please be aware that we may use third-party service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that are generally non-negotiable; accordingly, although we seek to conduct reasonable due diligence on such third-party service providers, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Personal Information. We are not, therefore, responsible for the data security measures of any third-parties. We seek to protect the Site from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold.
In particular:
* We review our information collecting, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
* We restrict access to Personal Information to our employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations.
4.1 Enforcement We regularly review our compliance with this Privacy Policy. We also adhere to several self regulatory frameworks. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “CONTACTING US” section noted below.
5.0 CHOICES AND ACCESS
You may opt-out of our disclosure of your Personal Information to any of our third-party partners by sending an email to us at privacy@esi.edu and include the words "Opt Out" in the subject line.
5.1 How you can access your Personal Information: If you would like to review or update your Personal Information that has been previously provided to us, you may do so by writing to our offices at 2600 Bancroft Way, Berkeley, CA, USA 94704 or by sending an email to privacy@esi.edu and ask for a copy of any personal information that we may have collected from from your accessing the Site. We will try to comply with your request to update your Personal Information as soon as reasonably practical. We are not responsible for changing information in the databases of third-parties with whom we have already shared your Personal Information.
6.0 RETENTION PERIOD We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.
7.0 CONTACTING US If you have any questions about this Privacy Policy, please contact us by sending an e-mail to info@esi.edu. Please note that information you submit through e-mail may not be secure; so please do not include any sensitive information in your communications to us.