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Last update: 26.07.2021
We, the company Allright Limited registered in accordance with the legislation of Cyprus, address: 67 Kennedy Avenue, Athienitis Kennedy Park, 4th Floor, Office 401, 1076 Nicosia, Cyprus, the registration number of the company: HE 418328 (hereinafter — "We", "Englishdom", "Company") take care of the privacy for the information provided by our users and visitors of the online-platform englishdom.com (hereinafter — "Website", "Platform", "Site").
- What is the personal information and its processing?
- What kind of information do we collect?
- The basis for the data use.
- How long do we store data?
- Who do we share data with?
- How do we protect personal data?
- Safety of the online payments
- Your rights according to the GDPR.
- Enquiries and time limit for response.
- Responsibility limitation.
- Data breach notification.
- Our contacts.
What is a personal information and its processing?
Personal information (or personal data) — this is any information about you that, individually or in combination with other pieces of information, allows to identify you as a person. These can be your first and last name, login, company name, e-mail address and participant ID, your location, 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, systematization, accumulation, storage, elaboration (updating, modification), retrieval, use, transmission (distribution, sharing, access), sanitization, blocking, deletion, and destruction of personal data made with or without automation tool.
What kind of information do we collect?
User account information.
We collect, process and store the information that you voluntarily provide to us upon completion of your registration on the Site. This information includes your email address and / or e-mail of a friend you have invited, your full name, date of birth, passwords, gender, interests, English level, phone number, photos, or other images uploaded to your personal profile, your location ( city, country), your skype login, statistics on your progress and skills, the number of lessons paid, as well as your data that we can get from the social networks which you are registered in, provided you register on our platform with the help of certain social networks, etc.
Information about corporate clients.
At the same time, we can collect and process payment details of our corporate partners. These data include the name of the legal entity or private entrepreneur, its registration information, including registration number, date of registration, legal and postal addresses, invoice data and list of paid services, current account and other bank details of the partner, contact phone numbers, as well as data of the representative or other authorized person of such client.
Information about our staff / contractors.
Our company does not exist autonomously, but consists of a wonderful team of staff and contractors / consultants (freelancers). For this purpose, we collect and process the personal data of our existing employees, candidates for recruitment, as well as the data of independent contractors.
The basis for the data use.
We use the data from your account because you voluntarily share it with us, so we believe that you do not mind us collecting and using such information. By your explicit affirmative action according to the Article 6 of the GDPR, you give us your consent to process these data.
Englishdom collects information for the following purposes:
- to identify you as a Site User;
- to confirm access to your account;
- to determine your preferences, interests and goals, which further helps improving your user experience while learning English on the Platform;
- to disseminate marketing information belonging to related services, including the mailshots;
- to determine and further organize the completion of the desired level of English and its specialization (English for IT, Business English etc.);
- to track and display the level of your progress;
- to collect and analyze Site usage statistics.
The basis to process the data of our employees/contractors may be the following:
- the need to comply with the law, for example, labor code or AML when making payments;
- personal consent;
- the presence of a legitimate concern in our company for such processing;
- the need to execute an already signed contract or the need to conclude a contract, at the request of the personal data owner himself.
We also use the data of our corporate partners in accordance with the rules for the provision of specific Services to fulfill the relevant contractual obligations. This information is required for the invoices preparation and billing procedures.
How long do we store data?
We will not store your data longer than it is necessary to fulfill the purpose why these data are being processed, or to comply with statutory requirements. Since we are required to administer your account, the information is stored for at least the duration of your account's activity, as the purpose of the processing requires.
We also store information about our employees / contractors throughout their entire period of work with us, after which this information is deleted, except the cases when it is impossible to delete it (for example, data from tax documents, employment records, etc.).
As for our corporate clients (partners), we will store their data until the termination of our legal relations with them, unless otherwise provided by the legislation of a particular country, or as long as they do not demand its removal, if it is possible.
Who do we share data with?
We hope you understand that our Platform does not function on its own and that there is a number of individuals allowed to process personal data by Englishdom.
To achieve the purposes of this document, only our contractors / consultants and employees, who are entrusted with such a duty in accordance with their official, employment or contractual obligations, are allowed to process personal data.
An access to corporate partner data is only available to those employees who directly interact with them.
At the same time, the access to the data about employees / contractors is available to the director of the company, as well as HR and financial department staff due to their functional responsibilities.
How do we protect personal data?
We take both organizational and technical measures to protect the data against illicit or unauthorized processing and against any accidental loss or damage. These security measures are constantly changing to meet the latest technological advances.
Organizational measures to protect personal data.
- We have initiated systematic staff briefing on the work with the users’ personal data.
- We have introduced internal documentation with rules for handling confidential information.
- We sign a Data Processing Agreement with contractors where we specify the contractors’ rights and obligations on personal data protection in details.
- We additionally sign confidentiality agreements with our employees and contractors / consultants.
- We have differentiated the areas of responsibility for employees according to their functional responsibilities in order to eliminate the cases when many employees possess important data simultaneously.
Technical measures to protect personal data.
- To prevent data theft when interacting with the Website, we use the HTTPS (Hypertext Transfer Protocol).
- We use certificates to secure your data and encrypt your communications.
- We have introduced password hashing for additional security to help you avoid unauthorized use of your account.
- We decided to entrust data storage to the professionals. Technically the data, which we collect are stored on secure, dedicated servers with specifications: PX 61-SSD machine type, Intel Xeon E3-1275 v5 Quad Core, 64 GB DDR4 ECC, 2 × 480 GB SATA SSD Data Center Series.
- We use external Web-Socket (WSS) protocols, and database / network interaction is TCP / IP.
- All database accesses occur only through trusted IPs.
We do not disclose personified information from one site visitors to the other site visitors. We never publish personified information in the public domain or pass it to the third parties. The only exceptions are the situations when the provision of such information to authorized state bodies is prescribed by the applicable law. We only publish and distribute reports based on anonymous data collected. However, the reports do not contain information that would allow anybody to identify the personified information of service users. We also use anonymous data for internal analysis, the purpose of which is to develop products and our services.
Safety of the online payments.
The personal information you provide (name, address, telephone, e-mail, credit card number) is confidential and is not liable to disclosure. Your credit card information is only transmitted in encrypted form and is not stored on our Web server.
We recommend that you check that your browser is secure enough to make payments online, on a dedicated page.
All transactions with the payment cards are in accordance with the requirements of VISA International, MasterCard and other payment systems. When transmitting information, special technologies of card online payments are applied, data processing is carried out on a secure high-tech server of a processing company.
Your rights according to the GDPR:
- Right to access your data.
- Right to rectification.
- Right to deletion ("right to be forgotten").
- The right to restrict processing.
- The right to withdraw your consent.
- Right to object to processing.
- Right to data portability.
- Are you 13 years old already?
Right to access your data.
You have the right to know what kind of your personal information is processed by Englishdom, and to receive details of such processing.
This means that you have the right to ask us to provide you with confirmation if your personal data is being processed by the company, as well as to obtain complete information about the conditions of such processing, i.e. regarding the purposes of collection and processing, the processing period, third parties who have access to information.
Right to rectification.
On our site you can also fill in and change the information in your personal user profile yourself.
However, keep in mind that your data may not always be changed. For example, when your personal information has already been used during the performance of the relevant contracts and / or it is reflected in tax documents, which are compiled in accordance with the tax legislation.
Right to deletion (“right to be forgotten”).
According to Article 17 GDPR, you may request us to delete your personal data, provided that such processing is unlawful, or if the processing is no longer necessary to achieve the purposes for which they were collected or there are other grounds set by the GDPR rules.
Right to restrict processing.
You have the right to request restrictions on the processing of your personal data in the cases provided by applicable law, namely the provisions set in Article 18 GDPR.
Right to withdraw your consent.
If we process your personal data on the basis of your consent, you have the right to ask us to withdraw such consent for appropriate processing. It is enough to write to us at [email protected].
Right to object to processing.
This means that you have the right to oppose the processing of your data for use in marketing, socio-demographic profiling and other activities provisioned under Article 21 GDPR.
Right to data portability.
You have the right to receive the personal data that you have provided to us as a controller in a structured, universal and machine-readable format, and you have the right to transfer the mentioned data to another controller provided that it is technically possible and there are no restrictions specified in Article 20 GDPR.
Are you 13 years old already?
Enquiries and time limits for responses.
Englishdom will make every reasonable effort to review your requests regarding the rights as described above in a timely manner; however you should expect our response no later than one month after the date of submission of such request. Our response time can be extended by another two months if there are many user requests in Englishdom. Englishdom will inform you of such extension within one month of receiving the request along with the reasons for the delay.
Data breach notification.
In case of a breach of your personal data protection or a high risk of breach of your rights as a data subject, we shall immediately notify you and the competent data protection institution. We also put all efforts to reduce any such risks.
If you continue to use our Platform after making changes to this document, we will consider it as an acceptance of such changes.
If you do not agree to the changes, you should stop using our Platform. If the changes are so significant that we will need your consent again, we will do so.
Registered Office Address 67 Kennedy Avenue, Athienitis Kennedy Park, 4th Floor, Office 401, 1076 Nicosia, Cyprus
Registry code: HE 418328
Your Englishdom team