elt Privacy Policy

Version 1.0 · Effective October 14, 2026

1. Who we are and scope

This policy explains how Executive Language Training, LLC ("elt") collects, uses, stores and protects personal data. elt is a limited liability company incorporated in Illinois, USA, at 100 Saunders Road, Suite 150, Lake Forest, IL 60045.

It covers personal data about learners on elt language and cultural training programs, contacts at our corporate clients and partners, and visitors to eltlearn.com. It applies to all elt staff, contractors and trainers who handle personal data. Data about elt's own employees is covered separately.

elt follows the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR) and applicable US privacy laws.

2. Our role: processor and controller

elt is a data processor for learner data provided by corporate clients and relocation management companies. In that role, elt processes learner data only on the client's documented instructions, as set out in the client agreement and Data Processing Agreement (DPA).

elt is a data controller for business contact data of client and partner staff, inquiries made through eltlearn.com, and learners who enroll with elt directly.

3. Personal data we collect

elt collects only the data needed to deliver training.

  • Learners: name, email address, phone number; mailing address only when in-person lessons are requested.

  • Client and partner contacts: name, job title, company, business email, business phone.

  • Website visitors: information submitted through inquiry forms.

elt does not collect government identification numbers, financial or bank account data, or special category data such as health information.

4. How we use personal data

elt uses learner data only to schedule, deliver and administer training programs, and to report program progress to the client that commissioned the training. Where elt acts as processor, the lawful basis for processing is determined by the client as controller.

Where elt acts as controller, it relies on performance of a contract and on its legitimate interest in managing client relationships. elt sends marketing emails only where permitted by law and always offers an opt-out.

elt does not sell personal data, use it for automated decision-making, or use learner data for marketing.

5. Where data is stored and who can access it

Learner data is held in elt's cloud-based program management system. Access is limited to elt staff who manage programs and to the trainer assigned to each learner.

  • Program management system: program management and learner records (United States).

  • Email and productivity suite: email and business documents (United States).

  • Backup service: automated daily backups of program records (location available to clients on request).

All three providers hold ISO 27001 certification and SOC 2 reports. A current list of named sub-processors is available to clients on request. elt will notify clients before adding or replacing a sub-processor that handles their learners' data.

Trainers are independent contractors in several countries. Each trainer is bound by written confidentiality and data protection terms, may access only the learners assigned to them, and may not copy learner data to personal storage.

6. International transfers

elt is based in the United States, stores learner data in the United States, and its trainers access that data from several countries. elt is not itself certified under the EU–US Data Privacy Framework.

  • Transfers from clients to elt: UK and EU personal data is transferred under the EU Standard Contractual Clauses and, for UK data, the UK International Data Transfer Addendum, incorporated in the client DPA.

  • Storage with sub-processors: elt's program management provider is certified under the EU–US Data Privacy Framework and its UK Extension, and elt has executed its Data Processing Agreement.

  • Onward access by trainers: trainers are bound by contractual data protection obligations no less protective than this policy.

7. Security

elt protects personal data with controls proportionate to the limited data it holds: multi-factor authentication on business systems, role-based access, encryption in transit and at rest provided by its platforms, and a company password manager. Staff and trainers receive data protection guidance when they join elt. Further detail is in elt's Information Security Policy.

8. Retention and deletion

elt keeps learner data only for the duration of the training program. Within 30 days of a program ending, learner data is deleted from elt's systems, or returned to the client if the client requests it. Copies held in elt's automated backups are deleted automatically after 90 days. Backups created before October 2026 expire on their original 12-month schedule. Records elt must keep by law, such as invoices, are retained only as long as the law requires.

9. Breach notification

If elt becomes aware of a security incident affecting a client's data, it will notify the client without undue delay and within 24 hours. The initial notice shares what is known at the time, including what happened, the data and people affected, and the steps elt is taking, with updates as the investigation progresses. Where elt is the controller, it will notify the relevant supervisory authority within 72 hours where the law requires.

10. Individual rights

Under UK and EU GDPR, individuals may request access to, correction or erasure of their personal data, restrict or object to its processing, request data portability, and withdraw consent where processing relies on it.

Where elt is the controller, it responds within one month. Where elt is the processor, it forwards the request to the client within 5 business days and assists the client in responding. Requests go to compliance@eltlearn.com. Individuals may also complain to the UK Information Commissioner's Office or their local data protection authority.

11. Contact and policy review

Questions about this policy or about data protection at elt can be sent to compliance@eltlearn.com.

This policy is reviewed annually and whenever elt's systems or processing change. See also our Cookie Policy.