PRIVACY POLICY ENGLISHDOM

We, Allright Limited, a company registered under the laws of Cyprus, with the address: Florinis, 7, Greg Tower, 2nd floor 1065, Nicosia, Cyprus, company registration number: HE 418328 (hereinafter referred to as "We", "Englishdom", "Company"), take the privacy of our Users and visitors to the online platform englishdom.com (hereinafter referred to as "Website", "Platform", "Site") seriously.

Definitions in this Privacy Policy have the same meanings as given to them in our Terms of Use.

This Privacy Policy outlines what you can expect from the Platform regarding your personal data when we act as the data controller. In this document, we will explain the following matters:

- What is personal information and its processing?

- What information do we collect?

- The basis for data usage.

- How long do we keep the data?

- With whom do we share the data?

- How do we protect personal data?

- Online payment security.

- Cookies.

- Your rights under GDPR.

- Requests and the time frame for responses.

- Limitation of liability.

- Data breach notifications.

- Changes to this Privacy Policy.

- Contact information for communication with us.

What is personal information and its processing?

Personal information (or personal data) is any information about you that, alone or combined with other pieces of information, allows identifying you as an individual. This can be your name and surname, login, company name, email address, participant identifier, data about your location, the IP address of your device, etc., this concept is not limited to this list of examples.

Information processing means any actions (operations) with your personal data, such as collection, recording, organization, accumulation, storage, clarification (updating, change), extraction, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data, conducted using automation tools or without such use. 

WHAT INFORMATION DO WE COLLECT?

**User Account Information**

We collect, process, and store data that you voluntarily provide us with upon completing registration on the Site. Such data includes your email address and/or the email address of the friend you have invited, your full name, date of birth, passwords, gender, interests, level of English proficiency, phone number, photos or other images uploaded in your personal profile, data about your location (city, country), your Skype login, statistics of your progress and skills, the number of paid lessons, as well as your data that we may receive from social networks where you are registered, provided that you register on our platform using specific social networks, and so on.

**Corporate Clients Information**

At the same time, we may collect and process the payment details of our corporate partners. These data include the name of the legal entity or private entrepreneur, its registration data, including registration number, date of registration, legal and postal addresses, invoice data about the number and list of paid services, partner's bank accounts and other banking details, contact phones, as well as data of the representative or another authorized person of such a client.

**Information About Our Employees/Contractors**

Our company does not exist autonomously but consists of a wonderful team of employees and contractors/consultants (freelancers). For this purpose, we collect and process the personal data of our current employees, candidates during recruitment, and also data of independent contractors.

**Basis for Data Use**

We use data from your account because you voluntarily share it with us, thereby we consider that you consent to the collection and use of such information. By your explicit positive action in accordance with Article 6 of the GDPR, you give us consent to process these data.

The Company collects information for the following purposes:

- To identify you as a User of the Site;

- To confirm access to your account;

- To determine your preferences, interests, and objectives, which will further help improve your User experience when learning English on the Platform or providing Services;

- To distribute marketing information related to ancillary services, including sending emails;

- To better recommend Teachers to Students and to provide Teachers with methodological and informational support;

- To collect and analyze statistics on the use of the Platform.

The basis for processing data of our employees/contractors may be:

- The necessity to comply with legal norms, for example, labor laws or AML in making payments;

- Personal consent;

- The existence of a legitimate interest in our company in such processing;

- The necessity to perform an already concluded contract or the necessity to conclude a contract at the request of the personal data owner.

We also use data from our corporate partners in accordance with the rules of providing specific Services to fulfill relevant contractual obligations. Such information is necessary for preparing and issuing invoices. 

HOW LONG DO WE RETAIN DATA?

We will not retain your data longer than necessary to fulfill the purposes for which it is processed, or to comply with legal requirements.

As we are required to administer your account, information is retained at least for the duration of your account's activity period, as required by the purpose of processing.

We also keep information about our employees/contractors throughout the entire period of their work with us, after which such information is destroyed, except in cases where it cannot be deleted (e.g., data from tax documents, employment records, etc.).

Regarding our corporate clients (partners), we retain their data until the termination of our legal relationships with them unless otherwise provided by the legislation of a specific country, or until they wish to have them deleted, provided that it is possible.

WITH WHOM DO WE SHARE DATA?

We hope you understand that our Platform does not operate independently and there is a circle of individuals and services authorized to process personal data on behalf of the Platform.

For the purposes of this document, only those of our contractors/consultants and employees who have been assigned such a duty according to their official, labor, or contractual obligations are allowed to process personal data.

Access to corporate partners' data is only available to our employees who directly interact with them.

At the same time, access to data about employees/contractors is available to the company director, as well as HR and financial department employees, according to their functional duties. 

HOW WE PROTECT PERSONAL DATA?

We implement both organizational and technical measures to protect data from unlawful or unauthorized processing, and from any accidental loss, destruction, or damage. These security measures are continually updated to keep pace with the latest technological advancements.

Organizational Measures for Protecting Personal Data:

- Initiated systematic training for staff on handling user personal data.

- Implemented internal documentation with rules for handling confidential information.

- Data Processing Agreements are signed with contractors, detailing their rights and responsibilities regarding personal data protection.

- Non-disclosure agreements concerning confidential information are additionally signed with employees and contractors/consultants.

- Responsibilities among employees are delineated according to their job functions to prevent important data from being accessible to many employees simultaneously.

Technical Measures for Protecting Personal Data:

- To prevent data theft during interactions with the Website, we use HTTPS protocol (Hypertext Transfer Protocol Secure).

- We utilize certificates to ensure the security of your data and encryption of communication.

- Introduced password hashing for added security to help prevent unauthorized use of your account.

- Chose to entrust data storage to professionals. Technical data we collect is stored on secure, dedicated servers with specifications like PX 61-SSD, Intel Xeon E3-1275 v5 Quad Core, 64 GB DDR4 ECC, 2× 480 GB SATA SSD Data Center Series.

- Employ external Web-Socket protocols (WSS) for database interactions occurring at the transport/network level - TCP/IP.

- All database accesses are made exclusively from trusted IPs.

We do not disclose personalized data of one Site visitor to another. We never publish personalized information in the public domain or transfer it to third parties, except where such provision to authorized government bodies is required by law. We publish and distribute only reports based on collected anonymous data, which do not contain information that could be used to identify users' personalized data. We also use anonymous data for internal analysis aimed at developing our products and services. 

ONLINE PAYMENT SECURITY

The personal information you provide (name, address, phone, email) is confidential and shall not be disclosed. Your credit card details are only transmitted in encrypted form to processing centers of licensed Payment Systems.

We recommend you check if your browser is secure enough for online payments on a special page.

All operations with payment cards are carried out in accordance with the requirements of VISA International, MasterCard, and other payment systems. Special security technologies for online card payments are used for the transmission of information, and data processing is carried out on a secure, high-tech server of the processing company.

COOKIES

Like many other websites, our Platform uses cookies. These are small data files that serve as technical tracking identifiers for the purposes of statistics, marketing, analytics, etc. You can change your cookie settings at any time using your browser settings. More detailed information can be found in our Cookie Policy.

YOUR RIGHTS UNDER GDPR

- The right to access your data.

- The right to rectification.

- The right to erasure ("right to be forgotten").

- The right to restrict processing.

- The right to withdraw your consent.

- The right to object to processing.

- The right to data portability.

- Are you over 13 years old? 

THE RIGHT TO ACCESS YOUR DATA

You have the right to know which of your personal information is processed by the Platform and to receive details of such processing.

This means you have the right to request confirmation from us on whether your personal data are being processed by the company, and to receive comprehensive information about the terms of such processing, i.e., the purposes of collection and processing, the processing period, third parties who have access to the information.

THE RIGHT TO RECTIFICATION

On our website, you also have the ability to independently fill in and modify this information in your personal user profile.

However, consider that your data may not always be changeable. For example, if your personal information has already been used in fulfilling relevant contracts and/or is reflected in tax documents compiled in accordance with Tax Legislation.

THE RIGHT TO ERASURE OF YOUR DATA ("THE RIGHT TO BE FORGOTTEN")

According to Article 17 of the GDPR, you can request us to delete your personal data, provided that their processing is unlawful, or if data processing is no longer necessary for the purposes for which they were collected or otherwise processed, or other reasons provided by the GDPR rules.

THE RIGHT TO RESTRICT PROCESSING

You have the right to request a restriction of the processing of your personal data in cases provided by law, namely the provisions of Article 18 of the GDPR.

THE RIGHT TO WITHDRAW YOUR CONSENT

If we process your personal data based on your consent, you have the right to withdraw such consent for the relevant processing at any time. To do this, it is sufficient to write to us at [email protected].

THE RIGHT TO OBJECT TO PROCESSING

This means you have the right to object to the processing of your data for use in marketing, socio-demographic profiling, and other activities provided by Article 21 of the GDPR. 

THE RIGHT TO DATA PORTABILITY

You have the right to receive your personal data, which you have provided to us as the controller, in a structured, commonly used format. You also have the right to transfer these data to another controller, provided that it is technically feasible and there are no restrictions specified in Article 20 of the GDPR.

ARE YOU AT LEAST 13 YEARS OLD?

The privacy of children is one of our main concerns. At Englishdom, we can provide access to the Platform's functionalities only if you, as a User, are 13 years of age or older (or have reached the age of majority and are fully capable and legally competent to enter into agreements). If you are under 13 years old, you must obtain permission from your parents/guardians before providing any personal information to Englishdom. You guarantee that one of your parents or a legal guardian is informed about our website's Terms of Use and Privacy Policy and accepts their terms.

REQUESTS AND RESPONSE TIME

Englishdom will make all reasonable efforts to promptly consider your requests related to the rights described above. However, you should expect our response no later than one month from the date of such request submission. Our response time may be extended by an additional two months if Englishdom has a high volume of user requests. Englishdom will inform you of such an extension within one month from receiving the request, along with the reasons for the delay.

LIMITATION OF LIABILITY

We endeavor to fulfill the provisions of this privacy policy; however, we cannot guarantee the security of information in the event of factors beyond our control that result in the disclosure of information. The Platform and all information contained therein are provided on an "as is" basis without any warranties. We are not liable for any adverse consequences or any damages caused by restricted access to the site or as a result of visiting and using the information posted on it.

Additionally, our Platform may contain links to other online resources that are unrelated to our company and owned by third parties. We are not responsible for the accuracy, completeness, and reliability of the information posted on third-party sites and do not assume any obligations regarding the confidentiality of the information you leave on such sites. In this case, please familiarize yourself with the terms of use and privacy policy of the said online resources.

NOTIFICATION OF A DATA BREACH

In the event of a breach of your personal data security or the presence of a high risk of violation of your rights as a data subject, we will immediately notify you and the competent data protection supervisory authority. We also make efforts to minimize any such risks.

CHANGES TO THIS PRIVACY POLICY

Our business is constantly evolving, and we may update this Privacy Policy accordingly.

Any changes to the Privacy Policy will be posted on the Website with the date indicated at the top of this document. If you continue to use our Platform after changes to this document have been made, we will consider this as acceptance of such changes.

If you do not agree with the changes, you should stop using our Platform. If the changes are so significant that we need to ask for your consent again, we will do so.

CONTACT US

We hope this Privacy Policy has helped you understand how your personal information is processed on our site. If you have any questions, please write to us at [email protected].

Your Englishdom Team