Last modified: 25.11.2018
This document explains how we handle personal data at Spellian. We are respectful of the data that is shared with us by our members and take protecting it very seriously.
Please take time to read these details to fully understand how we handle your data and keep it safe.
Personal data refers to any information about personal or factual circumstances of an identified or identifiable person. This includes, for example, information and details such as your name, age, gender, school name, class, mobile device identifiers, telephone number or your email address.
Your data is handled according to the following legal provisions:
With regard to data communicated in forms, etc. with your consent, Art. 6(1) (a) GDPR;
With regard to services you use for the performance of a contract, Art. 6(1) (b) GDPR;
Otherwise, with particular regard to statistical data and online identifiers based on legitimate interests, Art 6(1)(f) GDPR (see below).
What information do we collect from you and why?
We need to collect some personal information from you to allow you benefiting from the utilisation of our website. This information is stored in secure servers and we strive to limit the requirement of data from our users and teachers to the necessary to perform our activities. We will collect personal information like your name, school, country, sex and date of birth when you apply for, or use any of our products or services. We will also collect data from your use of our website and app. The type of information that we collect from you will depend on your relationship with us.
We might keep details and records of when you contact us and we contact you, like calls, emails, text messages, social media messages or other communications, User interactions and log data when you use our website(s) and app and click on our adverts on other websites (see information on cookies on our website) as well as information we receive about you from third parties such as Schools or other parties in the education world.
Regarding video and audio chats: we might monitor or record video and audio chat sessions with the intent to improve our classes and/or improve the teacher or student effectiveness. We recommend that you exercise caution in disclosing any information, personal or otherwise, during a video or chat session.
How do we collect your data and why
We collect information from you when you apply for our products and services via our websites or our app, when you talk to us on the phone, over email, by letter, via chat or social media, when you make transactions using our products and services, when you connect to our products and services using devices, such as computers and mobile phones, using cookies and other internet tracking software.
Personal data will only be collected by us to the extent and for the purpose for which you provide the data to us, for example for the registration of your account or the allocation of specific lessons or the opportunity to contact you to organise a class.
We collect information only if we have a proper reason to do so and to (i) keep our records up to date, (ii) to enact good governance, accounting, managing and auditing of our business operations, (iii) to help us to deliver and develop products and services that may be of interest to you, and to (iv) comply with all regulations and law including prevention, detection and investigation of crime.
We use and store your personal data as part of our services for the following purposes and only if you have provided us with your express consent:
If you are a teacher, to create a public profile for you.
If you are a student, to create a private profile for you.
With the intent to facilitate conversations amongst students, or with teachers, who have a desire to improve modern foreign languages, where access is restricted to members only.
We use your personal information only within the company and forward it only to those companies/individuals that are involved in providing the relevant service.
We do not share your personal details with anyone. We never cede, share, interchange any personal data of our users or teachers with anybody. The only circumstance where this might happen is if we are obliged to disclose it – for example, at the direction of a court or administrative authority.
IP addresses, web beacons and cookies.
As most websites we might use “cookies” or / and “web beacons”. Cookies are small files that your browser stores on your device in a directory designated specifically for this purpose.
We need cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) to provide and monitor the effectiveness of our Service; (d) to monitor and aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) to diagnose or fix technology problems; (f) to help you efficiently access your information after you sign in; and (g) to keep the Spellian community safe for members.
Hosting and Backend Infrastructure
This type of service has the purpose of hosting data and files that enable Spellian to run and be distributed, as well as providing a ready-made infrastructure to run specific features or parts of Spellian. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where personal data is stored.
Payment processing services enable Spellian to process payments, e.g. for Tutor lessons. To ensure greater security, Spellian does not process or store credit card details, and uses only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to you, such as emails containing invoices or notifications concerning the payment.
This type of service allows Spellian to monitor the use and behaviour of its service components, so its features, performance, operation, maintenance and troubleshooting can be improved. Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Spellian.
Managing Contacts and Sending Messages
This type of service makes it possible to communicate with users outside of the app, e.g. via push notifications and email. They may manage a database of email contacts, phone contacts or any other contact information to communicate with students or teachers. These services may also collect data concerning the date and time when the message was viewed by the user, as well as when the user interacted with it, such as by clicking on links included in the message.
Web and Mobile Analytics
The services contained in this section enable us to monitor and analyse web and mobile traffic and can be used to keep track of how Spellian is used by users.
How do we protect your Data
It is extremely important for us to protect your data and we use the latest technology to do so. We employ physical protocols and electronic measures designed to safeguard your information from unauthorized access.
In order to protect your personal data against unauthorized access by third parties when being transmitted, we secure data transmissions, if necessary, using SSL and TLS encryption. This is a standard encryption procedure for online and mobile services, particularly for the Internet.
Please note that your external security details will be stored on a third-party secure server and not on your mobile phone or computer. Your external security details will be encrypted when stored and encrypted when data is transmitted – we will not have access to your external security details.
How long do we retain your Data and how can you access it
We retain your data:
If you have consented to this as part of processing, until such time as you withdraw your consent (e.g. by deleting your account);
If we need the data to fulfil an agreement, until such time as the contractual relationship with you ceases or legal retention periods expire;
If we use the data on the basis of a legitimate interest, until such time as your overriding interest obliges us to delete or anonymize them.
As a Spellian user, you have the right to access, rectification, right to object, to complaint, erasure and blockage. More specifically:
You have the right to request information about whether and which personal data is processed by our company. You also have the right to demand that your personal data is rectified or amended or deleted.
You can withdraw your consent to the processing and use of your data completely or partially at any time with future application.
If you have any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data, you can also contact our data protection officer at the contacts below.
Our Policy on Children’s Information
If you are under 18, you may use Spellian only with the authorization of a parent or guardian or a Teacher on your behalf.
Children under 14 are not allowed to use Spellian. If you are based in the European Economic Area (EEA), you may only use Spellian if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of Spellian has been provided to us. If you are a parent or a teacher and you learn that your child or student is using Spellian and you don’t want them to, please contact firstname.lastname@example.org.
Spellian is a worldwide service. Data can be transferred to third countries outside your home country and outside the European Union. This is done on the basis of contractual regulations stipulated by law that ensure appropriate protection of your data and that are available for you to view on request.
We reserve the right to restrict access to Spellian in the event of misconduct. Providing a safe and friendly community for language learners is our top priority. We therefore take reports of abuse very seriously. Reports of misconduct on Spellian are reviewed by human moderators and can lead to a ban from our website/app.
We may modify or update this document from time to time, and so you should review this page periodically. Your continued use of the Service after any changes constitutes your acceptance of the new Privacy terms. The date of our latest update is at the beginning of this document.
You can reach us as follows:
Spellian Ltd, 63, Norroy road – SW15 1PH London, United Kingdom or at email@example.com.
We undertake to reply to questions relating to data protection within five business days.