Privacy Policy

The Fluentify.com website (collectively, the “Site”) is owned by Fluentify UK Ltd doing business as “Fluentify” (“Fluentify”, “we”, “us”, “our”). This privacy policy (“Privacy Policy”) explains the information we collect, use and disclose when you use the Site. It should be read in conjunction with our Site Terms and Conditions of Use (the “Terms”). Capitalised terms that are not defined in this Privacy Policy have the meanings given to them in the Terms and data protection legislation. This Policy also applies to any of our other websites that post this Policy.

Fluentify, as data controller under this Policy, has its registered office at 55, Ludagte Hill, EC4M 7JW (London), and is registered in the United Kingdom under entry 08423300. Our European Union representative for personal data protection legislation purposes, shall be Blinguo Development Italia Srl and may be contacted through the following e-mail: privacy@fluentify.com. Fluentify is registered under the terms of the Data Protection Act 1998 in the Information Commissioner’s Office Public Register of Data Controllers (at www.ico.org.uk).

Note that this Privacy Policy is directed to residents of the European Economic Area. In this sense, if a data subject wants to use services via our Site, processing of personal data could become necessary. Note that, if you are the individual subscribing the services for your own professional use on behalf of your company, this Policy applies also to you.

Note that this Policy applies in cases where you directly purchase Fluentify’s Services, therefore all its aspects may not be applicable in cases where you may enjoy Fluentify’s Services that were purchased by third parties and provided to you, for instance, when Fluentify’s Services were purchased by your employer. In cases where Fluentify’s Services are purchased by third parties and provided to you (e.g. your employer) Fluentify acts as data sub-processor of, for instance, your employer, who may provide your personal data to us for your registration for Fluentify’s Services. In such cases we encourage you to read the Policy of Fluentify as data sub-processor.

We ask that you read this Privacy Policy carefully as it contains important information about what to expect when we collect personal information about you and how we will use your personal data.

Categories of personal data

The following categories of personal data may be collected and processed when you access the website:

  • Identity data, for example your name, surname, image, contact data or country from which you interact with us.

  • Economic transactions, such as your payment or card data, orders, purchases or returns.

  • Connection, geolocation and/or browsing data, for example, IPAddress, Operating System, Browser Type, Browser Version, Browser Configuration, the Name of the Internet Provider, etc.

  • Commercial information for example, if you have subscribed to our newsletter.

  • Information about your preferences.

Remember that, when we ask you to fill in your personal data to give you access to any Site functionality or Fluentify’s Service, certain fields (e.g. e-mail) are compulsory, since this is information that we need to be able to provide the service or give you access to the functionality at hand.

As a general rule, Fluentify’s Services are not intended for children under the age of eighteen (18) (“Children“), and we do not knowingly collect any personal information from such Children. Children should not use or attempt to use the Site. If you are Children, please do not attempt to use the Site or send any information about yourself to Fluentify.

Collection of data and source

The Site “fluentify.com” collects a series of general data and information from the data subject. In particular, for the provision of Fluentify’s Services, we will receive your personal data directly from you, as you will be required to provide different details for the registration and the management of Fluentify’s Services.

Consider also that, in other cases, we may collect information passively, as we may use tracking tools like browser cookies and other similar technology on our Site and in communications we send you.

Why do we process your personal data

Depending on how you interact with our Site, i.e., depending on the services, products or functionalities that you wish to enjoy, we will process your personal data for the following purposes:

 

PURPOSE

Additional information

Manage your registration as user of Fluentify’s Services

If you decide to become a registered user of Fluentify’s Services, we need to process your data to identify you as a user of the Site and grant you access to its various functionalities, products and services available to you as a registered user. You may cancel your registered user in accordance with the Terms.

We hereby inform you that the data we gather regarding your activity, which have been collected through the different channels of the Site and which include your purchases, shall remain linked to your account.

For the development, performance and execution of the purchase or services contract that you executed with Us on the Site.

This purpose includes processing your data, mainly:

  • To contact you for updates or informative notices related to Fluentify’s Services, including quality surveys and to be able to establish the degree of customer satisfaction with the service;

  • The provision of Fluentify’s Services. This shall include your booked lessons and other data necessary in order to provide the service. Albeit we act as a mere intermediary between Tutors and You, this may also include the registration of some random lessons where you participate in order to verify there are no undesirable behaviours.

  • To manage payment of Fluentify’s Services that you purchase, regardless of the payment procedure used. Note that, consent to the activation of saving your payment data enables your autocompleted payment data to appear in subsequent purchases so that you do not need to introduce them in each new process, and these data will be deemed valid and effective for subsequent purchases. You may change or cancel your payment data at any time through the section on payment information.

  • To activate the mechanisms necessary to prevent and detect unauthorised uses of the Site (for example, during the purchase and returns process) as well as potential fraud being committed against you and/or against us. If we consider that the transaction may be fraudulent or we detect abnormal behaviour which indicates attempted fraudulent use of our features, products or services, this processing may result in consequences such as the blocking of the transaction or the deletion of your user account.

  • For invoicing purposes and to make available to you invoices of the purchases you have made through the Site.

  • To meet requests or applications that you make through the customer support channels.

For marketing purposes

This purpose includes the processing of your data, mainly, for:

  • To give you recommendations and offer our own products and services based on your usage of our Site and an analysis of your user profile (for example, based on your purchase and browsing history).

  • If and when you subscribe to our Newsletter, we will process your personal data to manage your subscription, including to send information on our services through various means (such as e-mail). We may also make available to you this information through push notifications in case you have activated them in your device.

Remember that you may unsubscribe from the Newsletter at any time without cost through the Site, in addition to through the instructions that we provide you with in each notice. If you do not want to receive push notifications, you can deactivate this option in your device.

  • Data enrichment: When we gather your personal data from a variety of sources, we may consolidate them under certain circumstances for the purpose of improving our understanding of your needs and preferences related to Fluentify’s Services (including for the purposes of analyses, generating user profiles, marketing studies, quality surveys and improving our interactions with our customers). This refers, for example, to the way we combine your information if you have a registered account and, using the same e-mail linked to your account, you make a purchase as a guest, or to information which is automatically compiled (such as IP and MAC addresses or metadata) which we may link with the information you have provided us directly through your activity on the Site.

  • To perform promotional actions (for example, for the organization of competitions). On participating in any promotional action, you authorise us to process the personal data that you have shared with us depending on the promotional action and disclose them through different media such as social networks or the Site itself.

Analysis of usability and quality to improve our services

If you access our Site, we inform you that we will treat your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with our Site and with the actions we implement on other websites and apps, so we can improve Fluentify’s Services.

In addition, we occasionally perform quality surveys and actions to know the degree of satisfaction of our customers and users and detect those areas in which we may improve.

Contact possibility via the website

The Site contains information that enables a quick electronic contact to our company, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject.

Legal grounds to process your data

The legal terms on which we are permitted to process your personal data also depends on the purpose for which we process them, as explained in the following table:

Purpose

Legal grounds

To manage your Site user registration

We process your data because this is necessary on the terms regulating the use of the Site. In other words, for you to be able to register as a user on the Site, we need to process your personal data, since we would otherwise be unable to manage your registration.

We consider we have a legitimate interest to link to your account your purchases and the data collected through different channels of the Site about your activity.

Development, performance and making of the purchase or services contract

We process your data because their processing is necessary for us to make the purchase or services contract with you. Certain processing of data related to the purchase process is activated only because you request or authorise it, as is the case of the storage of payment data for future purchases or the processing of data necessary to scan the till receipts through the Wallet section of the App or to provide you with the “Coming Soon” / “Back Soon” functionalities (where these functionalities are available). In these cases, our processing of your data is supported by your own consent.

We consider that we have a legitimate interest to carry out the necessary verifications to detect and prevent potential fraud or fraudulent uses of the Site, for example when you make a purchase or return. We understand that the processing of these data is positive for all the parties involved: for you, as it allows us to put in place measures to protect you against attempted fraud perpetrated by third parties; for Us, as it allows us to avoid unauthorised uses of the Site; for all our customers, as it also protects their interest by ensuring that fraudulent activities are discouraged and detected when they do occur.

Contact via Site and Customer Support

When you have no relationship at all with Us, we consider that we have legitimate interest in answering the requests or queries raised by you through the existing different contact channels.

If you are a user of Fluentify’s Services or are in a pre-contractual phase to purchase the same, and get in touch for the management of incidents related to Fluentify’s Services, the processing of your data is necessary to perform the purchase contract.

When your request is related to the exercise of your rights on which we inform you below, or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligations.

Marketing

We shall process your data for marketing purposes based on the consent that you give us. Marketing includes receiving information through multiple channels, such as push notifications in your device, in case you activate the relevant settings, or e-mail.

Analysis of usability and quality

We consider that we have a legitimate interest in analysing the Site usability and the user’s satisfaction degree, since we understand that that the processing of these data is also beneficial for your because the purpose is to improve the user experience and provide a higher quality Fluentify Service.

Students hereby consent to the processing of their personal data in the feedback that the Tutors give in order to constantly have an updated profile of the student. The feedback will be accessible to every Tutor in order for the student to be able to start where the last session ended. Tutors will not post any unlawful or offensive content concerning the student. The feedback content is solely the responsibility of the Tutor. Fluentify does not take any responsibility on the contents posted on the Student profile. Any complaint or request to this regard shall be directed to hello@fluentify.com .

Routine erasure of personal data

The time for which we will keep your data will depend on the purposes for which we process them, as explained below:

Purpose

Basis for erasure and blocking

To manage your registration for Fluentify’s Services.

We will process your data for the time during which you remain a registered user (meaning, until you decide to unsubscribe).

Development, performance of a contract

We will process your data for the time necessary to manage the purchase of the services, including potential complaints or claims related to the purchase of the service in question. Sometimes, we will only process the data until the time when you decide, as is the case of payment data that you requested us to store for future purchases (where this feature is available).

Customer Support

We will process your data for the time necessary to meet your request or application.

Marketing

We will process your data until you withdraw your consent.

Likewise, we will process your data until you unsubscribe or cancel your subscription to the newsletter.

If you participate in promotional actions, we will keep the data during a six (6) months period from the end of the action.

Analysis of usability and quality

We will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey.

Contact possibility via the website

When you make an enquiry, or contact us by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 further month(s), after which point we will delete your information.

Notwithstanding the fact that we will process your data for the time strictly necessary to achieve the purpose in question, we will subsequently keep them duly stored and protected for the time during which liability may arise for their processing, in compliance with legislation in force from time to time. Once each of the potential actions is time barred we will proceed to delete the personal data.

Disclosure of your information

To achieve the purposes mentioned in this Privacy and Cookies Policy, we must give access to your personal data to entities of the Fluentify Group and to third parties that provide us with support in the services that we offer your, i.e.:

  • Financial institutions.

  • Anti-fraud detection and prevention entities.

  • Technological and analytical service providers.

  • Providers and partners of services related to Fluentify’s Services.

  • Providers of customer support related services.

  • Service providers and collaborators related to marketing and publicity, such as advertising agencies or advertising partners.

For service efficiency purposes, some of these providers are located in territories outside the European Economic Area that do not offer a level of data protection comparable to that of the European Union. In such cases, we inform you that we transfer your data with adequate safeguards and always keeping your data safe, using the most convenient international data transfer tools. Most of our personal data transfers shall be based in an adequacy decision issued by the European Commission.

Nevertheless, whenever necessary, we may also decide to conclude Standard Contractual Clauses and any relevant supplementary measures. You may consult the content of such Standard Contractual Clauses through the following link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en.

Your rights

We undertake to keep your personal data confidential and to ensure that you may exercise your rights. We have agreed that you may exercise your rights free of charge by writing us an email to a single e-mail address: privacy@fluentify.com, simply informing us of the reason for your request and the right that you wish to exercise. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity.

In this sense, notwithstanding the purpose or legal basis we use to process your data, you have the following rights:

  • To request access to your personal data that we hold. We remind you that where you are a Platform registered user you may also consult this information in the relevant section of your online account.

  • To request that we rectify the personal data that we hold. Please bear in mind that if you are a registered user on the Site, you may also access the relevant personal data section of your online account to change or update your personal data. In any case, please take into account that, on actively making your personal data available to us through any procedure, you guarantee that they are true and accurate, and you undertake to notify to us any change or modification of your data. You will be liable for any loss or damage caused to the Site or to the person responsible for the Site or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy and Cookies Policy.

  • To request that we erase your personal data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them.

  • To request that we limit the processing of your personal data, which entails that in certain cases you can request us to temporally suspend the processing of the data or that we keep them longer than necessary.

  • If you have given us your consent to process your data for any purpose, you also have the right to withdraw such consent at any time.

  • When we are legally permitted to process your data due to your consent or to for the purposes of a contract you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data that you made available to us in a structured, commonly used and machine-legible format, to be able to transmit them to another entity directly without impediments on our part.

  • In addition, where the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data.

Finally, we inform you that you have the right to lodge a complaint before the relevant Data Protection Authority. Depending on your specific circumstances, your Data Protection Authority could be:

Changes to the Privacy and Cookies Policy

We may amend the information contained in this Privacy and Cookies Policy when we consider this appropriate. Should we do so, we will notify you by various procedures through the Platform (for example, through a banner, a pop-up or a push notification), or we may even send you a notice to your e-mail address when the change in question is relevant to your privacy, for you to be able to review the changes, assess them and, as the case may be, object or unsubscribe from ay service or functionality. In any case, we suggest you to review this Privacy and Cookies Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our Website and our App.

2. Cookies

We use cookies and similar devices to facilitate your browsing in the Platform, understand how you interact with us and, in certain cases, to be able to show you advertisements in accordance with your browsing habits. Please read our Cookies Policy to understand with greater detail the cookies and similar devices that we use, their purpose, how to manage your preferences, as well as other information of interest.

All intellectual property rights contained in this document are reserved.