Privacy Policy Last update - 07.10.2019

This Privacy Policy («Privacy Policy») details the personal data we (GrammarWay.com or Lean.GrammarWay.com) receive about you, how we process it and your rights and obligations in relation to your personal data.

Your use of GrammarWay Services is subject to your acceptance of our Terms of Use and this Privacy Policy. If you disagree with any provisions of either document, you must not use our Services.

We shall only process your personal data if: you have given us consent to do so for one or more specific purposes; you may withdraw your consent at any time; it is necessary for the performance of our contractual obligations towards you; the law requires us to do so; or we have a legitimate interest to do so. This includes processing your data for scientific research purposes, statistical purposes and direct marketing purposes, all of which are subject to additional safeguards.

This Privacy Policy will explain what your specific rights regarding to your personal data are, and how you can exercise those rights.

If you have any questions or complaints about this policy or the ways in which we process your personal data, you can contact us by email info@grammarway.com.

GrammarWay saves the right to revise this Privacy Policy from time to time. Revised policy will become effective on the date of the publication thereof on GrammarWay website or at a later date if specified in the revised policy.

In case of revising this Policy, you will be notified about it (via email or when you use The Services again). If you do not agree with the revised policy, you may terminate your user account.

Definitions

«Personal Data» means any information relating to an identified person («data subject») such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; «your personal data» means personal data relating to you.

«Processing» means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such 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.

«Restriction of Processing» means the marking of stored personal data with the aim of limiting their processing in the future.

«Filing system» means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis.

«Controller» means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

«Processor» means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

«Third Party» means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

«Consent» of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’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.

«personal data breach» means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

«Genetic data» means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question.

«Biometric data» means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data.

«Main establishment» means: as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment; as regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation.

«Representative» means a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this Regulation.

«Enterprise» means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity.

«Group of Undertakings» means a controlling undertaking and its controlled undertakings.

«Binding Corporate Rules» means personal data protection policies which are adhered to by a controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity.

«Relevant and Reasoned objection» means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union.

Information we collect

This article explains how GrammarWay collects, uses and shares user’s personal data.

Information users provide

Through the registration process, we will collect and process information as your name, e-mail address (or parent’s /custodian’s e-mail address),  age or date of birth, the Geo-location where you signed up for our services, thematerials you learn, your learning history in order to provide personalized Services. We also collect your payment transaction information and payment history in case you choose to pay for GrammarWay subscription.

We shall not process personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, your genetic data, your biometric data for the purpose of uniquely identifying you, or data concerning your health, sex life or sexual orientation. This shall not apply if one of the following applies:

– you have given us explicit consent to the processing of those personal data for one or more specified purposes;
– processing relates to personal data which you have manifestly made public; 
– processing is necessary for the establishment, exercise or defence of legal claims.

We also use user's e-mail address to send information about our services, such as upcoming changes or improvements, GrammarWay newsletters that users can freely subscribe to and unsubscribe from, and responds to user's comments and suggested amendments.

You can request the termination of your account at any time from within GrammarWay website. Upon termination of your account for whatever reason, we will delete your name and e-mail address from our production databases within 7 days. Any backups will be permanently removed after 90 days. Thereafter, we will no longer be able to track any remaining service information back to you, and therefore this information ceases to be personal data within the meaning of this policy.

Activity Data

We generate data about your use of our Services including your engagement in educational activities on the Service. We also collect technical data about how you interact with our Services - for more information see Use of Cookies.

User Payment Information

GrammarWay keeps track of the following payment information: user name, e-mail address, product brought, order id, price, currency, VAT information, payment provider, GrammarWay UI language at the time of payment, GeoIP location at the time of payments, pricing location, payment status, payment providers transaction id, subscription information to handle future payments. We retain this data for seven years as required by the law.

Use of cookies

When you enter the Website, we collect your browser type and your IP address. In addition, GrammarWay stores certain information from your browser using «cookies». A cookie is a piece of data stored on the user's computer tied to information about the user. We use session ID cookies to confirm that users are logged in. It is done in order to be able to provide our services to you and to maintain and improve the quality of our Service.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies may be necessary to provide you certain features available on the Website.

Please note that you may have cookies placed on your computer by third party websites that refer you to our Service. Although we do not share your personal data with these third party websites unless it is reasonably necessary to offer the Service, they may be able to link certain non-personally identifiable information we transfer to them with personal data they previously collected from you. Please review the privacy policies of each website you visit to better understand their privacy practices. In addition, GrammarWay  informs you that anytime you click on links (including advertising banners), which take you to third party websites, you will be subject to the third parties’ privacy policies.

You can find more information about cookies and how to manage them at http://www.allaboutcookies.org.

Use of third parties services

To support and enhance the Service, GrammarWay cooperates with a variety of third party advertising networks, marketing analytics service providers and website analysis firms, and different external processors. These providers collect and use non-personally identifiable information, such as mobile device ID, about users’ visits to and use of the Website, as well as other websites in order to serve with advertisements and content tailored to meet users’ preferences and likely interests or better understand ad effectiveness. Aggregate demographic and interest data will also be used for market research purposes.

We use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

List of data processors

Google (https://policies.google.com/privacy)
Google Analytics - tracks users activities and does demographics analysis
Google Analytics for Firebase - provides acquisition attribution and product usage data
Google Optimize - enables AB testing on Lingvist website

Sentry (https://sentry.io/privacy/) - Application quality monitoring and automatic error reporting

User data subject rights and data retention

You can manage your account settings at learn.grammarway.com/settings to update, amend, and correct your information. 

You also have the following rights in relation to the personal data GrammarWay holds about you, unless provided otherwise by local law: 

– To request access to, or erasure of, the personal data GrammarWay  holds about you.
– To request GrammarWay to restrict the processing of the personal data GrammarWay hold about you.
– To object to GrammarWay processing personal data relating to you.
– Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.
– To delete your account with GrammarWay by following the instructions available through the Service.

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you need further assistance regarding your rights, please contact GrammarWay using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Contacts

For all data privacy inquiries, any questions or concerns you have about this Privacy Policy, and for support inquiries, please contact us at info@grammarway.com