English Coach is an English learning app offered by COACH AI SL (“English Coach”). Our services (“Services”) include access to a wide variety of learning content for a variety of language proficiency levels. This content is available on applications (“Apps”) for various operating systems available to download on mobile and/or tablet devices, from our website https://www.englishcoach.ai (“Website”).
1. PERSONAL DATA THAT WE COLLECT
When you interact with our Website or Apps, we collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”).
Personal Data You Give Us. When you sign up for or use the Services, you voluntarily give us certain Personal Data, including your name and email address.
If you buy a subscription to English Coach, you may be asked to provide payment information (including payment card number, security code associated with the card, expiry date), to our payment service providers (please see “Sharing and Disclosure” below).
When you use the Services, you may generate learning data such as exercise answers, learning scores, time spent completing an exercise and progress within a course, which we will collect and store for use in connection with the Services.
Please note that to answer certain exercises, namely, those which are designed to improve your pronunciation, you will need to submit voice data, which we will also collect and store for use in connection with the Services. If you would not like us to receive this data please do not use or access these Services.
We also collect data and information you choose to provide to us when you complete any “free text” boxes in our forms (for example, support requests).
We may also collect non-Personal Data, such as your time zone or first language.
Automatically Collected Data: When you use the Services, the following information is created and automatically logged in our systems:
Log data: Information (“log data”) that your browser automatically sends whenever you visit the Website, or that the Apps automatically send when you use them. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Website), browser type and settings, the date and time of your request, and how you interacted with the Services.
Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.
Usage Information: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, the other users you interact with and the time, frequency and duration of your activities e.g. Session duration; Learning Activity; Session progress; Answers
2. HOW WE USE DATA
We use the data we collect, described above:
To authenticate users, provide the Services, process transactions and respond to your requests. For users located within the EU, this use is necessary to perform the contract with you.
As necessary for certain legitimate business interests, which include the following:
To customise the learning experience and degree of difficulty to our users’ level and needs.
To better understand how visitors interact with our Website and/or Apps and ensure that our Website and/or Apps are presented in the most effective manner for you, and as part of our efforts to keep our Website, network and information systems secure.
To conduct analytics to inform our marketing strategy, enable us to enhance and personalise our communications and the experience we offer to our users and improve the quality of the current service.
Research, artificial intelligence and machine learning. We process the data collected about you for scientific research in fields relevant to English Coach. These are in particular the fields of machine learning, artificial intelligence, natural language processing and deep learning as well as tracking the efficiency of online learning.
Marketing. We will send you updates and information about our new products and services, upcoming events or other promotions or news by email or push notification. Where required by law, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving such emails by following the instructions contained in each promotional email we send you or by updating your user settings. We will continue to contact you via email regarding the provision of our Services and to respond to your requests.
If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, we will keep basic data to identify you and prevent further unwanted processing.
We may anonymise or de-identify the information that we collect and use such anonymised or de-identified data for commercial, statistical and market research purposes, including sharing it with affiliates and business partners.
3. SHARING AND DISCLOSURE
We may share your Personal Data and other information with certain third parties in the following circumstances:
Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions your Personal Data may be shared with third-party providers of hosting, email communication and customer support services, analytics, marketing and advertising. For more details on the third parties that may place cookies through the Website, please see the “Cookies” section below. Following our instructions, these parties may access, process or store Personal Data in the course of performing their duties for us.
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale of all or a portion of our assets, or transition of a service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction.
Legal Requirements: If required to do so by law, applicable regulation or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of English Coach, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the Apps, or the public, or (iv) protect English Coachagainst legal liability.
4. DATA RETENTION
5. UPDATE YOUR INFORMATION
If you need to change or correct your Personal Data, or wish to have it deleted from our systems, please contact us via email: [email protected]
6. RIGHTS UNDER EU LAW
Scope. This section provides information on your rights under EU law (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway).
Data Controller. COACH AI SL is the data controller for your Personal Data. To find out our registered office, please contact us via email: [email protected]
Your Rights. Subject to EU law, you have the following rights in relation to your Personal Data:
Right of access: If we are processing your Personal Data you can download a copy of that Personal Data.
Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to erasure: You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). If we shared your data with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
If we are relying on a legitimate interest (described under the “How We Use Data” section above) to process your Personal Data (unless we demonstrate compelling legitimate grounds for the processing); or
If we are processing your Personal Data for direct marketing.
Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.
Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorised to hear those concerns.
You may email us at [email protected] to exercise your rights.
7. LINKS TO OTHER WEBSITES
We take reasonable administrative and technical steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet is 100% secure. Therefore, while we strive to protect your data, we cannot guarantee its absolute security.
11. CONTACT US