Privacy Policy
1.0 Introduction
We are committed to safeguarding the privacy of our students and users of the website; in this policy we will explain how we handle and process your data.
In this section we explain what personal data we collect and why we collect it
2.0 Account Data
We may process your student membership sign-up and website account data (“account data”). The account data may be processed for the purposes of operating our website, providing you with our services, ensuring the security of our websites and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and school or learning business.
We may process any of your personal data identified in the other provisions of this policy where necessary in the event of a legal case, to cover the establishment, exercise or defence of any legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, the protection and assertion of our legal rights, your legal rights and those of others.
We may process your personal data set out under this policy where such processing is necessary for compliance with a legal obligation in Switzerland to which we are subject, or where it is clearly ordered to protect your vital interests or the vital interests of another person.
Disagreements between students in online classes or inappropriate behavior in group forums or posts deemed offensive are subject to the judgement and decision of action taken by the school moderation team. Those moderating groups, classes, forums and posts or comments reserve the right to use your account data to resolve any disagreement.
2.1 Class, student, exercise activity, messages, comments and feedback
When students, teachers or website visitors leave comments on The Boston School GmbH website we collect the data shown in the comments forms, email sign-ups, reviews, comments, lesson and class workflows as well as forum or group posts. This is in addition to the website visitor’s IP address and browser user agent string which is processed specifically for spam and security risk detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/.
After approval of your comment or post, your profile picture is visible to the public in the context of your comment in some cases. At other times it is visible only to fellow class attendees or school staff. The legal basis for this processing of messages, comments and feedback is our legitimate interests, namely monitoring, trying to safeguard and improve the school website and services.
2.2 Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. We request you avoid uploading images of family which can prompt another member or visitor to the website downloading the image(s) and extracting any location or your personal data from the images on the website.
2.3 Cookie Policy – Contact forms, class or event registrations and email newsletter sign-up forms
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last between 1 day and to a maximum of one year. Please clear your browser cache to remove active cookies so they can be renewed on a future visit.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for approximately two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks or more depending upon your browser settings. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 2 days.
2.4 Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
3.0 Analytics
We may process data about your use of our group website and its services (“usage data”). The usage data may include your browser type and version, referral source, IP address, geographical location, type of device, operating system, length of visit, page views and website navigation paths, as well as other information about the pattern of your services you use. The source of the usage data is from our analytics and security tracking system. This usage data may be processed for the purposes of analysing the use of the school website and its classes, learning materials, events, website student list and other services. The legal basis for this processing is our legitimate interests, to ensure as safe a website as possible by monitoring and improving our websites and services.
4.0 Who we share your data with and how long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue. For users that register on our school online learning site or for an event (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
We may process your personal data and use of our services (“services data”). The services data may be processed for the purposes of providing such member services as newsletters, ensuring the security of our group website, its functionality, the maintaining of back-ups of our databases and for communicating with you.
The legal basis for this processing is our legitimate interests, to apply best efforts to work for the proper administration of the group website and its business.
4.1 Classes, Online Learning, Events, Directory and any Membership Subscriptions or other purchases
We may process information relating to orders or other transactions related to the purchases of services, that you enter into with us and/or through the school website. This data (“transaction data”) may be processed for the purpose of supplying the requested ordered services and for keeping proper records of those transactions. No payment is processed by the group website, payments are requested by Bank, Post or through a third-party system such as Stripe or Paypal as chosen by you. The legal basis for this processing is the performance of a contract between you and us for a learning service, membership subscription , an event payment or another service. Steps taken at your request, to enter into such a contract and our legitimate interests, namely that we process and administer in a proper way our website and business. Offline payments are available on request for those seeking to pay directly using a IBAN and personal or company reference as invoiced.
4.2 Newsletters, mailshot, group social media platforms and email communications
We may process information that you provide to us for the purpose of subscribing to our newsletters, joining a social media group such as Facebook and for other notifications. This newsletter and email data (newsletter and messaging data) may be processed for the purposes of sending you the newsletters and other notifications, and analysing their use. The legal basis for this processing is consent and acceptance that we can reach out to you regarding school matters, updates, offers and informational language communications.
5.0 Providing your member or personal data to others
If you make an enquiry seeking information, class materials or need to message another student to seek information, advice, support or to assist you with a school offering or service, we may disclose your enquiry data to one or more third parties for the sole purpose of enabling them to respond, to provide support or to answer your request in a more specific way. The result of your request may be a quotation or information, or to market and/or sell to you a related or relevant professional service(s). Every endeavour is made to ensure you are informed by the school of such communication. We may disclose your personal data to other students or those managing an event insofar as reasonably necessary for the purposes of obtaining confirmations, management, feedback, attendance or other related activities and follow-up.
5.1 Financial transactions relating to our websites and services
A student offer or subscription or learning service or event which require the explicit need to be handled by payment services providers such as Stripe or PayPal, Eventbrite or others. We will share transaction data with the payment services providers only to the extent necessary for the purposes of processing your payments, any school related refunding of such payments, dealing with complaints and queries relating to any such payments and refunds. You can find information about the payment services providers’ privacy policies and practices on their websites. All payments paid by students for non-school events fall under the responsibility of the person or third party offering the event, service and they indemnify against any loss The Boston School GmbH, its staff, managers, shareholders and those conducting activities on behalf of the school.
6.0 International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside Switzerland and the European Economic Area (EEA).
6.2 The servers of the website host, Geo-Directory and others are in the U.K. and Europe. Some of the plug-in, security and other Internet and software cloud services are backed-up or supported from the USA. This includes cloud services and server providers Amazon, MailChimp® (email service) trademark of The Rocket Science Group and others. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission and applicable Swiss Data regulations where possible.
6.3 You acknowledge and accept that personal data that you submit for publication as comments, posts or through our group website or services may be available, via the Internet, around the world. We at The Boston School GmbH cannot prevent the use (or misuse) of any such personal data by others.
7.0 Retaining and deleting personal data
7.1 Our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Any personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.2 We will retain your personal data for the duration of your membership and at the end of the following periods it will be deleted:
(i) usage data will be retained in accordance with current legal requirements on the website server host in accordance with their terms and conditions. Personal, class interactions, comments, group or forum posts will be retained until either the conversation is deleted by the person making it, it is no-longer required as a group post or as part of a back-up of the website for a period of at least 12 months after the account is closed.
(ii) in the case of a dormant account, all information will be deleted from the profile 24 months after the last date of activity and the request to close the account is sent. The Boston School GmbH does not want dormant accounts or ones requiring archive, hence the sending of the request to close to the last known active email account of the member profile.
(iii) publication and transaction data will be retained for the period of publication or for any transaction for a period as stated in the third-party payment platforms who could retain it for up to 7 years following the date of your last transaction with them.
(iv) newsletter data will be retained for so long as the relevant person remains opted-in to notifications; and notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your interests or the interests of another natural person.
Your rights
8.1 Your rights under data protection law include:
- the right to access;
- the right to resolution and rectification;
- the right to erasure;
- the right to restrict processing;
- the right to complain to a supervisory person in the The Boston School GmbH and to withdraw consent.
- You have the right to receive confirmation as to actions taken, that data was rectified or erased at your instruction. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data upon request. The first copy will be provided free of charge, but any additional copies will be subject to a reasonable administration fee.
- You have the right to the erasure of your personal data without undue delay. Those circumstances include the closure of your account, your data being deemed to be obsolete or subject to archive, you withdraw consent or request to unsubscribe.
Requests will not be complied with in all circumstances because of certain exclusions, where processing or data retention is subject to legal obligation.
8.2 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing or event suggestion purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.3 The online lesson sign-up, any subscription membership sign-up, email newsletter sign-up and telephone or messaging contact assume the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
Re-direct urls or links to third party websites
Our school website includes hyperlinks to other website pages, Google analytics and maps and third-party websites. Many links are posted in class comments, forums, post comments and The Boston School GmbH has no control over, and is not responsible for, the privacy policies and practices of these third parties.
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our websites is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
10: Any Subscription renewal and updating information
Upon renewal of any membership subscription, sign-up for lessons, update of your personal information, we request a check of your existing information and ask you to let us know if the personal information that we hold about you needs to be corrected or updated. Much can be self-managed however we can support you with any key or fundamental changes.
11: Browser use and website experience
Many browsers control the user experience and their settings may block or allow flash, cookies and other components required to have a positive website user experience. The methods for controlling add-ons and settings vary from one browser to another.
You can however obtain up-to-date information about your browser by visiting the support resources:
- https://support.google.com
- https://support.mozilla.org
- https://support.microsoft.com
- https://support.apple.com
12. Amendments
We may update this policy from time to time by publishing a new version on our website and will advise you of any significant changes to this policy by email.
13.You can contact The Boston School GmbH by email info@thebostonschool.com or by using the school website contact form