Personal information means information about an identifiable individual or information that permits an individual to be identified. It does not include business contact information, such as name, title, business address and business telephone number when used for business communications.OUR COMMITMENT
Spires takes responsibility for maintaining and protecting the personal information under our control. We have appointed a data controller who can be contacted directly by the public who is responsible for our day to day compliance. We review this policy and our personal data protection practices regularly to ensure that we are in compliance with applicable legislation and current best practices. We do not knowingly collect any personal information from children under the age of 13 and the services offered by Spires are not intended for use by children.HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION
We only collect personal information as required to meet the purposes that we have identified. We do not indiscriminately collect or retain personal information.
Spires typically collects personal information that is voluntarily provided by the individual in question. At times, however, personal information is obtained from other sources, such as government bodies or third parties such as employers, references and service providers, as permitted by law. Where the purpose for the collection of personal information is unclear, you can ask the Spires representative with whom you are dealing to provide an explanation of the purpose for the data collection.
Our reason for collecting personal information about tutors, students, parents, staff and consultants is to establish and maintain our contractual or other business relationship with that individual.
The purpose for collecting personal information about tutors and students is primarily to facilitate the provision of educational tutoring services online, including to allow students to quickly and easily assess the professional and educational background of tutors, as well as allowing us to communicate effectively with our tutors, students and parents and to maintain mailing lists. We may also use your personal information to:• Respond to your comments, questions and requests and provide customer service;
As appropriate, Spires will ask for specific consent to collect, use and disclose personal information, including for the purposes of completing or arranging for the completion of background checks and other searches. Such a request, and your consent to such request, may be given in writing or orally. In some cases, consent can be implied through an individual relationship or conduct with us, depending on the sensitivity of the information.
DPA permits Spires to disclose personal information to third parties without the affected party’s knowledge or consent to certain parties. Accordingly, we may share personal information about you as follows:• with consultants and other service providers who need access to such information to carry out work on our behalf, including our legal advisors;
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
Personal information supplied to us is confidential and we do not disclose the information to any third party except with actual or implied consent, or as permitted or required by law. We do not exchange or sell personal information.
Spires may use third party service providers from time to time to carry out certain functions for us such as printing, storage, shredding or document scanning. Where we use such outside service providers, we require those third parties to protect personal information in the same manner in which we protect it and to not use or disclose it for any purposes except as directed by Spires. Spires recognizes that the European Union ("EU") and Switzerland have implemented omnibus data protection regimes established pursuant to the European Data Protection Directive (95/46/EC) and the Swiss Federal Act on Data Protection, respectively. Among other things, these laws require an "adequate level of protection" for the transfer of certain individually identifiable data about individuals in EU member countries and Switzerland to Spires' operations.PROTECTING YOUR PERSONAL INFORMATION
We strive to maintain personal information in as accurate, complete and up-to-date a form as necessary to fulfil the purposes for which it was collected. We protect personal information by security safeguards appropriate to the sensitivity of the personal information, regardless of format. Our security safeguards include premises security and restricted access to files containing personal information. Depending upon the information under our control, we also use technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access, internal passwords and security policies.INFORMATION WE COLLECT AUTOMATICALLY
We automatically collect certain information about you when you access or use our website or transact business with us, including:• Log Information: We collect information about your use of our websites, such as the type of browser you use, access times, pages viewed, your IP address and the referring link through which you accessed our websites.
To the extent that our website contains links to third party web sites. Spires is not responsible for the privacy practices or the content of such web sites nor does Spires warrant the quality, accuracy or completeness of information contained in these sites.ACCESSING YOUR PERSONAL INFORMATION
You may write to our Privacy Officer to request access to personal information about you. Spires will generally inform you if we are holding personal information about you, as well as details about the personal information. We reserve the right to confirm your identity before complying with any access request. In responding to an access request, we may charge a reasonable copying or retrieval fee, the amount of which we will provide in advance. Access to personal information may be denied if required or authorized by law. If a request for access is denied, Spires will provide an explanation of the reasons for the refusal. If you choose to withdraw your consent to continued collection, use or retention of your personal information, we will explain the consequences of such withdrawal. You may also challenge the accuracy of personal information about you in our custody and Spires will amend personal information where appropriate.HOW TO CONTACT US
If you have a concern about the personal information handling practices of Spires, a complaint, in writing, may be directed to our Privacy Officer. Upon verification of your identity, we will act promptly to investigate the complaint and respond within 60 days. Where our Privacy Officer makes a determination that a complaint is well founded, we will take the necessary steps to correct the offending information handling practice and/or revise the privacy policies and procedures of Spires. Where our Privacy Officer determines that a complaint is not well founded, the individual will be notified in writing of such determination.