e-ducateme Privacy Policy

e-ducateme is committed to protecting your personal data. We tried to write down this Privacy Policy in the most clear and plain language possible. Likewise, we tried to provide you with our privacy commitments in a transparent and easily accessible way. That said, we hope you will get all needed details to be assured your personal data is safe with us.

Before you give us your consent on the processing of your personal data or provide us with your personal data within any form on our website, we kindly ask you to read carefully this Privacy Policy, so we can be sure that you completely understand the conditions under which we would cooperate.

This Privacy Policy applies to your use of the Services of e-ducateme, as defined in our Terms & Conditions. e-ducateme offers you options concerning data we process, use and share as described in this Privacy Policy.

This Privacy Policy explains when, where, and why we process personal data about people who use e-ducateme, how we use it, the conditions under which we may disclose it to others, your rights in respect of your personal data, as well as how we keep it secure.

GENERAL

Anyone can access our Website without the necessity to register an account. Therefore, limited use of the Services is always possible without the provision of your personal details (for example, browse the Website, check how e-ducateme works, look through the list of instructors, read the e-ducateme Blog, review the variety of services etc.). However, whenever you access the Website we collect log information and put cookies on your device, by which we track your activity on the Website. You can always opt out from cookies except from those, without which the Website cannot work.

When you are a registered User e-ducateme may collect from you and process Cookie identifiers and those data you specifically provide us with upon registration, including first name, last name, email, phone number, Skype ID or social network ID (if assigned through Facebook or Google+ or if accessing Google Calendar), time zone, interface language, IP address, and device type, as well, whereas in case of Telegram subscription, your Telegram ID may also be processed by e-ducateme.

Specifically, if you are an instructor, we may also collect and process, besides the aforementioned information, the other data provided by you, including zip-code, gender, year of birth, city of living, and education experience.

Registered Users may additionally provide us with added profile pictures as well as chosen currency to perform actions pursuant to our Refund and Payment Policy.

You can find out more about the specific cases of data collection and the purposes of processing of such data in separate section of this Privacy Policy.

We may change this Privacy Policy from time to time, so please check this page to ensure that you’re happy with any changes. We will post those changes on this page and update the Privacy Policy modification date at the top of this page. The additional notifications on any amendments will be sent to your email.

Any questions regarding this Policy and our services should be sent to [email protected].

1. What is personal data and what is processing of personal data. Main definitions

Personal data is any information relating to you and that alone or in combination with other pieces of information gives the opportunity to a person that collects and processes such information to identify you as an individual.

Processing of the personal data means any operation with your personal data, whether or not by automated means, as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; means you as a user of e-ducateme.

Consent of the data subject/user is any freely given, specific, informed and unambiguous indication of the data subject/user's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. e-ducateme lawful bases for processing

e-ducateme processes your personal data only when we have lawful bases. Specifically, e-ducateme processes your personal data if:

• processing is based on the consent you have given. As such our newsletters, collection, analysis, and publication of user feedback and reviews, analysis of video lessons, and placement of different types of cookies is based on your consent;

• processing is necessary to provide our services to you according to our Terms of Service which constitute a contract between you and us as regards to information services of e-ducateme;

• processing is necessary for the purposes of our legitimate interests. Those legitimate interests are:

e-ducateme may also process information provided by you (including content and messages) that you post on/through our Website, including personally identifiable information. By so doing, you acknowledge that any information you share through the Services will be available to e-ducateme and to other users of the Services (students/instructors). You also acknowledge that parts of your content cannot be deleted from the Service as it may be connected to the Lessons created by you and used by other users (students/instructors).

From our turn and unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with the Terms of Service.

(4) Service Use, Cookies and other Similar Technologies

When you use our Services, we monitor and analyze web traffic and keep track of your behavior while using our Services. We may receive the information about your IP address, proxy server and operating system, the web browser or your mobile carrier and location based on phone settings.

(5) Billing information

Details of transactions you carry out through our Website (as ID, date and time of transaction).

(6) Enterprise

When you wish to share your contact details for more information regarding e-ducateme Enterprise one-on- one online language training for international teams, as name, email, company name and phone number.

(7) Sensitive data

Unless you expressly agree, e-ducateme does not process your sensitive data.

4. Data We Collect: Purposes

We may process your personal data you provided us voluntarily with for the purposes defined below. From our perspective, we process your personal data to personalize the use of e-ducateme to the fullest extent possible and to provide you with the high-quality Services under the Terms of Service.

(1) Provision of Services

Primarily, we process your personal data to authorize access to our Services and to fulfill our obligations under the Terms of Service for Services provision. Specifically, we use your personal data upon registration to help others (be it an instructor or a student) to find your account or profile, schedule, give and/or take lessons, and track your learning progress.

In order for you to use the Services you will need to provide payment (e.g. credit card details) and billing information through our partners – third party payment providers, which process your personal data encrypted and securely. Please see our Refund and Payment Policy for more information.

For professional training customers, we process personal data of their employees to create their accounts and connect with the most suitable instructors for further learning. Based on the data about lessons taken by such students, we provide the professional training customer with statistical reports on their employees’ performance.

Please note, that without the information provided by you under our Terms of Service, we will be unable to provide you with the functionality of our platform, connect you with other users, allow you to communicate with them and take/give lessons.

(2) Payment Services

We use third-party payment providers to bill you through an online account payment in lieu of directly processing your credit/debit card information. Your paid balance for one or more lessons is safe in your account as we use an integrated iframe for checkouts from our partners-payment providers (Braintree, Stripe, PayPal) and instructors get payment for each confirmed lesson securely through third-party payment providers (Braintree, Stripe, PayPal, TransferWise). Correspondingly all transactions are secured as our partners-payment providers use SSL encryption protection. All payment information is stored encrypted and securely by Braintree, a PayPal service. We do not store your payment information on our servers.

(3) “Tell-A-Friend”

For referral service purposes named “Tell-A-Friend”, we generate a personalized referral link for you to share with your friends to sign them up.

(4) Communications

We may also contact you via email and other ways, including through publicly available notices, for the Services-related purposes (welcoming letter, security and legal notices, announcements, e-ducateme updates, reminders, suggestions etc.). We could also use your data to enable you to communicate with other users through e-ducateme.

We may contact you by email and other ways, including through publicly available notices, for servicerelated purposes (welcome letter, security and legal notices, announcements, e-ducateme updates, reminders, suggestions etc.). We may also use your data to enable you to communicate with other users through e-ducateme, including exchanging messages, conducting video calls, and/or leaving feedback about other users.

Your contact data (including email, phone number, Skype name etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including:

- Feature development and product updates;
- Marketing activities, including publishing them on e-ducateme on other information resources; -Customer Support updates;
- Other service updates for improving your experience.

Your feedback will not be video recorded, audio recorded, or webcast by the Interviewer without obtaining consent from you first. The same applies to your voice and/or image recording.

Having received the communications from us, you are always able to opt-out to such communications in each message, excluding legal notices, or change of user settings on e-ducateme

(5) Marketing and promotion of e-ducateme

We may process your first name, last name and email on our mailing list or for the newsletter and send you messages with some commercial or promotional information about our Services. But don’t worry, we will request your consent first, and you may always opt-out from our marketing messages, using the mechanisms described under the respective link in each message, and through the user settings available on e-ducateme.

To promote e-ducateme platform through blog and influencer channels, we allow individuals to participate in the affiliate program on our Website. When we receive the information to participate in the affiliate program, we process this information to register you as an affiliate and further track the progress of the promotion of our platform.

Also, please pay attention that we may use the information provided by you as feedback. The latter, under Section 12 of the Terms of Service, may be used by e-ducateme without any additional compensation to you.

(6) Analytics and Development

In order to find the points of interest in our Services and for the purposes of analytics, we monitor and analyze web traffic and keep track of your behavior within our Services. This enables us to provide services that are relevant to you and boost the quality of our Services. The data concerned within this activity are Cookies and Usage data, such as the parts of our Services you visit, the date and duration of your visit, and type of the device you used during your visit. All your data stated in this paragraph is collected and further processed in a manner that does not allow your identification.

We may also carry out polls and surveys through e-ducateme using external GDPR-compliant services. You are not obliged to respond to them and you may opt-out of such polls and surveys through user settings. In order to inform, optimize and serve you relevant advertising based on your past use of our Services, we may process your Usage Data and Cookies.

(7) Instructor verification and program preparation

To ensure a high quality of lessons given by instructors on e-ducateme, we collect and process instructor credentials to verify their eligibility to teach subjects claimed by them. Besides that, we cooperate with the instructors and use their information to help them develop the learning programs.

(8) Support and Platform Supervision

In case of any disputes on e-ducateme and other Services-connected issues, we may use data (including communications) to resolve such matters, supervise user behavior on the platform, and respond to any complaints or requests.

(9) Competitions participation

From time to time, we conduct learning-focused competitions for individuals that meet certain criteria. Participants are required to fill in the registration forms to register for the competition and prove they are eligible. We process this information exclusively to organize and conduct the competition, determine the winner(s), and contact them regarding the results and prizes.

(10) Compliance with legal requirements

We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and/or establish our legal rights.

(11) Fraud prevention

Certain information, such as your log information, payment information and your behavior on the platform are subject to our supervision to prevent fraudulent activities on the platform and assisting you in managing your user sessions.

(12) Changes

If e-ducateme decides to change the purposes of processing specified above, we will inform you about such changes prior to the use of your personal data within the newly set purposes. The notification on such

changes will be sent to your email and you will have to provide your consent for the amended purposes unless the additional purpose of processing is compatible with those listed above.

In case you do not want to provide us the requested personal data for the purposes specified above, you may not have access to certain functions of the Services.

5. How We Share personal data?

In order to provide high-quality services, e-ducateme hires people, enters into the agreements with independent contractors as well as cooperates with other services providers, companies and organizations strictly under data processing agreement (DPA). For those reasons, some of your personal data can be passed to the persons mentioned. e-ducateme uses only secure places of storage, such as provided by AWS (Amazon, the USA) with servers located in Netherlands and the United States, and other services and applications listed below.

As we mentioned above, we also use some services to collect, manage, analyze or otherwise process your data:

(8) Areeba, PayPal, Stripe:

These are payment providers and services enabling your transfer and receipt of funds as payment for services provided via our Services.

These well-known service providers will help us to ensure that your data is secure within e-ducateme

e-ducateme has contractors and subsidiaries in other countries, who may have access to your personal data. At the same time, in all cases we pass your personal data to other persons we ensure that your personal data is being protected and used only within the purposes specified in this Privacy Policy. This is achieved by using only certified services and products, signing data processing agreements for protection of personal data with contractors and partners (including the Standard Data Protection Clauses Adopted by the European Commission and compliant with the EU data protection laws), as well as taking technical measures to ensure the information is protected when stored, used and while being processed and transferred.

By ticking the respective box when providing us with your personal data you agree to such transfer and processing within the purposes set in this Privacy Policy.

6. How long will the personal data be processed and stored by e-ducateme?

Your personal data will be stored by e-ducateme no longer than is necessary for the purposes for which the personal data is processed.

Generally, e-ducateme retains your personal data as long as your account is active. In case your account expires or you decide to delete your account e-ducateme retains your personal data not longer than 90 days after the account is expired.

However, in case of conflict situations in progress e-ducateme may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defence of legal claims and for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject in case of an expired account or in case data subject requested to delete his personal data. Upon the expiry of this period or earlier, if a conflict situation is settled, all personal data gets deleted.

As you are entitled to delete your account or profile after such a request it will be permanently removed within 30 days or earlier from our active systems, servers and back-ups. By deleting your account or profile all your personal data will be removed as well within 90 days.

Personal Data collected when you registered on our mailing list or for the newsletter will be stored as long as you are interested in receiving our emails. We consider that you’re interested in this until you unsubscribe from the mailing list or from the newsletter by clicking the respective link contained in each of our emails.

7. Your rights as data subject regarding your personal data e-ducateme processes:

• a) right of confirmation - to obtain from e-ducateme the confirmation as to whether or not personal data concerning you is being processed;

• b) right of access to your personal data processed by e-ducateme;

• c) right to rectification – ask e-ducateme to have incomplete personal data requiring corrections completed;

• d) right to erasure (right to be forgotten) – request e-ducateme to erase personal data. In most cases

e-ducateme will erase it unless otherwise required by legislation;
e) right of restriction of processing. For example, you could contest the accuracy of your personal

data or in case e-ducateme is not interested in processing of your personal data any longer, but you want e-ducateme to do this for different reasons, for example, to bring some claim for somebody and, instead of the erasure of information, its processing will be just restricted.

f) right to data portability - to have your personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others;

g) right to object to processing of your personal data by e-ducateme when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us. The other case is if we process your data for the purposes of the legitimate interests pursued by us or by a third party and you believe that such interests are overridden by your interests or fundamental rights and freedoms. If you make a request with objection to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing;

h) Right to withdraw consent at any time by contacting us. After we at e-ducateme receive such withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data, unless otherwise is set by law.

If one of the aforementioned reasons applies, please contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately. These requests are free of charge.

If you believe that our use of your data violates your rights, you can lodge a complaint with the competent data protection authority.

Please, note that when the processing of your personal data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification and we will no longer process your data with such direct marketing purposes.

8. Other Privacy Commitments

(1) Cross-border transfers

We process your personal data both within the United States and outside the United States. Although countries where we process data may have different laws, we take measures to ensure high privacy compliance (namely, as provided in Section 5 of this Privacy Policy).

(2) Time for reply and reaction

e-ducateme will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if e-ducateme is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. e-ducateme will inform you of any such extension within one month of receipt of the request, together with the reasons of such delay.

(3) Security

e-ducateme takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. For example, e-ducateme uses verified contractors that might have access to the data with which the relevant data processing agreements are signed.

(4) Children’s privacy

The privacy of children is one of our concerns. e-ducateme Services are not intended for use by children under the age of 16 without the express permission of their parent or legal guardian. If you are under the age of 16 you will need to get your parent’s/legal guardian’s permission before submitting any personal data to e-ducateme. We may process the personal data of children under the age of 16, provided that data has been consensually provided by parents/legal guardians for the express purpose of using e-ducateme Services.

e-ducateme is acting in compliance with COPPA. It requires us to inform parents and legal guardians about how we collect, use, and disclose personal information from children under the age of 13. We do not knowingly collect information from children and minors. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide information on our Website without their permission.

(5) Breach notifications

If any personal data of yours would be under the breach, we would inform you and the respective data protection agencies as to the accidents without undue delay, if there are high risks of violation of your rights as data subject. We would also do our best to minimize any such risks.

(6) “DoNotTrack” requests

e-ducateme does not share personal data with third parties for their direct marketing purposes. Also, our Services do not support “Do Not Track” requests.

9. Legal Matters

e-ducateme considers your use of its Service to be private. However, we may disclose your personal data stored in our databases, in order to:

• (1) comply with the law or legal process served on us;

• (2) enforce and investigate potential violations of this Privacy Policy; including use of this Service to participate in, or facilitate activities that violate the law;

• (3) investigate potential fraudulent activities; or

• (4) protect the rights, property, or safety of e-ducateme, its employees, its customers or the public.

We hope this Privacy Policy helped you to understand how your personal data will be dealt here e-ducateme. We will take care of your personal data, so you can use our Services and not to be concerned over your privacy. Should you have anything to tell us, e-mail us at [email protected]

We will be happy to receive any information or comment from you to make our platform better for our users.

Your e-ducateme Team