Política de privacidad

This Privacy policy concerns the internet website LangMedia Sp. z o.o. (hereinafter referred to as website or platform) and services provided by LangMedia sp. z o.o.

Personal data administrator

The administrator of Users’ personal data (hereinafter referred to as Site Provider) is:

In order to get more information, you can contact the Data Protection Officer we have designated at . Correspondence address: Data Protection Officer LangMedia Sp. z o.o., ul. Rapackiego 5, 53-021 Breslavia, POLONIA.

In this Privacy Policy GDPR refers to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Data security

The employees of the Site Provider authorised to process personal data take part in the training in accordance with the internal Security Policy and sign statements on maintaining personal data confidentiality.

All servers on which personal data are stored are located within the European Union territory.

We make use of technical and cryptographic security solutions protecting the processed data against unauthorised access, modification or removal. We regularly install security patches on our servers.

Payments security

In the case of payment transactions, the data such as the card number are not processed on our servers, but only on the servers of the authorised companies handling payments, which make use of the security solutions compliant with the legal requirements and the regulations of the organisations that issue payment cards. These companies provide us with the information on the status of particular payment transactions.

By paying via PayPal, payment details are transferred to Paypal (Europa) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. The details are transferred pursuant to art. 6 sec. 1 letter b of GDPR and only to the extent necessary to process payments. You can find more information about data protection in the PayPal privacy policy at: www.paypal.com/pl/webapps/mpp/ua/privacy-full

By paying via PayU, payment details are transferred to PayU S.A. with its registered office in Poznań (60-166 Poznań, ul. Grunwaldzka 182), entered in the Register of Entrepreneurs kept by the District Court Poznań – Nowe Miasto and Wilda in Poznań, 8th Commercial Department of the National Court Register under KRS number 0000274399, NIP number: 779-23-08-495, Polish payment services provider monitored by the Polish Financial Supervision Authority, entered into the register of Polish payment services providers kept by the Polish Financial Supervision Authority under the number IP1/2012. The details are transferred pursuant to art. 6 sec. 1 letter b of GDPR and only to the extent necessary to process payments. You can find more information about data protection in the PayU privacy policy at: https://poland.payu.com/zasady-prywatnosci-w-payu/

What information is collected?

We collect the data related to you whenever you use our websites and applications, create an account in one of our websites, subscribe to the newsletter, participate in our competitions or contact us.

Information provided by the User while creating an account

When an account is created, we ask you to provide the following information:

• first name and surname,
• e-mail address,
• account name (login) - visible to the general public,
• access password.

The provision of this data is voluntary, but necessary to conclude an agreement to maintain your account on the platform and provide access to paid courses.

If you have a privileged account and access to the administrator panel in eTutor, you must also give your phone number to which the Site Provider will send a text message with a code to verify the person using the account.

In some cases, with the User’s prior consent, an account is created on the basis of the data provided to us by the User’s employer or other entity paying for the course on behalf of the User.

Optional account information provided by the User

When the account has been created, the User may add additional information to his or her profile:

• photo (avatar) - visible to the general public,
• phone number,
• correspondence address,
• sex,
• year of birth,
• Skype login (or another web messenger).

When you log in to the website or create an account using an external website, such as Facebook, we collect your account’s ID, first name, surname, e-mail address and gender.

The Administrator allows you to log in to the website via:

• Facebook Connect provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA or, for the users living within the territory of the EU – Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter: Facebook). It is not necessary to register if you use Facebook. In order to log in, you will be redirected to the Facebook page where you can log in with your user data. This way, the User’s Facebook profile is linked to the User’s account. You can find more information about Facebook and its privacy settings at: https://pl-pl.facebook.com/about/privacy/update
• Google account provided by Google Ireland Ltd. (Gordon House, 4 Barrow Street, Dublin, Ireland (hereinafter: Google). It is not necessary to register if you use a Google account. In order to log in, you will be redirected to the Google page where you can log in with your user data. This way the User’s Google profile is linked to the User’s account. You can find more information about Google and its privacy settings at: https://policies.google.com/privacy.

Content sent by the User

When you use our services, we collect and process the following data:

• history of orders and payments made using the sites, including the payer’s data (in case of payments made to our bank account - first name, surname, address, bank account number),
• messages sent to us by e-mail, message module on the website, contact form, chat module, social networks and by phone,
• IP addresses and information related to the devices used to access our services,
• history of using the sites and mobile applications of the Site Provider,
• learning history (including the information about the completed lessons, exercises and tests done, repetitions completed and words and grammatical structures learnt, written compositions and recordings),
• history of search queries in the websites, including queries in Diki dictionary,
• messages and comments published in the language questions section, on the forum or in the suggestions section,
• messages exchanged between the Users on the platform,
• ad views and interactions with the ads,
• lists of vocabulary and grammar elements, and other content you store on the website.

Private messages exchanged between the Users are treated as confidential and they are not disclosed to third parties without the User’s consent, except for the situation where such disclosure is required under the relevant provisions of law.

The Site offers the function of inviting other people, who have not created an account on our website yet, where the friends’ e-mail addresses can be provided in order to send invitations recommending our services to them. The provided addresses are used to send an invitation on your behalf.

Logs

When the Sites are used, the following information may be recorded each time after sending a request to the Site Provider’s server:

• date and time of sending a request,
• content and status of the request (for example URL address of the visited web page together with the enclosed parameters),
• IP address of the computer submitting the request,
• the amount of data sent in reply,
• the headers sent by the User’s device (specifying, among others, the browser, operational system, the set language, the web page from which the redirection took place, the content of cookies)

Cookies, browser history and cache memory

We make use of cookies, browser local storage (for example Web Storage) and device storage (in case of mobile applications), which may store not only the data that are necessary to provide required service (for example the data of the User’s session on the website, User’s preferences and settings), but also additional information such as unique identifiers or temporary data which make the content load faster.

We make use of cookies to store a unique identifier of the Remember me functionality, so that you don’t have to each time log on to the website with a browser / application on a particular device, unless meanwhile you log out with the Log Out button / the cookie expires / you remove the cookie and change the password to the account.

If the User does not agree to store such data on his or her device, the web browser settings can be modified accordingly. The limitation of using the mentioned mechanisms may influence the functionalities available on the Site. Also, the right browser settings enable removing previously stored data.

The Administrator also uses services provided by third parties which use cookies. The list of third parties providing these services can be changed and as for now it includes:

Google Ads – remarketing tool provided by Google LCC, which enables viewing personalized ads of the eTutor website, you can find more information at: https://policies.google.com/technologies/ads?hl=pl

Google Analytics – a tool collecting information about visits on the eTutor website, views of subpages and the time spent on the website, you can find more information at:
https://www.google.com/analytics/terms/

Facebook Pixel – a tool which enables targeting personalised ads at Facebook Users, you can find more information at:
https://www.facebook.com/privacy/explanation,

Hotjar – a tool which allows the Administrator to analyse the User’s activity on the website, including collecting data about the User’s behaviour on the website and their preferences, you can find more information at:
https://www.hotjar.com/privacy/

HubSpot - a tool which automates marketing and contacts management and monitors the User’s internet activity as well as reports on it, you can find more information at:
https://legal.hubspot.com/privacy-policy

Pixel tags

We make use of pixel tags, i.e. the elements placed in an e-mail or a website’s code, which enable monitoring the activity such as opening an e-mail or displaying a webpage.

What is the purpose and basis of processing your personal data?

We process your personal data only if we have legal basis to do so.

The purposes of processing personal data on the basis of art. 6 sec. 1 point b of the GDPR (processing required to conclude an agreement that you are a party hereto or to take actions upon your request prior to conclusion of the agreement):

• concluding and executing the agreement, which covers maintaining your account in the website and handling payments,
• providing high quality services, maintaining the services, solving technical problems,
• sending notifications about transactions made and subscriptions approaching their end,
• settle the agreement after it has been completed.

The purposes of processing personal data on the basis of art. 6 sec. 1 point c of the GDPR (fulfilling our legal obligations) are as follows:

• bookkeeping and tax settlements,
• keeping accounting documents for the period of time specified by legal regulations,
• handling complaints,
• recording the history of changes to ensure accountability of processed personal data.

The purposes of processing personal data on the basis of art. 6 sec. 1 point f of the GDPR (our legitimate interest) are as follows:

• handling Users’ inquiries sent by e-mail, contact form, or by phone,
• monitoring activity on the websites and mobile applications in order to develop the services we provide as well as increase their quality,
• settlements with the partners through which you order our services,
• direct marketing (for example informing the users about our services),
• fulfilling the obligations towards the partners who provide us with contents and software we require to provide our services,
• carrying out promotions, contests and loyalty programs you can participate in,
• improving the existing services and products (for example, the written compositions sent to us help us develop the system for detecting and correcting errors and also analyse the most frequent types of errors),
• developing new services and products,
• carrying out surveys and statistical analyses,
• offering better adjusted contents, including the search results and the content of the courses,
• improving the matching of ads, which enable us to provide some services free of charge,
• ensuring security, detecting violations, enforcing legal claims.

Profiling

We use the collected data also for profiling the Users, i.e. processing it in an automated way to anticipate the behaviour and personal preferences of the Users. However, it does not cause any legal effects towards you and does not have any relevant impact on your situation.

Who do we transfer your data to?

Personal data processing entrusted to other entities

We entrust the processing of your personal data to:

• the entities which support our IT systems, provide hosting services, data storage services, and telecommunication services, support electronic mail,
• the entities which handle payments on our behalf,
• the entities which handle bookkeeping and tax settlements,
• the entities which provide us with legal and consulting services,
• the partners which promote our services,
• the group administrators, if you use our services through an organization (for instance your employer),
• the teachers and subcontractors who provide us with services related to conducting language courses, if the service you use covers teacher’s assistance or residential course (e.g. blended learning),
• in case of lessons with a teacher, to the entities which provide supporting tools for organizing, conducting and billing the lessons.

In case of the courses paid for through another company or an organization (for instance your employer) we transfer the personal data of the course Users for the purpose of billing (first name, surname, e-mail address), and in case of some of our customers, with your consent, also for the purpose of monitoring your learning progress. Expressing such consent may be a condition to cover the costs of your course by an external entity.

Personal data processing entrusted to the entities outside the European Union

We use services of the suppliers from different countries, including the suppliers with their registered offices located outside the European Union (for example in the USA). Legal regulations related to personal data protection in these countries are different from the regulations applied in the European Union, however, we require all our suppliers to process the entrusted data in a secure way in compliance with the data protection law applied in the EU. We apply standard measures specified in the EU law, primarily appropriate contractual clauses.

Such suppliers, as of the date of this privacy policy, include Amazon Web Services with its registered office in the USA, Google Inc. with its registered office in the USA, Facebook Inc. with its registered office in the USA.

What you are entitled to

In relation to the processing of your personal data, you are entitled to request:

• access to your personal data,
• correction of the incorrect data and filling in missing information,
• to limit the processing of your personal data,
• to stop processing your personal data and profiling which results from our legitimate interests related to your specific situation,
• to stop processing your personal data for the purposes of direct marketing and profiling related to direct marketing,
• removal of the data being processed,
• removal of the data published unjustifiably on our websites,
• making the data processed in an automated way available in a structured and commonly used format, for example to transfer it to another data administrator.

The ability to exercise the abovementioned rights may depend on the legal basis for processing your personal data by us and on the purpose for processing your personal data. Please send the applications related to the processing of personal data by e-mail or by post.

You can view or modify most of the personal data related to your account at Ustawienia konta. There is also a functionality which enables you to request removal of your account.

In order to authorize the submitted applications related to personal data our employee may also ask you to provide additional information to confirm the identity of the person submitting the application.

You have the right to withdraw your consent to processing personal data at any time. The withdrawal of consent does not affect the lawfulness of processing your personal data based on consent before its withdrawal.

Data retention period

If you withdraw your consent to processing your personal data or if all the agreements which have been the basis for the processing of your personal data are terminated, your personal data shall be removed, subject that:

• We do our best to protect personal data of the Users against accidental or intentional removal. Therefore in some situations there is a delay between removal of the data in an account and removal of the copies of these elements from our servers.
• In exceptional situations (for example if there is a risk of pursuing claims related to the execution of an agreement or if the User violates these regulations or the regulations of the applicable law) we may retain the data which are required to determine the scope of violation or to pursue and defense against possible claims. However, we shall not retain the data for more than 10 years from the date of withdrawal of the consent or termination of the agreement.
• We are obligated by law to retain the data necessary for tax and accounting settlements, for the period of time specified in appropriate regulations.
• We are obligated by law to ensure accountability of stored personal data, therefore we shall store required information and documents for the period of time necessary to do so.
• The data shall not be removed if there is other legal basis for the processing of the data which override the regulations related to the interests, rights and freedoms of the User.

Supervisory authority

If you have any objections to the way we process your personal data, please contact us first. You are also entitled to make a complaint to the supervisory authority:

Urząd Ochrony Danych Osobowych (Personal Data Protection Office)
ul. Stawki 2
00-193 Warszawa
Website: https://www.uodo.gov.pl/

Changes to the Privacy Policy

The Site Provider reserves a right to make changes to this Privacy Policy, in compliance with the relevant legal regulations. The valid version of the Privacy Policy will be available on the following web page: https://www.etutor.pl/regulamin/polityka-prywatnosci/.

Privacy Policy updated on: 31 March 2023.