Privacy Policy

Welcome to the Armirate Education Limited's privacy policy.

Armirate Education Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we process your personal data and tell you about your privacy rights and how the law protects you.

For the purposes of our privacy policy, “Student” shall mean a prospective or current participant of a course provided by Armirate. If the Student is over the age of 18, the terms “you” and “your” shall be deemed to refer to and include the Student. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Armirate Education Limited collects and processes the Student’s and / or your personal data, including any data we collect through your use of this website or that you may provide through this website when you download content or apply for a Student to join a course.

This website is not intended for children and we do not knowingly collect data relating to children, save for when they are provided by a parent or legal guardian on behalf of their child for the purpose of their participation on a course provided by Armirate. If you are below the age of 18 then you must have your parent’s or legal guardian’s consent to submit any personal data at all. We will promptly delete any personal information relating to minors where we are informed that parental or guardian consent has not been granted. Should you be a concerned parent or guardian of a minor who has submitted their personal data without your consent please write to us by email or post at the addresses provided below.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you and / or the Student so that you are fully aware of how and why we are using the Student’s and / or your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Armirate Education Limited is the controller and responsible for the Student’s and/or your personal data (collectively referred to as Armirate, "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact us by email at info@armirate.com.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you and / or the Student is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you and / or the Student. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU AND / OR THE STUDENT
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you and / or the Student which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Special categories of personal data includes Health and Biometric Data such as dietary requirements, allergies, medical information and any special requirements you and / or the Student may have.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account details.
Transaction Data includes details about payments to and from you and other details of courses you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, courses, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, store and use information about the Student’s and / or your health and generic biometric data which are considered Special Categories of Personal Data. Save for information about Student’s and / or your health and generic biometric data, we do not collect any Special Categories of Personal Data about you or the Student (this includes details about the Student’s and / or your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and trade union membership). Nor do we collect any information about criminal convictions and offences. Special Categories of Personal Data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place appropriate safeguards which we are required by law to maintain when processing such data.

We process the Student’s health and generic biometric data to:

ensure the Student’s health and safety on any course provided by Armirate;
assess the Student’s fitness to participate on any course provided by Armirate;
provide the Student with appropriate adjustments (if required) on any course provided by Armirate; and
to administer medication to the Student where your express consent has been obtained.

We do not need your consent if we use special categories of the Student’s or your personal information in accordance with this written policy to carry out our legal obligations or exercise specific rights provided for by law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data relating to you or the Student. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

We do not need your consent where the purpose of the processing is to protect you, the Student or another person from harm or to protect the Student or your well-being and if we reasonably believe that you or the Student need care and support, are at risk of harm and are unable to protect themself.

IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you and / or the Student with a course). In this case, we may have to cancel the course you have booked with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you and / or the Student including through:

Direct interactions. You may give us the Student and / or your Identity, Contact, Financial Data and Health and Biometric Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the Student’s and your personal data you provide when you apply for a Student to participate in our courses, manage your booking, request marketing to be sent to you, give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy at https://silkroads.co.uk/cookie-policy/ for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.

4. HOW WE USE YOUR PERSONAL DATA

We will only use the Student’s or your personal data when the law allows us to. Most commonly, we will use the Student’s or your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and the Student’s and / or your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Please see the section below in the Glossary to find out more about the types of lawful basis that we will rely on to process the Student’s and / or your personal data.

Generally, we do not rely on consent as a legal basis for processing the Student’s and / or your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE THE STUDENT’S AND / OR YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use the Student’s and / or your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process the Student’s and / or your personal data for more than one lawful ground depending on the specific purpose for which we are using the Student’s and / or your data. Please contact us if you need details about the specific legal ground we are relying on to process the Student’s and / or your personal data where more than one ground has been set out in the table below.

5. DISCLOSURES OF THE STUDENT’S AND / OR YOUR PERSONAL DATA

We may share the Student’s and / or your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

External Third Parties as set out in the Glossary
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If there is a change to our business, then the new owners may use the Student’s and / or your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of the Student’s and / or your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use the Student’s and / or your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

As part of the process of processing your application for a Student to participate in a course and performing our contract with you, the Student’s and / or your personal data may be transferred outside the United Kingdom (UK) and European Economic Area (EEA). This could include places whose laws may provide for a lesser standard of protection for the Student’s and / or your personal data than that provided under European Law.

Examples of situations where we are required to transfer the Student’s and / or your data may include, but are not limited to:

Transfers to suppliers and partners when Armirate assists with flights, insurance, visa applications and/or renewals;
Transfers to partners where certain licences, permissions and/or authorisations are required in order to participate in our programs and/or enter certain controlled areas (such as partner schools and other experiences).

Suppliers and partners are required to adhere to the same standards as Armirate when dealing with personal data. In all cases of transfers, we will implement appropriate safeguards to ensure the Student’s and / or your privacy rights are protected, such as using an international data transfer agreement or standard contractual clauses approved by the European Commission or obtaining your consent to the transfer.

7. DATA SECURITY

We have put in place appropriate security measures to prevent the Student’s and / or your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to the Student’s and / or your personal data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process the Student’s and / or your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY OR THE STUDENT’S PERSONAL DATA FOR?

We will only retain the Student’s and / or your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain the Student’s and / or your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the Student’s and / or your personal data, the purposes for which we process the Student’s and / or your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete the Student’s and / or your data: see your legal rights below for further information.

In some circumstances we will anonymise the Student’s and / or your personal data (so that it can no longer be associated with you or the Student) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

PURPOSES FOR WHICH WE WILL USE THE STUDENT’S AND / OR YOUR PERSONAL DATA

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which courses, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased a course from us and you have not opted out of receiving that marketing

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your purchase of a course, product / service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://silkroads.co.uk/cookie-policy/.

CHANGE OF PURPOSE

We will only use the Student’s and / or your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use the Student’s and / or your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process the Student’s and / or your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to the Student’s and / or your personal data. Please click on the links below to find out more about these rights:

Request access to the Student’s and / or your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and / or the Student and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you or the Student. This enables you to have any incomplete or inaccurate data we hold about you and / or the Student corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of the Student’s and / or your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove the Student’s and / or your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed the Student’s and / or your information unlawfully or where we are required to erase the Student’s and / or your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of the Student’s and / or your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on the Student’s and / or your fundamental rights and freedoms. You also have the right to object where we are processing the Student’s and / or your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process the Student’s and / or your information which override the Student’s and / or your rights and freedoms.
Request restriction of processing of the Student’s and / or your personal data. This enables you to ask us to suspend the processing of the Student’s and / or your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of the Student’s and / or your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of the Student’s and / or your personal data to you or to a third party. We will provide to you, or a third party you have chosen, the Student’s and / or your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process the Student’s and / or your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide a course to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access the Student’s and / or your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm the Student’s and / or your identity and ensure your right to access the Student’s and / or your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you and / or the Student (both positive and negative) and the Student’s and / or your rights before we process the Student’s and / or your personal data for our legitimate interests. We do not use the Student’s and / or your personal data for activities where our interests are overridden by the impact on you or the Student (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you or the Student in respect of specific activities by contacting us.

Performance of Contract means processing the Student’s and / or your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing the Student’s and / or your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

EXTERNAL THIRD PARTIES

Our educational and activity providers.

Lanzhou Oriental Secondary School;
Service providers acting as processors based in the United Kingdom, China and other jurisdictions who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom, China and other jurisdictions who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs (or other equivalent bodies), regulators and other authorities based in the United Kingdom, China and other jurisdictions who require reporting of processing activities in certain circumstances.
Hospitals, medical services, hotels, airline and transport providers and catering service providers based in the United Kingdom, China or elsewhere.

Country/region

Privacy Policy