You Consent to This Policy

By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Policy.  Beyond this Policy, your use of the Services is subject to our Terms of Use.  If you do not agree to this Policy or our Terms of Use, you may not use the Services.

This Policy and the Terms of Use apply regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the "Contact Us" section below.

Types of Personal Information We Collect

We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with the Services, and information collected from third parties.  The categories of personal information that we collect and the purposes for which we collect that information are described below.

A. Personal Information You Provide to Us

The following list describes the categories of personal information we may collect directly from you:

1. Account and Contact Information includes first name, last name, email address, username and password.  We collect this information when you provide it directly to us such as when you sign up for the Services, creating an account through the Site, or fill out a form.  We collect this information for providing the Services, administrative purposes, and marketing and advertising our products and services.

2. Location data, if you choose to give this to us.

3. Payment and Commercial Information includes name, address, phone number, third party payment service provider-related information, debit or credit card information, purchase and participation history, or other payment processing information.  We collect this information for providing the Services and for administrative purposes.

4. Responses to Surveys and Questionnaires includes information you provide to us when you respond to marketing materials, promotions, contests, or other surveys.  We collect this information for administrative purposes and marketing and advertising our products and services

5. Social Media Information includes information that you post by sharing on a blog or another social media platform.  We collect this information for administrative purposes and marketing and advertising our products and services.  Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private.

6. User-Generated Content.  If you post, upload, comment, or otherwise submit content on the Services, we may collect certain information about you such as your name and email address and products you may have purchased.  Be aware that as a default, any information you post on the Services, including without limitation reviews, comments, and text, may be available to and searchable by all users of the Services.  We collect this information for providing the Services and administrative purposes.

7. Usage information about how you use our website, IT, communication and other systems.

8. Device ID (unique identifier) and User ID used to identify your device and account for app functionality, analytics, and subscription management.

The purposes for which we use your personal information are described in further detail in the "How We Use Personal Information We Collect" section below.

B. Personal Information Collected Automatically Through "Cookies" or Other Tracking Technologies

We may send one or more cookies to your computer or other device.  We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services.  These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services.  This information allows us to understand how you use the Services.

Cookies. Cookies are small files created by websites, including our Services, that reside on your computer's hard drive and that store information about your use of a particular website.  When you access our Services, we use cookies and other tracking technologies to:

1. Estimate our audience size and usage patterns;

2. Store information about your preferences, allowing us to customize our Services according to your individual needs;

3. Contact you to provide you with information or services that you request from us;

4. Advertise new content, events, and services that relate to your interests;

5. Provide you with more personalized content that is most relevant to your interest areas; and

6. Recognize when you return to our Services.

We set some cookies ourselves and others are set by third parties.  You can manage your cookies preference as described in the "Your Privacy Options and Configurations" section below.

Types of Cookies and Their Functions.  The following chart lists the different types of cookies that we and our service providers use on the Services, examples of who serves those cookies and links to the privacy notices and opt-out information of those cookie servers.  Because the specific cookies we use may vary over time, as well as differ by the specific page you are browsing, the below chart is illustrative only.

1. Types of Cookies: Essential

   1. Purpose: These cookies are required for the operation of the Services and enable you to move around the Services and use its features.  Disabling these cookies can negatively impact the performance of Services.

   2. Who Serves (for example):

      1. InstaEnglish

      2. Google

2. Types of Cookies: Functionality

   1. Purpose: These cookies are used to recognize you when you return to the Services.  This enables us to personalize content for you and remember your preferences.  These cookies also enable your interactions with the Services such as emailing us and customer support chat.

   2. Who Serves (for example):

      1. Google  

3. Type of Cookies: Analytics, Performance, and Research

   1. Purpose: These cookies, beacons, and pixels allow us to analyze activities on the Services.  They can be used to improve the functioning of the Services.  For example, these cookies recognize and count the number of visitors and see how they move around the Services.  Analytics cookies also help us measure the performance of our advertising campaigns to help us improve them and to optimize the content on the Services for those who engage with our advertising.

   2. Who Serves (for example):

      1. Google

      2. Meta

      3. Squarespace

4. Type of Cookies: Advertising

   1. Purpose: These cookies and pixels are used to deliver relevant ads, track ad campaign performance, or track email marketing. 

   2. Who Serves (for example):

      1. Google

      2. Meta

We do not use analytical tools in a manner that discloses to third parties that a specific person viewed specific video materials.

Cookie Retention Period.  Some cookies operate from the time you visit the Services until the end of that particular browsing session.  These cookies, which are called "session cookies," expire and are automatically deleted when you close your Internet browser.

Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your internet browser.  These cookies are called "persistent cookies" and the length of time they will remain on your device will vary from cookie to cookie.  Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.

C. Personal Information We Receive From Third Parties

We may receive additional information about you, such as demographic data, from third parties, such as travel agents or travel agencies or marketing partners and combine it with other information we have about you.

We collect most of this personal data directly from you - in person, by telephone, text, or email and/or via our website and apps. However, we may also collect information:

1. From a third party with your consent, e.g., Apple App Store, Google Play Store, Branch

2. From cookies on our website.

3. Via our IT systems, e.g.,

   1. Mobile app systems integrated with Branch (user engagement and attribution), RevenueCat (purchase and subscription data), and Google Analytics (user activity and behavior tracking).

   2. Website monitoring and analytics through Google Analytics.

   3. Cloud hosting and storage systems provided by Amazon Web Services, including metadata and operational logs.

   4. Communication systems, such as email and messaging platforms, for customer support and inquiries.

   5. Technical monitoring tools like Amazon Web Services CloudTrail for security, error logging, and debugging purposes.

   6. App Store platforms (Apple App Store and Google Play Store) for app downloads, purchases, and related user interactions.

HOW WE USE PERSONAL INFORMATION WE COLLECT

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A.   Providing Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

1. Managing your information and accounts;

2. Providing access to certain areas, functionalities, and features of our Services;

3. Answering requests for customer or technical support;

4. Communicating with you about your account, activities on our Services, and policy changes;

5. Processing your financial information and other payment methods for products or Services purchased or used;

6. Processing applications if you apply for a job we post on our Services; and

7. Allowing you to register for events.

B.    Administrative Purposes

We use your information for various administrative purposes, such as:

1. Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

2. Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

3. Measuring interest and engagement in our Services;

4. Improving, upgrading, or enhancing our Services;

5. Developing new products and services;

6. Ensuring internal quality control and safety;

7. Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;

8. Debugging to identify and repair errors with our Services;

9. Auditing relating to interactions, transactions, and other compliance activities;

10. Sharing personal information with third parties as needed to provide the Services;

11. Enforcing our agreements and policies;

12. Carrying out activities that are required to comply with our legal obligations;

13. Preventing and detect fraud against you or us; and

14. Screen for financial and other sanctions or embargoes, or other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety law or rules issued by our professional regulator.

C.   Marketing and Advertising our Products and Services

1. We may use personal information to tailor and provide you with content and advertisements.

2. We may provide you with these materials as permitted by applicable law.

3. Some of the ways we market to you include email campaigns, custom audiences advertising, and "interest-based" or "personalized advertising," including through cross-device tracking.

4. We may use personal information to conduct external audits and quality checks, e.g., for ISO or investors in People accreditation and account audits.

5. We may use personal information to share your personal data with members of our group and third parties that will or may take control or ownership of some or all our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymized where possible and only shared where necessary.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in "Contact Us" below.

D.    With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

How and Why We Use your Personal Data - More Detail

More details about how we use your personal data and why are set out in the table below.

How and Why We Use Your Personal Data - Special Category Personal Data

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:

1. We have your explicit consent.

2. The processing is necessary to protect your (or someone else's) vital interests where you are physically or legally incapable of giving consent - or -

3. The processing is necessary to establish, exercise, or defend legal claims, or for you to exercise your right to erase (See "Your Rights").

How and Why We Use Your Personal Data - Sharing

See "Who We Share Your Personal Data With" for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We will use your personal data to send you updates (by email, text message, mobile push notifications [if enabled], telephone, or post) about our services, including exclusive offers, promotions, or new services).

We have a legitimate interest in using your personal data for marketing purposes (see above "How and Why We Use Your Personal Data"). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

1. Contacting us at support@insta-english.net

2. Using the unsubscribe link in emails.

3. Replying “STOP” to any text message.

4. Disabling Notifications.

   1. You may also adjust your mobile device settings to disable notifications from us by modifying notification preferences in your device’s settings.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it to or share it with other organizations for marketing purposes.

Who We Share Your Personal Data With

We routinely share personal data with:

1. Third parties we use to help deliver our services to you, e.g., payment service providers, warehouses and delivery companies;

2. Other third parties we use to help us run our business, e.g., marketing agencies or website hosts; or

3. Third parties approved by you, e.g., social media sites you choose to link your account to or third-party payment providers.

We only allow those organizations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

1. Our and their external auditors, e.g., in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations.

2. Our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations.

3. Law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations.

4. Other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymized but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

We will not share your personal data with any other third party.

Your Personal Data With - in More Detail

More details about who we share your personal data with and why are set out in the table below.

Who We Share Your Personal Data With - Further Information

If you would like more information about who we share our data with and why, please contact us (see "How to contact us" below).

Where Is Your Personal Data Held

Personal data may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see above: "Who We Share Your Personal Data With").

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: "Transferring Your Personal Data Out of the UK/EEA".

How Long Your Personal Data Will Be Kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, we retain personal data only as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and address user requests. Retention periods are determined based on the nature of the data and its processing purposes.

Different retention periods apply for different types of personal data. Further details on retention periods can be obtained by contacting us at support@insta-english.net.

Transferring Your Personal Data Out of the UK and EEA

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

1. Our service providers located outside the UK and EEA in Japan and United States

2. Amazon Web Services, Branch, RevenueCat, Google Analytics

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

1. The UK government has decided that the particular country ensures an adequate level of protection of personal data (known as an "adequacy regulation") further to Article 45 of the UK GDPR. We rely on adequacy regulations for transfers to Japan and to U.S. companies that are certified under the UK Extension to the EU-U.S. Data Privacy Framework.

2. In the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an “adequacy decision”) further to Article 45 of the EU GDPR. We rely on adequacy decisions for transfers to Japan and to U.S. companies that are certified under the EU-U.S. Data Privacy Framework.

3. There are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you. In cases where no adequacy decision applies, we rely on legally-approved standard data protection clauses recognized or issued further to Article 46(2) of the UK GDPR or EU GDPR for such transfers.

4. A specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK or EEA, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognized or issued further to Article 46(2) and Article 45 of the UK GDPR and Article 46(2) and 45 of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK or EAA data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on "Changes to this privacy policy" below.

International Transfers of Your Personal Data Outside the UK - in More Detail

More details about the countries outside the UK to which your personal data is transferred are set out in the table below.

International Transfers of Your Personal Data Outside the EEA - in More Detail

More details about the countries outside the EEA to which your personal data is transferred are set out in the table below.

Transferring Your Personal Data Out of the UK and EEA - Further Information

If you would like further information about data transferred outside the UK/EEA, please contact us (see "How to Contact Us" below).

Your Rights

You have the following rights, which you can exercise free of charge:

For more information on each of those rights, including the circumstances in which they apply, please contact us (see "How to Contact Us" below) or see the Guidance from the UK Information Commissioner' Office (ICO) on individual's rights.

If you would like to exercise any of those rights, please:

1. Email us at support@insta-english.net

2. Email, call, or write to us - see below: "How to contact us."

3. provide enough information to identify yourself (e.g., your User ID and email address) and any additional identity information we may reasonably request from you

4. Let us know what right you want to exercise and the information to which your request relates.

Keeping Your Personal Data Secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to Complain

Please contact us if you have any queries or concerns about our use of your personal data (see below "How to Contact Us"). We hope we will be able to resolve any issues you may have.

You may also have the right to lodge a complaint with:

1. The Information Commissioner in the UK

2. Data protection regulator and/or the relevant supervisory authority in your jurisdiction. For more information, please see our data protection complaints policy OR please contact us if you would like further information.

3. For a list of relevant EEA data protection supervisory authorities and their contact details, see here.

The UK's Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.