PRIVACY POLICY

Introduction

The company under the name “E. MOUTSOY & CO G.P.” and the distinctive title “M M Publications” (hereinafter referred to as “MM Publications ”, “the Company”, “we”, or “us”) has created this Privacy Policy, in order to demonstrate our Company’s commitment to protecting your personal information.

This Privacy Policy applies to all users of the website www.mmplacement.com and its online service, “English Placement Test,” and explains how we collect, use, process, and share the information you may provide to us through our website.

Our website provides external links to other websites, applications, and social media platforms, which we believe may be of interest to you. They do not operate under this Privacy Policy, and we cannot influence how they collect and use personal information. Therefore, we recommend that you read their Privacy Policies before providing any information to them.

Data Controller

MM Publications is the controller of the personal data collected through this website. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our Company, using the following contact details:

Contact Details

Full name of legal entity: E. Moutsou and Co. G.P.
Postal address: 20 Lakonias Str., Alimos 175 46, Athens, Greece
Email address: online-services@mmpublications.org.uk

Categories of Personal Data we collect

We need to know your basic personal data in order to assess your English language level. Therefore, in order to assess your skills, we collect from you and process the following data:

Your full name;
email address;
The version of the test you selected and completed;
Your performance report;
Your navigation environment (IP address, operating system, type of device, date, and time of the different evaluation sessions);
Your teacher’s email address (optional), so that they can also receive your performance report.

How your data is collected

We use different methods to collect data from and about you, including through:

Direct interactions

You may give us your personal data when, for example, you:

register to use our free online English Placement Test;
sign up to receive news, updates, or other marketing from us;
contact us;
request to exercise your individual rights under applicable privacy laws.

Automated technologies or interactions

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. Please see our 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, including:

analytics providers (such as Google);
information that is part of your profile on a third-party social network that you allow to share with us.

Why we collect Personal Data

We will process your personal data following the requirements of applicable laws on an appropriate legal basis, including:

Where the processing of the above data is necessary for the performance of our service.
Where it is necessary for our and your legitimate interests (or those of a third party). Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they do not override your rights. Additionally, in some cases, you have the right to object to this processing. For more information, visit Sections "Data Subject Rights" and "How to Exercise Your Rights" of this policy.
Where we need to comply with a legal or regulatory obligation.
When you have provided us with your explicit consent to do so. In case we rely on consent as a legal basis for processing your personal data, please note that you have the right to withdraw your consent at any time. For more information, please visit Sections "Data Subject Rights" and "How to Exercise Your Rights" of this policy.

How we use your Personal Data

We will only use 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.

We collect and process your personal data for the following purposes:

To assess your English language level;
To administer and protect our business, services, and website;
To use data analytics to develop insights, and to improve our website, services, marketing, customer relationships, and experiences;
To respond to any communications, queries, or requests for information or services from you, howsoever received;
To manage our relationship with you;
To comply with our legal or regulatory obligations; and
To establish, exercise, or defend legal claims.

How long we use your Personal Data

Personal data submitted for the purpose of assessing your English language level, shall be kept by the Company for a period of 3 months from the delivery of results.

In some circumstances, we may retain some information in a depersonalized or aggregated form, but not in a way that would identify you personally, for research or statistical purposes.

How we share your Personal Data

To best serve you, we may share your personal data with service providers, professional advisors, or business partners, if we are legally required to. Therefore, depending on the purposes for which we collect your personal data, we may disclose it to the following categories of recipients who deliver services either to you or to us:

the teacher you have requested to have a copy of your results;
our service providers, organisations who support the services we offer through the website, and only process personal information on our behalf, following our instructions and data protection law. Service providers help us with things like:
- - website and data hosting;
- - website analytics and search engine optimization services;
- - managing marketing lists;
- - technical assistance and support;
- - sending emails and other correspondence;
- - security and fraud prevention
- - hosting and other technology and communications services.
our business partners, suppliers, and sub-contractors, for the performance of any contract we enter into, with them or you;
our auditors, legal advisers, and other professional advisers;
any member of our group of affiliated companies, and any selected third party, provided that you consent to our sharing your information with them for marketing purposes;
third parties connected with the provision of our services and products, and solely to the extent that is required for the successful provision of our services to you and the efficient use of our products by you.li>

We may disclose personal data to a third party:

if we are under a duty to disclose or share your personal information, in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions of Service and other agreements, or to protect the rights, property, or safety of our Company, our customers, or others.
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 a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
when you ask us to do so, or when we believe it is required by law.

We will never sell or transfer your personal information to any third party, without proper authorization.

International transfers of your Personal Data

The data that we collect from you may be transferred to other countries, either within or outside the European Economic Area (EEA). It may also be processed by staff, partners, and service providers operating outside the EEA, who work for us or one of our suppliers. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it, by ensuring that the appropriate safeguards are implemented according with the applicable legislation.

About Cookies and how we use them

Cookies are general mechanisms (simply explained as small text files), which are stored on the browser or hard drive of your computer or mobile device when you visit a webpage or application. There are different types of cookies. Some cookies come directly from our website (“first party”) and others come from third parties which place cookies on our site (“third party”). Cookies can be stored for varying lengths of time on your browser or device. A “session cookie” expires immediately when you end your session (i.e., close your browser). A “persistent cookie” stores information on the hard drive, so that when you end your session and return to the same website at a later date, the cookie information is still available.

Generally, we use cookies to improve the quality of our service when you visit our website. We also use cookies to understand how visitors interact with our website. Such cookies do not collect any personally identifying information. We will not use cookies for any purpose not stated in our Cookie Policy. If you would like to opt out of accepting cookies altogether, you can generally set your browser to not accept cookies or to notify you when a cookie is sent, in order to give you the chance to decide whether or not to accept it. However, certain features of our website may not work if you delete or disable cookies.

In order to be informed in detail about our Cookie Policy, click here.

Children’s Privacy

We are deeply concerned about the protection of the personal data of children. Therefore, if you are under the age of 15 years, or equivalent minimum age depending on jurisdiction, your parents or guardians must read and agree to this Privacy Policy on your behalf. Please note that, if you are under 15 years old, or equivalent minimum age depending on jurisdiction, you are NOT permitted to provide us with any personal data, except with your parent or guardian’s consent. If we learn that we have accidentally received personal data from or about a child under 15 without the above permission, we will delete that information.

Data Security

We abide by the applicable legislation and our Privacy Policy, and we apply reasonable and appropriate technical and organizational security measures to protect your personal data against accidental destruction, loss, unauthorized alteration, disclosure or access, misuse, and any other unlawful form of processing, covering any technology infrastructure point.

We have put in place appropriate security measures to protect the confidentiality and security of information transmitted to us, such us:

we take steps to make sure that solely authorized users have access to your Personal Data, abiding by confidentiality clauses, on a need-to-know basis and to the extent necessary in order to fulfil the respective purposes.
we require our service providers to contractually promise to take steps to protect the Personal Data we give them (including limiting the information we share and requiring confidentiality commitments).
we use technical security measures (end to end encryption).

Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, to the extent permitted by law, we do not guarantee or warrant the security of any information you transmit to or from our website, and you do so at your own risk. You are also responsible for using appropriate technologies to prevent your device not being affected by viruses or similar malware.

Data Subject Rights

You are entitled to exercise the following rights, in accordance with the provisions of the applicable legislation:

The Right of Access

Under article 15 of the General Data Protection Regulation (GDPR), you have the right to request a copy of any of the personal data which are being ‘processed’ by the Company, as well as other relevant information. Please keep in mind that depending on the circumstances, we may not be able to provide all or some of the requested information.

The Right to Rectification

Under article 16 of the GDPR, you have the right to have inaccurate personal data rectified. You may also be able to have incomplete personal data completed – although this will depend on the purposes of the processing. This may involve providing a supplementary statement to the incomplete data.

The Right to Erasure

Under article 17 of the GDPR, you have the right to have your personal data erased. This is also known as the ‘right to be forgotten’. In such cases we will make every effort to erase the data relating to you, without delay, provided that one of the reasons provided by law applies and if processing or further storage is not required, i.e., if we have a legal obligation to maintain it or a legal dispute is pending. Please note that some personal data sets are impossible (or infeasible) to edit or remove (e.g., server backup or microfiche).

The Right to Restrict Processing

Under article 18 of the GDPR, you have the right to restrict the processing of your personal data in certain circumstances. This means that you can limit the way that we use your data. This is an alternative to requesting the erasure of your data. Where data processing is restricted, we will continue to hold your data, but we will not process it unless you consent to the processing, or processing is required in relation to a legal claim. Where the Company is to lift any restriction on processing, you will be informed in advance.

The Right to Data Portability

Under article 20 of the GDPR, you have the right to receive the personal data that the Company processes on you in a structured, machine-readable format, and to transmit the data to a different data controller.

The Right to Object to Processing of Data

Under article 21 of the GDPR, you have the right to object to the processing of your personal data at any time. This effectively allows you to stop or prevent us from processing your personal data, unless we demonstrate compelling legitimate grounds for the processing, which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

The Right to Withdraw your Consent

You have the right to withdraw your consent at any time, where we are relying on consent to process your personal data. If you do that, we will update our records immediately to reflect your wishes. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

How to exercise your Rights

If you have a complaint, you can contact us, using the details provided above. For your convenience, you can fill out the form that can be found here and send it to us via e-mail to online-services@mmpublications.org.uk or via registered letter to the postal address of our Company, as provided in the aforementioned form. We will do our best to help, but if you are still unhappy, you can contact the Hellenic Data Protection Authority, which is our lead supervisory authority, via the contact details provided on www.dpa.gr. Exceptionally, if you wish to withdraw your consent to our newsletters, you should either follow the link by clicking the “unsubscribe” button or send us an email.

You will not have to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee, if your request is clearly unfounded, repetitive, or excessive, considering the administrative costs of providing the information, the costs of communication, or the costs of taking the action requested. Alternatively, we may refuse to comply with your request in these circumstances.

Where your request is received, the Company will respond without undue delay, and within one month, at the latest. Where the request is complex or the Company receives several simultaneous requests, the Company may extend the timescale for response, from one month to three months. If this is the case, the Company will write to you within one month of receipt of the request, explaining the reason for the extension.

We may need to request specific information from you to confirm your identity and ensure your right on your personal data. 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.

Changes to this Privacy Policy and your duty to inform us about changes

We may make changes to this Privacy Policy and will let you know about these changes by displaying them on this website. Changes will begin to have effect at the time they are displayed. The version of the Privacy Policy that will apply to you is the one which is current at the time you use this website, or you use our services.

LAST UPDATED: February 2023