Privacy Policy – Macmillan International Curriculum

This is the privacy policy (“policy”) for this website which is run and provided by Springer Nature Ltd, The Macmillan Campus, 4 Crinan Street, London, N1 9XW UK, international.curriculum @macmillaneducation.com (we, us and our).

We will only use the personal data gathered over this website as set out in this policy. Below you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what control and information rights you may have.

I. Summary of our processing activities

The following summary provides you with a quick overview of the processing activities that are undertaken on our website. You will find more detailed information under the indicated sections below.

When you visit our website for informational reasons without setting up an account, only limited personal data will be processed to provide you with the website itself (see III).
In case you register for one our services (e.g. discussion forum, blog or web shop) or subscribe to our newsletter, further personal data will be processed in the scope of such services (see IV, V and VI).
Furthermore, your personal data will be used to provide you with interesting advertising for our services and products (see VIII) and for statistical analysis that helps us to improve our website (see IX). Additionally, we improve your website experience with third party content (see X).
We have implemented appropriate safeguards to secure your personal data (see XIII) and retain your personal data only as long as necessary (see XIV).
Under the legislation applicable to you, you may be entitled to exercise certain rights with regard to the processing of your personal data (see XV).

II. Definitions

Personal data: means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
Processing: means any operation which is performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation or any kind of disclosure or other use.

III. Informational use of the website

When you visit our website for informational reasons, i.e. without registering for any of our provided services listed under IV and without providing us with personal data in any other form, we may automatically collect additional information about you which will contain personal data only in limited cases and which is automatically recognised by our server, such as:

your IP address;
your device type, name and IDs;
the date and time of your requests;
the content of your requests;
information on your browser version;
your screen resolution;
information on your operating system, including language settings.

One of the methods we use to collect this information is via cookies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. On this Site, we use two kinds of cookies: session cookies and persistent cookies. Session cookies exist only for as long as your browser remains open. Once you close your browser, they are deleted. Persistent cookies, in contrast, last beyond each visit to the Site and remain on your hard drive after you close your browser. The cookies used on the Site include those that are strictly necessary cookies for access and navigation, and cookies that track usage (performance cookies) and remember your choices (functionality cookies). Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site.

We use such information only to assist us in providing an effective service (e.g. to adapt our website to the needs of your device or to allow you to log in to our website), and to collect broad demographic information for anonymised, aggregated use.

The personal data automatically collected is necessary for us to provide the website, Article 6 sec. 1 sent. 1 lit. b GDPR, and for our legitimate interest to guarantee the website’s stability and security, Article 6 sec. 1 sent. 1 lit. f GDPR.

Personal data that is collected automatically is retained for [1] months and properly erased afterwards.

IV. Registration for our services [only if applicable]

Our website offers a blog and submission forms. In order to use the aforementioned services you have to set up an account. With regard to the registration of an account and its subsequent use, we process: Provide the data you process.

Information (such as your name, user name and email address) that is provided by registration;
Information in connection with an account sign-in facility (e.g. log-in and password details);
Communications sent by you (e.g. via e-mail or website communication forms).
The information that is necessary for the performance of the service is labelled accordingly. All further information is provided voluntarily.

We will process the personal data you provide to: Provide the data you process.

Identify you at sign-in;
Provide you with the services and information offered through the website or which you request;
Administer your account;
Communicate with you;
(behavioural) Advertising and profiling

For this, the legal basis is Article 6 sec. 1 sent. 1 lit. b GDPR. [Addition: For any purpose that is not necessary for the performance of a contract (e.g. behavioural Advertising and profiling) state the legitimate interest that justifies processing. E.g.: The use of your personal data for behavioural advertising and profiling is done for the legitimate interest to improve your experience while using the website, Article 6 sec. 1 sent. 1 lit. f GDPR.]

We use the personal data and contact data you provide by registration to inform you directly about our additional products and services. The use of your personal data for directly advertising related products and services is a legitimate interest for us as a provider of this website, Article 6 sec. 1 sent. 1 lit. f GDPR.

You can object to the use of your personal data for direct marketing at any time. We will then refrain from any processing to the extent it is related to such purposes. You can inform us about your objection by contacting us at international.curriculum@macmillianeducation.com

[Additional function- notification service: For our [provide the relevant services, e.g. blog or discussion forum] we offer a notification service. If you chose this service while setting up your user account or posting your comment, you will receive a notification email when another user replies to the same topic or article. This service is provided by means of a double-opt-in. Thus, you will receive an email containing a link by which you can confirm that you are the owner of the email address and wish to be notified via our email service. You can end this service by opting out via the link provided in each notification email. This notification service is based on your consent, Article 6 sec. 1 sent. 1 lit. a GDPR.]

Your personal data is, in the absence of exceptions within the specific services mentioned below, retained for as long as your user account is used. After deletion of your account, your personal data will be erased [1] month later. Statutory storage obligations or the need for legal actions that may arise from misconduct within the services or payment problems can lead to a longer retention of your personal data. In this case, we will inform you accordingly.

V. Information about the specific uses that require registration

For the use of the following services you have to set up an account as described under IV. Your customer account retains your personal data for future purchases and other activity. You can delete the personal data as well as the account in your account’s settings. This processing is based on Article 6 sec. 1 sent. 1 lit. b.]

1. Use of our discussion forum [only if integrated into the website; please check if correct]

Our forum can be accessed and read without registration. Anything you post on the discussion forum will be available to a broader public; you can delete your posts at any point in time. In order to provide content to the forum, you will have to register as described in IV. You are not obliged to provide your real name but can use an alias or post as ‘anonymous’. However, our staff can see the email address of the user account linked to all comments.

You can delete your user account by requesting a deletion of your registered account on macmillanic.com – [please include action to be taken]. In case you decide to delete your user account, all your account data, including all communication will be deleted. Information posted by you into our discussion forum will remain visible, but any link to your person will be deleted. The unique username you selected during signup process will become available to other users upon deletion.

In addition to the extent of processing described under IV, when you post a comment we will retain your IP address – the email address linked to your account as long as the comment is hosted on the site. – [additional metadata, e.g. log time or time of posting] for [one week]. This is necessary to defend ourselves from possible liability claims that may arise from unlawful comments posted by you and reflects our legitimate interest with regard to the legal justification of this processing activity in Article 6 sec. 1 sent. 1 lit. f GDPR.

We reserve the right to delete comments that are off-topic, spam, abusive, use excessive foul language, include ad hominem attacks or offend against legal regulations.

Please see our Terms and Conditions or Term of Use for further details on what rights we hold around the user-generated content posted on our Site: [insert the link here]

2. Blog [only if integrated into the website]

You can publicly comment on our blog where we post a variety of articles to inform you about our activities. When posting a comment your user name will be made public. Therefore, we do recommend the use of an alias or post as ‘anonymous’. To be able to comment on our blog you will have to register as described in IV.

In addition to the extent of processing described under IV, when you post a comment we will retain your IP address [additional metadata, e.g. log time or time of posting] for [one week]. This is necessary to defend ourselves from possible liability claims that may arise from unlawful comments posted by you and reflects our legitimate interest with regard to the legal justification of this processing activity in Article 6 sec. 1 sent. 1 lit. f GDPR.

We reserve the right to delete comments that are off-topic, spam, abusive, use excessive foul language, include ad hominem attacks or offend against legal regulations.

3. Web shop [only if integrated into the website]

For the use of our web shop you have to set up an account as described under IV. Your customer account retains your personal data for future purchases. You can delete the personal data as well as the account in your account’s settings. This processing is based on Article 6 sec. 1 sent. 1 lit. b.]

By statutory law we are required to retain the provided financial data in relation to transactions (including address, payment and order information) for [ten years]. However, after [2] years we will restrict the processing of your personal data to comply with the statutory requirements and will not process the personal data any further. Regarding this, the retention of your personal data is based on Article 6 sec. 1 sent. 1 lit. c GDPR.

VI. Newsletter [only if integrated into the website]

With your email address you can subscribe to our newsletter that provides you with the latest news about our products and services if you consent to receiving such newsletters. The legal basis for this processing is Article 6 sec. 1 sent. 1 lit. a GDPR. Your email address will be retained as long as you subscribe to our newsletter. This service is provided by means of a double-opt-in. Thus, you will receive an email containing a link by which you can confirm that you are the owner of the email address and wish to be notified via our email service. When your subscription is not confirmed within [96] hours after the confirmation mail has been requested, the personal data you provided will not be processed for any purpose and it will be automatically erased.

You can unsubscribe from this service by opting out via the link provided in each newsletter.

~~VII. Automated decision making~~

~~We do not use your personal data for automated decision making which produces legal effects concerning you or similarly significantly affects you.~~

[Alternative, when automated decision making takes place:] We use your personal data to perform automated decision making [Addition, if applicable: including profiling]. These decisions are used to [provide the significance and envisaged consequences of such processing for the data subject] and are based on [provide the logic involved]. If the processing does not involve automated decision processing take this part off.

~~VIII. Online advertising [only if integrated into the website]~~

[In this section you can inform the user about the use of external online advertising providers such as Google AdSense or the Amazon affiliate program. Please note: Many of the providers offering online advertisement may potentially not comply with the GDPR stipulations. Thus, contracting with these provides bears potential risks.] —Take this part off-

This website uses the online advertising services of [provide service provider] to present you with ads that meet your interests. Respective advertisement is labelled as [provide, e.g. “Google-Ad”]. Additionally, this service helps us to improve our website and to make your visit more interesting. In order to do so, we collect statistical information about you that will be processed by [provider]. This processing is based on Article 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to improve your website experience and to promote our products and services.

~~[Provider] will be automatically informed about your visit on our website. For such purpose, a web beacon is used to place a cookie on your computer.~~

Please note that we neither have the control of the extent of personal data that is collected by the respective plug-in provider nor do we know the processing’s purpose or the period your personal data will be retained. [In case of third country transfer: Your personal data will be transferred to and processed in [provide, e.g. the United States]. For further information about the potential risks of a cross border data transfer refer to XII.] ]

~~It is possible that [provider] discloses your personal data to its business partners, third parties or authorities.~~

You can prevent the installation of such a cookie [provide solution: Examples for Google Ads: (i) by a respective setting of your browser that blocks the installation of third party cookies, (ii) by deactivating the [provider’s] interest-related advertising under http://www.google.de/ads/preferences, (iii) or generally blocking cookies under http://www.google.com/settings/ads/plugin].

Further information about the processing of your personal data in the provider’s course of operation is provided by its privacy policy. Moreover, you will be provided with further information with regard to your rights and settings concerning privacy. You can access the provider’s privacy policy by following this link [provide link]. Analysis [only if integrated into the website]

~~For statistical analyses we use web analytic services to collect information about the use of this site.~~

1. General Tracking information

The tool collects information such as

Page accessed, URL click stream (the chronological order of our internet sites you visited)
IP address
Time of visit
Device and browser information (operating system information, Mobile device identifier, mobile operating system, etc.)
geographic location, type of device accessed on etc.
Referring site, application, or service

We use the information we get from Google Analytics only to determine the most useful information you are looking for, and to improve and optimise this website. We do not combine the information collected through the use of Google Analytics with personal data.

Depending on the provider the information generated about your use of the website will be transmitted to and stored by Google Analytics on servers in the United States. For further information about the potential risks of a cross border data transfer refer to section XII. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or any other identifying information. The provider will use this information in order to evaluate your use of the website, to compile reports on website activities and to provide other services relating to website and internet use to us.

[Recommendable for EU users if you use Google Analytics: We have activated the IP-anonymisation within the Google Analytics service, and your IP address will be truncated within the area of member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. The IP-address your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google.]

The legal basis for this processing is Art. 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to analyse our website’s traffic to improve the user’s experience and to optimise the website in general.

2. Google Analytics / Google Tag Manager

We use Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). On our behalf Google will use the information generated by a cookie for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet activity in connection with the use of the website.

We have activated the IP-anonymisation within the Google Analytics service, and your IP address will be truncated within the area of member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. The IP-address your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser; however please note that if you do this you may not be able to use the full functionality of this website. In addition to that you may prevent the collection of the information generated by the cookie about your use of the website (including you IP address) and the processing of this data by Google if you download and install the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout

IX. Third party content and social media plug-ins [only if integrated into the website]

1. Social media plug-ins

We use the following social media plug-ins: Facebook, Twitter, Instagram and Linkedin. This allows you to communicate with such services and like or comment from our website. Social media plug-ins enable a direct communication between your device and the servers of the social media provider, allowing the social media provider to communicate with you and collect information about you browsing our website. This processing is based on Article 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to improve your website experience and to optimise our services.

Transfer of personal data takes places whether you have an account with the provider or not.

[In case of third country transfer:] Your personal data will be transferred to and processed in [provide, e.g. the United States, if you choose to use a plug-in provided by AddThis that is based outside of the UK.. For further information about the potential risks of a cross border data transfer refer to XII.

Further information about the processing of your personal data in the provider’s course of operation is provided via their respective privacy policy. Moreover, you will be provided with further information with regard to your rights and setting concerning privacy.

a) Facebook Social Plugins

We use so-called social plugins („plugins“) of the social networking site facebook.com provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The plugins can be identified by one of Facebook’s logos (white “f” on blue tile or a “thumps-up”-sign) or by the additional text “Facebook Social Plugin”. The list of Facebook Social Plugins and their appearance can be accessed via: http://developers.facebook.com/plugins.

If a user visits one of the websites using such a plugin, the user’s browser directly connects to Facebook’s servers. The plugin and its content are made available directly on Facebook’s servers and included in the website by the user’s browser.

Due to the integration of the plugin Facebook collects the information that a user is visiting the corresponding website. If the user is logged in on Facebook at the moment he or she visits the website, Facebook may be able to connect the visit on the website to the user’s Facebook account. If the user interacts with the plugin – for example if he or she presses the like button or comments on something – the user’s browser transmits this information to Facebook. Facebook stores this information. If a user is not a member of Facebook, Facebook may collect and store the user’s IP-address. Facebook states that it only collects anonymized IP-addresses in Germany.

The reason for and scope of the data acquisition and information about the way in which the data is processed and used by Facebook, as well as the user’s rights in this respect and settings options for protecting the users privacy can be found under: http://www.facebook.com/policy.php.

If the user is a member of Facebook and does not wish Facebook to collect personal data via this homepage and to link this with his data stored on Facebook, the user needs to log off from Facebook before going to this homepage.

The user may also block Facebook’s plugins using add-ons for the user’s browser, for example the „Facebook Blocker“.

b) Instagram

Instagram plug-ins are operated by Instagram LLC, 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”). An overview of Instagram plug-ins can be found here: http://blog.instagram.com/post/36222022872/introducing-instagram-badges; information on data protection at Instagram can be found here: https://help.instagram.com/155833707900388/

c) Linkedin

We use LinkedIn button. The button is provided by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. The button is marked using the text ‘LinkedIn’ and its ‘in’ logo picture.

The button enables the user to share an article or a website of this homepage on LinkedIn or to follow the provider on LinkedIn.

If a user visits one of the websites using such a button, the user’s browser directly connects to LinkedIn’s servers. The LinkedIn-button and its content are loaded directly from LinkedIn’s servers and included in the website by the user’s browser. According to the provider’s knowledge, LinkedIn collects the user IP-address and the website’s URL when the button is loaded from LinkedIn’s servers. However, this data is only be used for loading and displaying the LinkedIn-button.

Further information can be found in LinkedIn’s privacy statement under: https://www.linkedin.com/legal/privacy-policy.

Should you have any questions regarding our privacy policy, please contact us via the e-mail address:dataprotection@springer.com.

2. YouTube

We use YouTube’s service in order to play some videos directly from our website. This processing is based on Article 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to improve your website experience and to optimise our services.

Your browser will directly communicate with YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066. We do not have any influence on YouTube’s data processing activities. Please check YouTube’s privacy policy for further information: https://support.google.com/youtube/answer/7671399?hl=en Here you can find information about your rights and privacy settings. [Your data will be sent to a country outside the EEA. For further information about the potential risks of a cross border data transfer refer to X.]

3. Links to third party websites

This website may contain links to third party websites. We are not responsible for the content and the data collection on respective third party websites; please check the privacy policy of respective websites for information of respective websites’ data processing activities.

X. Information sharing

Your personal data will only be disclosed to a third party to the extent necessary to fulfill our contractual relationship. Legal basis for the transfer of your personal data is Article 6 sec. 1 sent. 1 lit. b and f GDPR and represents our legitimate interest to implement our general terms and conditions of business or any other agreements concluded with you.

Some of the recipients mentioned above reside outside the EEA. For further information about cross border transfer in general and transfers outside of the EEA see 5.

We may disclose your personal data to following contractors who assist us in providing the services we offer through the website. For example, when you make a purchase we may share information about you and your transaction with other companies for the purpose of processing your transaction. In addition, we may retain third party service providers to manage our customer databases or distribute e-mail offerings. Such data transfers will be based on data processing agreements. Therefore, our contractors will only use your personal data to the extent necessary to perform their functions and will be contractually bound to process your personal data only on our behalf and in compliance with our requests. In the event that we undergo re-organisation or are sold to a third party, any personal data we hold about you may be transferred to that re-organised entity or third party in compliance with applicable law.

We may disclose your personal data if legally entitled or required to do so (for example if required by law or by a court order).

XI. Cross border data transfers

Within the scope of our information sharing activities set out above, your personal data may be transferred to other countries (including countries outside the EEA) which may have different data protection standards from your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavour to take reasonable measures to maintain an adequate level of data protection when sharing your personal data with such countries.

In the case of a transfer outside of the EEA, this transfer is safeguarded by EU Standard Contractual Clauses. You can find further information about the aforementioned safeguards under https://ec.europa.eu/info/law/law-topic/data-protection_enn or by contacting the Data Protection Team at dataprotection@springernature.com

We have reasonable state of the art security measures in place to protect against the loss, misuse and alteration of personal data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our website whilst it is in transit over the internet and any such submission is at your own risk.

XII. Security

XIII. Data retention

We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this policy, your personal data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements.

XIV. Your rights

Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:

1. require (i) information as to whether your personal data is retained and (ii) access to and/or duplicates of your personal data retained, including the purposes of the processing, the categories of personal data concerned, and the data recipients as well as potential retention periods;

2. request rectification, removal or restriction of your personal data, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;

3. refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time;

4. object, on grounds relating to your particular situation, that your personal data shall be subject to a processing. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal data or present you our compelling legitimate grounds for an ongoing processing;

5. take legal actions in relation to any potential breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection regulators;

6. require (i) to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side; where technically feasible you shall have the right to have the personal data transmitted directly from us to another controller; and/or

7. not to be subject to any automated decision making, including profiling (automatic decisions based on data processing by automatic means, for the purpose of assessing several personal aspects) which produce legal effects on you or affects you with similar significance.

You may (i) exercise the rights referred to above or (ii) pose any questions or (iii) make any complaints regarding our data processing by contacting us using the contact details set out below.

XV. Contacting us

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to our Group Data Protection Officer. You can contact our Group Data Protection Officer via dataprotection@springernature.com

The information you provide when contacting us at international.curriculum@macmillaneducation.com will be processed to handle your request and will be erased when your request is completed. Alternatively, we will restrict the processing of the respective information in accordance with statutory retention requirements.

XVI. Amendments to this policy

We reserve the right to change this policy from time to time by updating our website respectively. Please visit the website regularly and check our respective current privacy policy. This policy was last updated on 02 December2019.