Earlston Academy
Empowering minds, inspiring futures, connecting creativity and knowledge across the globe
ENROLL TODAYEffective Date: 25 September, 2025
This Privacy Policy outlines the practices governing how Earlston Academy collects, uses, and protects your personal information when you access or interact with the Earlston Academy Service (which includes the website https://earlstonacademy.com/ and all associated web functionalities) (collectively, the “Service”). This document is legally binding and is incorporated by reference into the Terms of Use that you agreed to (the “Contract”).
We adhere to the provisions of the data protection laws relevant to your location or country of residence.
Age Restriction
We are committed to not knowingly gathering personal data from any individual who is under eighteen (18) years of age.
Guidance for Underage Users
If you have not yet reached the age of 18, we ask that you refrain from registering for the Service or attempting to submit any personal information to us.
Should you be a parent or legal guardian and have reason to believe that your child under 18 has furnished us with personal data in a manner that violates this Policy, we urge you to contact us immediately using the details provided in this Privacy Policy.
If you encounter any difficulty accessing or reading this Privacy Policy online, please contact us using the details provided in this policy. Upon request, we will provide you with a copy of this Policy in an alternative, easy-to-read format at no cost to you.
Please be assured that we will not collect or process any additional sensitive personal data (such as health information) in connection with your request for an alternative format of this Policy.
To operate the Service and fulfill our contractual obligations, we collect and process the personal data detailed in the following section. Please note that all the information listed is collected directly from you, the data subject, at the point of interaction or submission.
Description: This category includes the essential personal information required to establish your Earlston Academy account. This data is collected at the point of registration and typically includes:
Description: If you choose to enroll in a Earlston Academy course, we require additional information to manage your participation and progress. This Student Data may include, but is not limited to:
Description: You may voluntarily provide us with additional personal data when interacting with the Service, the Earlston Academy team, or our website. This typically occurs when you engage in actions that do not require full account registration.
Specifically, we may collect information about your name and contact information when you:
Description: Earlston Academy utilizes cookies, web beacons (also known as "pixels"), and other tracking technologies on our platform to enhance the quality of your user experience (collectively referred to as "Cookies"). A cookie is a small, common text file that your web browser places on your device when you visit a website. This file subsequently sends information about your visit back to the website when you return. The information gathered by these cookies may encompass browser details, Internet activity, and Service usage data.
For comprehensive information about the types of cookies we use and how they function, please consult our separate Cookie Notice.
Description: Earlston Academy provides information about the tutors who instruct in its educational courses to students and users of the Service. This published information includes:
Description: This category includes the same Student Data collected during enrollment (as detailed in the "Students" section). Earlston Academy typically retains this information; however, it may require graduating students to confirm or update certain personal data before course completion, such as changes to contact information or professional status.
We only process your personal data when we have a valid legal basis for doing so, which are outlined below:
We may process your personal data where it is necessary to provide you with the Service and to fulfill our obligations as defined in the Contract you accepted.
We may process your personal data where we (or a designated third party) have a legitimate interest in using it, provided that this processing is essential and that these interests are balanced against, and do not unduly infringe upon, your fundamental rights and freedoms.
Where "legitimate interest" is recognized as a lawful basis under the data protection laws of your country of residence, we rely on it to:
If your jurisdiction does not recognize "legitimate interests" as a valid legal basis for processing, we will instead rely on an alternative and appropriate legal basis available under that country’s specific data protection laws.
Where required by relevant law, we will process your personal data based on your express consent. You maintain the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of any processing that took place prior to your withdrawal.
We process your personal data when it is necessary to comply with applicable laws, regulations, or mandatory legal requests.
Purposes, Bases, and Data Categories
The next section that follows will provide a concise overview by defining the following key aspects of our data processing activities:
Provision of Core Services
We process your Registration Data and Student Data when it is necessary to perform our Contract with you. This enables us to effectively provide you with the Service, including access to courses and platform functionality.
Educational and Career Support for Graduates
For graduating students, we rely on your Consent to process specific Student Data (related to your education and professional qualifications). This information is used solely to facilitate the provision of educational and career opportunities.
Service Improvement
We process Registration Data, Student Data, Other Data, and Cookies based on our Legitimate Interest to continually enhance, optimize, and debug our Service to provide a better user experience.
Communication and Outreach
To inform both current and prospective students about our courses and educational opportunities, we rely on Consent or Legitimate Interest. This requires the use of Student Data, Registration Data (when the data subject has provided consent), Other Data, and Tutor Data.
Where required by relevant law, we will process your personal data based on your express consent. You maintain the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of any processing that took place prior to your withdrawal.
We process your personal data when it is necessary to comply with applicable laws, regulations, or mandatory legal requests.
Purposes, Bases, and Data Categories
The next section that follows will provide a concise overview by defining the following key aspects of our data processing activities:
Provision of Core Services
We process your Registration Data and Student Data when it is necessary to perform our Contract with you. This enables us to effectively provide you with the Service, including access to courses and platform functionality.
Educational and Career Support for Graduates
For graduating students, we rely on your Consent to process specific Student Data (related to your education and professional qualifications). This information is used solely to facilitate the provision of educational and career opportunities.
Service Improvement
We process Registration Data, Student Data, Other Data, and Cookies based on our Legitimate Interest to continually enhance, optimize, and debug our Service to provide a better user experience.
Communication and Outreach
To inform both current and prospective students about our courses and educational opportunities, we rely on Consent or Legitimate Interest. This requires the use of Student Data, Registration Data (when the data subject has provided consent), Other Data, and Tutor Data.
Where required by relevant law, we will process your personal data based on your express consent. You maintain the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of any processing that took place prior to your withdrawal.
We process your personal data when it is necessary to comply with applicable laws, regulations, or mandatory legal requests.
Purposes, Bases, and Data Categories
The next section that follows will provide a concise overview by defining the following key aspects of our data processing activities:
Provision of Core Services
We process your Registration Data and Student Data when it is necessary to perform our Contract with you. This enables us to effectively provide you with the Service, including access to courses and platform functionality.
Educational and Career Support for Graduates
For graduating students, we rely on your Consent to process specific Student Data (related to your education and professional qualifications). This information is used solely to facilitate the provision of educational and career opportunities.
Service Improvement
We process Registration Data, Student Data, Other Data, and Cookies based on our Legitimate Interest to continually enhance, optimize, and debug our Service to provide a better user experience.
Communication and Outreach
To inform both current and prospective students about our courses and educational opportunities, we rely on Consent or Legitimate Interest. This requires the use of Student Data, Registration Data (when the data subject has provided consent), Other Data, and Tutor Data.
Marketing, Promotion, and Targeted Advertising
We rely on Consent or Legitimate Interest to use Other Data, Student Data, Registration Data (when consent is provided), and Cookies for marketing, promotional campaigns, and advertising, including tailoring ads based on the personal data we have collected about you.
Security and Integrity
We process Other Data, Student Data, Registration Data, and Tutor Data based on our Legitimate Interest in maintaining the security and integrity of our network. This includes detecting, investigating, and actively preventing activities that could violate our policies, lead to security incidents, or involve fraudulent or illegal conduct.
We process Registration Data, Student Data, Other Data, Cookies, and Tutor Data when required to meet our Legal or Regulatory Obligations, including responding to mandatory legal requests from authorities.
We rely on Legitimate Interest to process Registration Data, Student Data, Other Data, Cookies, and Tutor Data to establish, exercise, or defend our legal rights in the event of a dispute or legal claim.
We process Registration Data, Student Data, Other Data, Cookies, and Tutor Data based on our Legitimate Interest to conduct internal planning, prepare essential business reports, and create future business forecasts.
We rely on Performance of Contract, Legitimate Interest, or Consent to process Registration Data, Student and Graduating Student Data, Other Data, Cookies, and Tutor Data. This data is used to conduct research, administer surveys, and manage contests.
We rely on Legitimate Interest and, where necessary, Consent, to process the Correspondence and calls between users and Earlston Academy's support team. This processing serves multiple purposes:
Where applicable data protection laws mandate that we process specific types of personal data only with your explicit consent (or another specific lawful basis), we will strictly adhere to that requirement by obtaining the necessary consent or relying on the appropriate legal ground defined in that jurisdiction.
Consequently, the details in the section above concerning purposes, legal bases, and data categories are only applicable to the extent that they comply with the mandatory legal requirements of your specific country of residence. The exact lawful bases we rely on to process your personal data may therefore vary depending on the data protection laws of your location.
How We Share Your Personal Data
Disclosure of Your Personal Data
We may disclose or share your personal data with the recipients listed below. Any sharing is strictly limited to what is required or permitted by applicable law and is done in accordance with your valid requests:
We may share your personal data with third-party vendors and external partners (known as Service Providers) who support our business operations and the delivery of the Service. These recipients act on our behalf and include:
We may disclose data to additional vendors or consultants engaged to help us either deliver the Service directly or fulfill any of the other purposes described in Section 3 of this Privacy Policy (Purposes and Legal Bases).
We share data with public authorities only when strictly necessary to comply with legal or regulatory obligations or to formally respond to mandatory inquiries, subpoenas, or warrants.
Your data may be shared with lenders or other financial service providers where this is necessary to facilitate payments, manage loans, or provide related financial services.
We will share your data with other third parties as and when required to comply with applicable laws, court orders, or other mandatory legal processes.
Your personal data may be disclosed to a relevant third party in connection with a sale, merger, corporate restructuring, or the transfer of all or part of our business, assets, rights, or obligations (e.g., in the event of bankruptcy).
Please be aware that all third parties listed above are strictly prohibited from using your personal data for any purpose other than performing their specific contractual functions and fulfilling the purposes for which the data was originally shared.
When you purchase our courses or other products, you will be redirected to external websites operated by our trusted payment service providers to complete your transaction. Once the payment process is finished, we only receive confirmation regarding the status of the transaction.
We want to assure you that we do not collect, access, or store any of your sensitive payment details (such as credit card numbers or bank account information).
We have no control over and cannot view any information you enter on the payment provider’s site. All payment processing is handled directly by the third-party provider and is governed exclusively by their own privacy policy and terms.
Please note: Any data you submit during the checkout process is subject to the provider’s terms and privacy practices, over which Earlston Academy has no control.
Our Privacy Policy governs how we collect, use, protect, and disclose your personal data only within the Earlston Academy Service.
However, the Service may contain links to external websites, platforms, or tools that are not operated by Earlston Academy. Examples include external services like Zoom or other video-conferencing and webinar tools used to facilitate online classes.
Separate Registration and Policies
These third-party providers may require you to register or sign up independently, and they operate strictly under their own separate terms and privacy policies. We encourage you to review their documents before providing any personal information.
Disclaimer of Liability
Earlston Academy does not control, endorse, or assume any liability for the content, privacy practices, or security measures employed by these external sites and services.
Separate Policies
This Privacy Policy does not govern or cover how those third parties collect, use, or share your personal data, even if they are branded as Earlston Academy partners.
WE STRONGLY RECOMMEND THAT YOU REVIEW THE PRIVACY POLICY OF ANY THIRD-PARTY SITE OR SERVICE YOU ACCESS THROUGH OUR SERVICE BEFORE SUBMITTING ANY PERSONAL DATA.
The entity acting as the “Controller” of your personal data for the purposes of this Policy is the company responsible for operating the Service pursuant to the Contract.
You can find comprehensive details regarding the identity of the Controller within the Contract. Throughout this Privacy Policy, this operating company is referred to as "Earlston Academy," “we,” or “us.”
Should you have any questions concerning how we manage your personal data as described in this Policy, please feel free to reach out to us at:
E-mail: contact@earlstonacademy.com
Due to the global nature of Earlston Academy's operations, your personal data may be moved, stored, and utilized outside the boundaries of your home country or the European Economic Area (“EEA”). This includes transfers to regions like the United States, Africa, and any other jurisdiction hosting our essential service providers and subprocessors. These necessary international transfers are performed to facilitate the global delivery, hosting, and ongoing support of the Service.
All transfers are executed electronically over secure, encrypted channels (for instance, utilizing HTTPS). The data itself may reside on servers managed by our cloud and other trusted service providers.
To guarantee that your personal data maintains an appropriate level of protection when transferred internationally, we rely on one or more of the following approved mechanisms, as allowed by relevant law:
For individuals who want full visibility into our international data transfer operations—including comprehensive lists of every recipient and access to the detailed data processing agreement(s) we use—further information is available upon request.
Data subjects may contact us to make this request using the general support email: support@earlstonacademy.com (referencing Section 1 for context). Alternatively, you may contact the specific Data Protection Officer whose details are provided in the privacy sections tailored to your jurisdiction.
Your personal data is kept for a period sufficient to satisfy the specific purposes detailed in Section 3 of this Privacy Policy. Specifically, we hold the data throughout the duration that your Earlston Academy account remains active, and for a subsequent period of up to five (5) years following account deactivation. This timeframe may be extended if necessary to comply with binding legal or regulatory obligations.
At the conclusion of this defined retention period, your personal data will be either securely deleted or rendered irreversibly anonymized
We employ comprehensive physical, technical, and organizational security measures designed to be proportionate to the sensitivity of the personal data we gather. These safeguards are in place to prevent accidental loss, unauthorized intrusion, or improper disclosure of your information.
Our protective mechanisms include, but are not limited to, the following categories:
It must be noted that while Earlston Academy endeavors to shield your data from harm, no security framework is entirely invulnerable. Consequently, we cannot guarantee that information you send to us across the public internet will be absolutely secure against interception.
Fundamental Rights Regarding Your Personal Data
This section outlines the inherent rights you possess concerning the personal data that Earlston Academy processes, granting you control over your information.
You have the right to request that Earlston Academy verify whether we are processing any of your personal data. Should we confirm that processing is taking place, you are entitled to access this personal data and receive a clear explanation detailing the specifics of our processing activities.
You have the ability to ask us to correct your personal data if you find it to be inaccurate, misleading, or outdated. Furthermore, provided it aligns with the stated purposes of processing, you may request the completion or amendment of any incomplete or erroneous personal information we hold about you.
You may request that we delete or irreversibly anonymize your personal data in accordance with applicable legal provisions. This right generally applies in situations such as:
You have the right, as permitted by applicable law, to request the restriction (or temporary blocking) of certain personal data to limit how we process it in the future. This right is typically exercisable under the following conditions:
Right to Object to Processing
You are entitled to object at any time, based on your specific situation, to the processing of your personal data, provided this right is afforded to you by applicable laws. This objection is generally relevant when the processing is based on a lawful basis other than consent (a "consent exemption") or involves a potential failure to comply with applicable law.
Should you object, we will be required to stop processing your data, unless we can successfully demonstrate a compelling and lawful basis for continuing the processing that legitimately overrides your individual interests, rights, and freedoms, or if the processing is essential for meeting a legal or regulatory obligation or for the establishment or defense of legal claims.
You are entitled to the right of Data Portability, provided this right is granted under applicable laws. If the processing of your data is legally based on your consent or the performance of a contract signed with Earlston Academy, you may request and receive the personal data you supplied to us in a structured, standard, and machine-readable format. This allows you to effortlessly transfer that data to a different data controller.
Furthermore, where it is technically feasible, you may also request that Earlston Academy transmit this personal data directly to the other controller on your behalf.
If Earlston Academy engages in the shared use of your personal data with any other public or private entity, you reserve the right to request information detailing the identities of these specific entities.
When the processing of your personal data relies legally upon your consent, you have the right to be informed about the consequences of your refusal to provide that consent.
If the processing of your personal data results in an automated decision that impacts your rights or interests, you may request a review of that decision, provided this right is permitted under applicable laws.
Exercising Your Rights
To formally exercise any of the rights listed above (subject to any necessary legal restrictions), please reach out to us using the contact information detailed in Section 1 of this Privacy Policy, or by contacting the designated Data Protection Officer as specified in the privacy sections tailored to your jurisdiction.
If our legal basis for processing your data depends upon your consent, you are free to revoke that consent at any time. The withdrawal of your consent will not invalidate or affect the legality of any data processing that occurred prior to the date of your withdrawal.
To cease receiving electronic communications from us, you have several options:
If permissible under the laws that apply to you, you have the ability to submit a formal complaint directly to the relevant data protection authority located in your country of residence.
Necessity of Providing Personal Data
We restrict our collection of personal data exclusively to that which is strictly required for the delivery of the Service and for meeting the purposes detailed in Section of this Privacy Policy.
There exists no legal or contractual obligation compelling you to share your personal data with Earlston Academy. Providing this information is completely voluntary, and you retain the right to choose not to disclose any personal data to us.
This section is valid only for California residents and governs the personal information collected directly from you within the last 12 months.
Earlston Academy collects personal information falling into the following main categories
Category
Examples of Data Collected
Identifiers
Full name, email, phone number, address, age (if under 18), and work authorization status.
Protected Classifications
Gender and presence of children.
Commercial Information
Records of Earlston Academy services purchased or considered for purchase.
Internet/Network Activity
Data related to cookie usage
Professional/Employment
Area of interest, professional status/experience, and work authorization.
Educational Information
Highest degree or level of education and field of study.
We reserve the right to modify this Privacy Policy at any time, based solely on our discretion.
In the event that we introduce significant or material changes, we will inform you through appropriate communication channels (such as sending a notification via email or prominently posting an alert on our website). Should you not receive a direct notification, you can always review the most current version of the policy on this dedicated page.
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