Privacy Policy

Linguaclub, registered in accordance with the legislation of The Netherlands (hereinafter — “We“, “Linguaclub”, “Company“), takes care of the privacy of the information provided by our users and visitors of the online-platform linguaclub.eu  (hereinafter — “Site“, “Platform“).

This privacy policy describes what you can expect from Linguaclub in relation to your personal information when we act as the data controller. In this document we will make clear the following questions:

• What is the personal information and how it is processed?
• 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
• Cookies.
• Your rights.
• Enquiries and time limit for response.
• Responsibility limitation.
• Data breach notification.
• Changes to the current Privacy Policy.
• 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, level of language you want to learn, 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 consists of independent contractors and freelancers. For this purpose, we collect and process the personal data of our existing freelancers as well as the data of independent contractors.

The basis for the data use.

Linguaclub 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 Dutch, English, Spanish or Russian on the Platform;
• to disseminate marketing information belonging to related services, including mailings;
• to determine and further organize the completion of the desired level of Dutch, English, Spanish, Russian
• to track and display the level of your progress;
• to collect and analyze Site usage statistics.

The basis to process the data of our freelancers/contractors may be the following:

• the need to comply with the law, when making payments;
  • personal consent;
  • the presence of a legitimate interest of 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 provisioning 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 freelancers / 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 are a number of individuals allowed to process personal data by Linguaclub.

To achieve the purposes of this document, only our contractors / freelancers, 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 contractors/ freelancers who directly interact with them.

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/freelancers where we specify the contractors’ rights and obligations on personal data protection in details.
• We additionally sign confidentiality agreements with our contractors / freelancers.
• We have differentiated the areas of responsibility for employees according to their functional responsibilities in order to eliminate the cases when many contractors 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.
• 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, bank account, credit card number) is confidential and is not liable to disclosure. Your payment 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.

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.

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 Linguaclub, 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 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 info@linguaclub.eu.

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?

Children’s privacy is one of our main concerns. At Linguaclub, we can only provide services if you, as a user, have reached the age of 13 (or you have reached the age of majority and are fully capable and legally competent to enter into agreements). If you are under the age of 13, you must obtain the permission of your parent / guardian before providing any personal information to Linguaclub. You guarantee that one of the parents or legal guardian is aware of and accepts the terms of use of our site and the Privacy Policy.

Enquiries and time limits for responses.

Linguaclub 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 Linguaclub. Linguaclub will inform you of such extension within one month of receiving the request along with the reasons for the delay.

Responsibility limitation.

While we do our best to comply with this privacy policy, however, we cannot guarantee the security of information in case of factors beyond our control that result in disclosure. The site and all information on it are presented on an “as is” basis without any warranty whatsoever. We are not responsible for any adverse consequences, as well as for any damages caused as a result of limitation of access to the site or as a result of visit to the site and use of the information placed on it.

However, our Site may contain links to other online resources that are not related to our company and belong to third parties. We are not responsible for the accuracy, completeness and reliability of information posted on third-party sites, and we do not undertake any obligation to maintain the confidentiality of the information you leave on such sites. In this case, please read the rules of use and privacy policy of the mentioned online resources.

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.

Changes to the current Privacy Policy.

We do not stand still and our business is constantly developing, in this regard we may update this Privacy Policy.
Any changes to the Privacy Policy will be posted on the Site with the date at the top of this document.
If you continue to use our Platform after 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.

Our contacts.

We hope that this Privacy Policy has helped you understand how your personal information is processed on our site. If you have any questions, please email us info@linguaclub.eu .

Linguaclub

Registered at the Chamber of Commerce Utrecht: 87513935