Privacy Policy Pingu’s English
Disclaimer
Pingu’s English Pakistan is an official franchise partner of Pingu’s English UK, operated under Eureka Global Education. While we follow the global standards set by our head office, this website (pingusenglish.pk) is locally managed in Pakistan.
- Important information and who we are
Pingu’s English Pakistan (referred to below as “Pingu’s English Pakistan”, “us” or “we”) respects your privacy and is committed to protecting your personal data, in compliance with applicable data protection laws in Pakistan and in line with the standards set by the UK GDPR.
This Privacy Policy tells you how we look after your personal data when you use or visit our website, regardless of where you access it from. Together with our Terms of Use relating to the pingusenglish.pk website (the “Contract”), it also explains your privacy rights and how the law protects you.
CONTACT DETAILS
COMPLAINTS
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGE
Purpose of this privacy policy
This privacy policy gives you information on how we collect and process
your personal data through your use of our website pingusenglish.pk, including
any data you may provide through the website when using any of our services or
learning materials and content.
It is important that you read this privacy policy together with any other privacy
policy or fair processing notice we may provide on specific occasions when we
are collecting or processing personal data about you so that you are fully
aware of how and why we are using your data. This privacy policy supplements
the other notices and is not intended to override them. Our website is not
intended for children and we do not knowingly collect data relating to
children.
Controller and EU representative
Eureka Global Education is the controller and responsible for your personal data. We are responsible
for overseeing questions in relation to this privacy policy and assisting you
with any issues arising out of it. 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 in section 11 below:
- The data we collect about you
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 which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name,
username or similar identifier, title, gender and country location. - Contact Data includes email address, country location and
telephone numbers. - 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. - Profile Data includes your username and password, any data
concerning your interests, preferences, feedback and responses which you
submit via the website or any free text box including but not limited to
any note or message you leave for us via the website. We do not use any
automatic profiling system to create your profile. - Usage Data includes information about how you use our
website, products and services including the full Uniform Resource
Locators (URL) clickstream to, through and from our website (including
date and time), pages and information you viewed or searched for, content
downloaded from the website, page response times, download errors, length
of visits to particular pages, page interaction information (such as
scrolling, clicks and mouse-overs), the last page viewed on our website
before leaving it and methods used to browse away from the page.
We also collect, use and share Aggregated Data such as statistical
or demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data does not
directly or indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a specific website
feature in order to analyse general trends in how users are interacting with
our website to help improve it and our service offering. However, if we combine
or connect Aggregated Data with your personal data so that it can directly or
indirectly identify you, we treat the combined data as personal data which will
be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data
about you (this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health and genetic and biometric
data). Nor do we collect any information about criminal convictions and
offences.
Messages/Notes submitted by you on the website
You are entirely free to choose which, if any, information you wish to
input and include in any message or note submitted by you on the website,
although it must be accurate and not: (i) misleading, (ii) defamatory, (iii) denigratory,
(iv) pornographic, (v) illegal or (vi) offensive to others. You don’t have to
provide any and it is your choice as to what information you do include. Please
DO NOT post or add sensitive personal data referred to above as the
Special Categories of Personal Data to your message or note on the website.
If you fail to provide personal data
Where we need to collect personal data by law, or under the Contract we
have with you or in connection with services you have contracted or wish to
contract for with us or one of our licensees or their sub-licensees 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 or provide the services or
information you have asked for. In this case, we may have to suspend or cancel
a service you want to have from us but we will notify you if this is the case
at the time.
- How is your personal data
collected?
We use different methods to collect data from and about you including
through:
- Direct interactions. You may give us your Identity Data, Contact Data
and Profile Data by filling in forms or by corresponding with us by post,
phone, LiveChat, email or otherwise. This includes personal data you
provide when you:- create an account on our website;
- use the services of the website (including any test answers you submit, any
information you submit via interactive services accessed on or via the website
such as, by way of example, virtual classes); - submit a message or note to us on or via the website in relation to services or
licences you may be interested in finding out more about; or - give us some feedback or report a problem with
the website.
- Automated technologies or interactions. As you interact with the
website, we may automatically collect Technical Data and Usage 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 for further details. - Third parties or publicly available sources. We may receive personal
data about you from various third parties and public sources as set out
below:- Technical Data from analytics
providers such as Google based outside the EEA. - Identity
Data and Contact Data from publicly available databases.
- Technical Data from analytics
- How we use your personal data
We will only use your personal data when the law allows us to. Most
commonly, we will use 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 or in relation to the licensing of products, rights or
services you have contracted for with us. - Where it is necessary for our legitimate interests (or those of a third party)
and your interests and fundamental rights do not override those interests.
We make sure we consider and balance any potential impact on
you and your rights (both positive and negative) before we process your
personal data for our legitimate interests. We do not use your personal
data for activities where our interests are overridden by the impact on
you (unless we have your consent or are otherwise required or permitted to
by law). - Where we need to comply with a legal or regulatory obligation. We will identify the relevant legal obligation when we rely
on this legal basis.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we
plan to use 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.
Please be aware that we may process your personal data for more than one
lawful ground depending on the specific purpose for which we are using your
data.
Please contact us if you need details about the specific legal ground we
are relying on to process your personal data where more than one ground has
been set out in the table below.
Purpose/Activity | Type of | Lawful |
To verify | (a) (b) | Necessary |
To | (a) (b) (c) | Performance |
To process | (a) (b) Contact (c) Financial | (a) (b) Necessary for our legitimate interests (to ensure that we are able to |
To manage (a) Notifying you about changes to our Contract or privacy policy (b) Providing you with updates in relation to products/services falling (c) Tracking referrals made by you of other third parties as users/licensees (d) Providing you with reports on franchise and licensing arrangements in | (a) (b) (c) | (a) (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to help market, develop and |
To | (a) (b) Contact (c) Technical (d) Usage | (a) (b) Necessary to comply with a legal obligation |
To |
(a) (b) Contact (c) Technical (d) Usage
| Necessary |
To deliver | (a) (b) Contact (c) Profile (d) Usage (e) | Necessary |
To use | (a) (b) Usage | Necessary |
To | (a) Identity (b) Contact (c) Profile (d) Usage (e) | Necessary |
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:
Direct Marketing from us
We will send you content and marketing materials concerning the website or
similar products or services that we believe to be appropriate and may be of
interest to you from time to time unless you have opted out of receiving
marketing. We may also analyse your Identity, Contact, Technical, Usage and
Profile Data to form a view of which products, services and offers may be of
interest to you so that we can then send you relevant marketing communications.
This processing is based on our legitimate interest in growing our business,
consisting of the benefit that we may obtain from sending commercial
communications concerning the website, or services, products and initiatives
similar to the website, to encourage users to take up such services, products
and initiatives and to become involved with and further our growth and
development.
You will receive marketing communications from us if you are one of our users
of the website, and you have not opted out of receiving that marketing.
You may opt out of receiving this content and marketing at any time by
clicking the relevant ‘opt-out’ link or by contacting us at info@eurekaglobaleducation.com.
We will get your express consent before sharing your personal data with any
third party for their own direct marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by contacting
us at info@eurekaglobaleducation.com 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 you using our services or
undertaking one of our training or learning programmes or courses. You
will also still receive service-related communications that are essential for
administrative or customer service purposes.
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 the website may become inaccessible or not
function properly. For more information about the cookies we use, please see https://www.pingusenglish.pk/cookies-policy/.
Change of purpose
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 at info@eurekaglobaleducation.com
If we need to use 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 your personal data without your knowledge
or consent, in compliance with the above rules, where this is required or
permitted by law.
- Disclosures of your personal data
We may have to share your personal data with the parties set out below for
the purposes set out in the table in paragraph 4 above.
- Other users of the website.
- Our employees.
- Specific 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 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.
We require all third parties to respect the security of your personal data
and to treat it in accordance with the law. We do not allow our third-party
service providers to use 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.
Your social profile will be visible to users of the website, so any
personal data you choose to include there will be viewable. Please DO NOT
include personal or sensitive data within your social profile which you do not
wish to be visible to third parties.
- International transfers
Many of our Specific Third Parties are based outside the European Economic
Area (EEA) so their processing of your personal data will involve a
transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring at least one of the
following safeguards is implemented:
- Where we use certain Specific Third Parties, we may use specific contracts
approved for use in respect of transmission of such data by any relevant
authority and which are intended to give personal data the same protection
it has in the UK. For further details, see European Commission: Model
contracts for the transfer of personal data to third countries, by way of
an example. - Where we share personal data with employees or providers based outside the UK,
we may transfer data to them based on relevant permitted transfer
arrangements under applicable data protection legislation, which provide
for equivalent levels of protection for personal data to those provided
within the UK.
Please contact us at info@eurekaglobaleducation.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Data security
We have put in place appropriate security measures to prevent your personal
data from being accidentally lost, used or accessed in an unauthorised way,
altered or disclosed. In addition, we limit access to your personal data to
those employees, agents, contractors and other third parties who have a
business need to know. They will only process 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.
- Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as is 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 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.
In particular, the retention policy applicable to your personal data is:
·
for the purposes necessary to verify your age: if you do not accept the
Contract, for a period of 3 weeks
after your attempt to register to the website;
·
for the purposes necessary for using the website: during the Contract and for
a period of 6 months
after the termination of the Contract;
·
for the purposes of marketing: for a period of 24 months following your last interaction
with us demonstrating an interest in receiving communications concerning us,
including requesting of information or participating in initiatives promoted by
us;
·
for the purposes of satisfying any legal, accounting, or reporting
requirements: for the maximum period provided for by the applicable law;
·
for the purposes of ascertaining, exercising or defending our rights: for a
maximum of 10 years
from when the personal data are collected or, if longer, until the end of the
potential claim or litigation.
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 your personal
data, the purposes for which we process your personal data and whether we can
achieve those purposes through other means, and the applicable legal, regulatory,
tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see Request erasure of your personal data below for further information.
In some circumstances we may anonymise your personal data (so that it can
no longer be associated with you) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in
relation to your personal data. Please click on the links below to find out
more about these rights:
- Request to access your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us at .
No fee usually required
You will not have to pay a fee to access 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 may
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
your identity and ensure your right to access 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 may 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.
- 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 (both positive and negative)
and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests
are overridden by the impact on you (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 in respect of specific activities by contacting us at info@eurekaglobaleducation.com.
Performance of the Contract means processing your data
where it is necessary for the performance of the Contract to which you are a
party or to take steps at your request before entering into the Contract.
Comply with a legal or regulatory obligation means
processing your personal data where it is necessary for compliance with a legal
or regulatory obligation that we are subject to.
THIRD PARTIES:
Specific Third Parties
- Suppliers and sub-contractors for the performance of the Contract we enter into with
you to provide educational services to you relating to the teaching of
English. This will include but is not limited to third party operators of
our affiliated learning and educational centres and teachers, based in the
United Kingdom and inside and outside the EEA. - Our IT service providers based in your local jurisdiction (i.e. the country where
you live and/or access the website from) and the United Kingdom who
provide cloud-based IT operational and data hosting systems and
administration services and accounting services. - Our newsletter and email services providers responsible for sending out email
updates and newsletters on our behalf, based in the United Kingdom and
inside and outside the EEA, such as info@eurekaglobaleducation.com. - Our remote data centre providers based in your local jurisdiction and the
United Kingdom who provide us with data storage services, such as Google
Analytics. - Our licensees and sub-licensees in your local jurisdiction who currently have
licensing arrangements in place with us where you express an interest in
becoming a licensee or sub-licensee in that jurisdiction. - Professional advisers including lawyers, bankers, auditors and insurers based within
the United Kingdom and your local jurisdiction who provide consultancy,
banking, legal, insurance and accounting services. - HM Revenue & Customs, regulators and other authorities based in the
United Kingdom and any local equivalent in your jurisdiction if/when
relevant.
YOUR LEGAL RIGHTS:
You have the right to:
Withdraw consent at any time where we are relying on your consent to process 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 certain
products or services to you. We will advise you if this is the case at the time
you withdraw your consent.
Right to object to direct marketing – You also have the absolute right to object any time to the processing of your
personal data for direct marketing purposes, as stated above.
11. Contact Details
If you have any questions
about this privacy policy or about the use of your personal data or you want to
exercise any of your privacy rights, please contact us in the following ways:
Email address: info@eurekaglobaleducation.com
Postal address: Office 804, 805, 806, Pak Avenue, opposite to Lal Kothi, Pakistan
12. Complaints
You have the right to make a complaint at any time to the Information
Commissioner’s Office, the UK regulator for data protection issues
(www.ico.org.uk). However, we would appreciate the chance to deal with your
concerns before you approach them, so please contact us in the first instance.
13. Changes to the privacy policy and your duty to inform us of changes
This version was last updated on 30th September 2025. We keep our privacy policy under regular
review.
It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us.
Please also ensure that all data you submit is accurate at the time of
submission.
14. Third-party links
Our 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. 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.