This policy explains how we collect and use your personal data when you visit itsl.global, contact us, register or pay for a course, or comment on our blog, and how we use cookies and similar technologies.
1. Who we are
ITSL is the controller of your personal data.
Contact for privacy questions: info@itsl.global · +44 7367 000459.
2. The data we collect
- Registration and enquiry details: your name, email address, phone number, country, the programme you are interested in, your message and any other information you enter in our forms.
- Payment details: your name, email address, phone number, country, the programme you chose, the amount and the payment status. Card details are entered on Stripe's secure payment page; we never receive or store them.
- Blog comments: the name and (optional) email address you enter and the content of your comment. Comments are reviewed before they are published, and your email address is never published.
- Communications: emails and messages you send us and our replies.
- Advertising source (only with your consent): which advert, campaign, link or website brought you to our site — for example campaign (UTM) parameters, the Facebook or Google click identifier, the referring website and the page you first landed on. This is kept in your browser for 30 days and attached to any form or payment you submit during that time.
- Website activity (only with your consent): if you accept marketing cookies, the Meta Pixel and the Meta Conversions API record the pages you visit and the actions you take on our site (such as viewing a programme, sending a form, clicking a WhatsApp link, starting or completing a payment), together with your browser and device information and Meta's cookie identifiers.
- Analytics (only with your consent): if you accept analytics cookies, Google Analytics, which we run through Google Tag Manager, records how our site is used — for example the pages you view, your device and browser, your approximate location (country or city) and actions such as sending a form or starting a payment. We never send your name, email address or phone number to Google Analytics.
- Technical data: as with any website, our hosting provider processes your IP address and basic request information to deliver the site and keep it secure. We also count page views without cookies and without storing your IP address.
3. How we use your data and our legal bases
- To process your registration and payment and to provide your course (performance of a contract, or steps you ask us to take before entering into one).
- To answer your questions and requests (legitimate interests).
- To review and publish blog comments (legitimate interests).
- To keep accounting and tax records (legal obligation).
- To protect our website and services against misuse and fraud (legitimate interests).
- To understand how our site is used, to improve it and to see which pages and campaigns lead to enquiries, applications and payments (Google Analytics; your consent, which you can withdraw at any time).
- To find out which adverts and campaigns bring us enquiries, applications and payments, to measure the results of our adverts and to show our adverts to relevant people on Facebook and Instagram (your consent, which you can withdraw at any time).
4. What we do not do
We do not sell your personal data, we do not use it for automated decision-making, and we only send you marketing emails if you have agreed to receive them.
5. Who we share your data with
We use trusted service providers who process data on our behalf: Stripe (payment processing), Hostinger (website hosting and email), Supabase (database) and Cloudflare (domain name services). We may also share data with our professional advisers, or with authorities where the law requires it.
If you accept marketing cookies, we also share the website activity described in section 2 with Meta Platforms Ireland Limited (Facebook and Instagram) through the Meta Pixel and the Meta Conversions API. Before your email address, phone number, name and country are sent, they are converted into an irreversible code (hashing). We and Meta are joint controllers for collecting and sending this data; Meta's own use of it is governed by Meta's Privacy Policy (facebook.com/privacy/policy). If you do not accept marketing cookies, nothing is sent to Meta.
If you accept analytics cookies, Google Ireland Limited processes the analytics data described in section 2 for us as a service provider, through Google Analytics and Google Tag Manager. Google's privacy policy is available at policies.google.com/privacy. If you do not accept analytics cookies, Google Analytics does not set cookies on your device.
6. International transfers
Some of our service providers, including Meta and Google, may process data outside the United Kingdom, for example in the United States. Where they do, the transfer is protected by appropriate safeguards, such as UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework) or approved contractual clauses.
7. How long we keep your data
- Payment and accounting records: 6 years, as required by UK tax law.
- Registration and enquiry details: up to 2 years after our last contact with you, or for as long as you are a student with us.
- Blog comments: for as long as the comment is published, or until you ask us to remove it.
- Advertising source: 30 days in your browser; once attached to a form or payment, for as long as that record is kept.
- Google Analytics data: 14 months, after which Google deletes it.
- Your cookie choice: 12 months, after which we ask you again. Meta keeps the data it receives according to its own policy.
8. Cookies and similar technologies
When you first visit our website, a cookie banner asks for your choice. Until you choose, only strictly necessary storage is used. You can accept all, reject all or choose by category, and you can change your choice at any time with the "Cookie settings" link at the bottom of every page.
- Strictly necessary (always on): your language choice and your cookie choice, kept in your browser's local storage, and the sign-in cookies of our administration area for staff.
- Analytics and advertising source (only with your consent): Google Analytics cookies (_ga and _ga_…), set by Google to measure how the site is used and kept for up to 2 years, and a record in your browser's local storage of which advert, campaign or website brought you to our site, for 30 days.
- Marketing (only with your consent): the Meta Pixel, which sets Meta's _fbp and _fbc cookies to measure our adverts and the actions you take on our site, and the Google Maps map on our contact page. Without this consent the map is only loaded when you click "Show map", and Google may then set its own cookies.
- Images: some images on the site are loaded from Unsplash, which receives your IP address when they load.
9. Your rights
You have the right to access, correct or delete your personal data, to restrict or object to its use, to data portability, and to withdraw any consent you have given. To exercise these rights, email info@itsl.global; we will respond within one month.
You can withdraw your consent to cookies at any time with the "Cookie settings" link at the bottom of every page. Withdrawing your consent does not affect processing carried out before you withdrew it.
You also have the right to complain to the UK Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113.
10. Changes to this policy
We may update this policy from time to time. The date at the top of this page shows when it was last changed.
