Privacy Policy | InstaEnglish English-speaking app

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, and how and why we collect, store, use, and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).

Key Terms

It would be helpful to start by explaining some key terms used in this policy:

Key Term	Meaning
We, us, our	Westberg, InstaEnglish
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (when used for identification purposes) Data concerning health, sex life, or sexual orientation
Data subject	The individual who the personal data relates to

Personal Data We Collect About You

The personal data we collect about you depends on the services we provide to you. We will collect and use the following personal data about you:

Your name and contact information, including email address and telephone number, if you choose to give this to us
Location data, if you choose to give this to us
Your billing information, transaction and payment card information
Information about how you use our website, IT, communication and other systems
Device ID (unique identifier) and User ID used to identify your device and account for app functionality, analytics, and subscription management.

We collect and use this personal data for the purposes described in the section "How and why we use your personal data" below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How Your Personal Data is Collected

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:

From a third party with your consent, e.g., Apple App Store, Google Play Store, Branch
From cookies on our website.
Via our IT systems, e.g.,
- Mobile app systems integrated with Branch (user engagement and attribution), RevenueCat (purchase and subscription data), and Google Analytics (user activity and behavior tracking).
- Website monitoring and analytics through Google Analytics.
- Cloud hosting and storage systems provided by Amazon Web Services, including metadata and operational logs.
- Communication systems, such as email and messaging platforms, for customer support and inquiries.
- Technical monitoring tools like Amazon Web Services CloudTrail for security, error logging, and debugging purposes.
- App Store platforms (Apple App Store and Google Play Store) for app downloads, purchases, and related user interactions.

How and Why We Use Your Personal Data

Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.,

Where you have given consent;
To comply with our legal and regulatory obligations;
For the performance of a contract with you or to take steps at your request before entering into a contract; or
For our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use (process) your personal data for and why:

Data Use Purpose	Our Reasons
To provide services to you	To perform our contract with you or to take steps at your request before entering a contract
To prevent and detect fraud against you or Westberg	For our legitimate interests, i.e., to minimize fraud that could be damaging for you and/or us
To 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	To ensure we comply with professional, legal, regulatory obligations that apply to our business
To enforce legal right or defend or undertake legal proceedings	Depending on the circumstances: To comply with our legal and regulatory obligations In other cases, for our legitimate interests, i.e., to protect our business, interests and rights
To ensure adherence to business policies, e.g., policies governing security and internet use	For business operations purposes, i.e., ensure adherence to our internal procedures
To operate the business, e.g., improving efficiency, training and quality control	For legitimate interests, i.e., enhance efficiency to provide best service and price
To ensure the confidentiality of commercially sensitive information	Depending on the circumstances: For our legitimate interests, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
To conduct statistical analysis for management purposes, e.g., in relation to analyzing user behavior and engagement, evaluating marketing performance, and optimizing app and website functionality	For legitimate interests, i.e., efficiency to deliver best service at the best price
To prevent unauthorized access and modifications to systems	Depending on the circumstances: For legitimate interests, i.e., to prevent and detect criminal activity that could cause harm to you and/or us To comply with our legal and regulatory obligations
To protect the security of systems and data used to provide the services	To comply with our legal and regulatory obligations To ensure the security of systems and data exceeds the standard of our legal obligations for our legitimate interests, i.e., to protect systems and data and prevent and detect criminal activity that could cause harm to you and/or us
To update and enhance customer records	Depending on the circumstances: To perform our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations. For our legitimate interests, e.g., ensure we update customers about existing orders and new products
To use for statutory returns	To comply with our legal and regulatory obligations
To ensure safe working practices, staff administration and assessments	Depending on the circumstances: To comply with our legal and regulatory obligations For our legitimate interests, e.g., ensure adherence to internal procedures and ensure efficiency to provide the best service
To Market our services to: Existing and former customers Third parties who have previously expressed an interest in our services Third parties with whom we have had no previous dealings	For our legitimate interests, i.e., to promote our business to existing and former customers
To conduct external audits and quality checks, e.g., for ISO or investors in People accreditation and account audits.	Depending on the circumstances: For legitimate interests, i.e., to maintain accreditations to demonstrate adherence to the highest operational standards To comply with our legal and regulatory obligations
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	Depending on the circumstances: To comply with our legal and regulatory obligations In other cases, for our legitimate interests, i.e. to protect, realize or grow the value in our business and assets

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.

Purpose	Processing Operation	Lawful basis relied on under the UK GDPR and EU GDPR	Relevant categories of personal data
Communications with you not related to marketing, including changes to our terms or policies or changes to the products or other important notices (other than those addressed above)	Addressing and sending communications to you as required by data protection laws, i.e., The UK GDPR or Data Protection Act 2018 The EU GDPR	Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))	Your name, address and contact information, including email address and telephone number Your account details (username)
Comply with applicable law	Addressing and sending communications to you as required by California Consumer Privacy Act (CCPA), Act on the Protection of Personal Information (APPI), Personal Information Protection Act (PIPA)	Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))	Users in California (CCPA), Japan (APPI), and Korea (PIPA)
Comply with applicable law and ensure efficiency of service.	Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices	Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you	Your name, address and contact information, including email address and telephone number Your account details (username)

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.:

We have your explicit consent.
The processing is necessary to protect your (or someone else's) vital interests where you are physically or legally incapable of giving consent —or—
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:

Contacting us at support@insta-english.net
Using the unsubscribe link in emails.
Replying "STOP" to any text message.
Disabling Notifications.
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:

Third parties we use to help deliver our services to you, e.g., payment service providers, warehouses and delivery companies;
Other third parties we use to help us run our business, e.g., marketing agencies or website hosts; or
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:

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

Recipient	Use by Recipient	Personal Data Used
Amazon Web Services	Web and data hosting services, i.e., stores and processes a copy of your personal data on its servers for app functionality.	Any of the personal data we collect about you (see Personal Data We Collect).
Branch	Provides analytics and attribution services to measure and optimize app performance and marketing campaigns.	Device information (e.g., device ID), IP address, app interaction data (e.g., clicks, downloads), and location data (e.g., geographic location)
RevenueCat	Facilitates in-app purchase and subscription management services.	Purchase history, subscription details, user device information, and app interaction data, location data (e.g., geographic location), and IP Address
Google Analytics	Provides website and app usage analytics to monitor and improve services and customer experience.	Device information, IP address, browsing behavior on the website, and app usage statistics.

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:

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

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.
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.
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.
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.

Country	Recipient	Use by Recipient	Legal Applicability
Japan	Amazon Web Services Japan	Web and data hosting services, i.e., stores and processes a copy of your personal data on its servers for app functionality.	Legally-approved standard data protection clauses for transfers from a controller to a processor recognized or issued further to Article 45 of the UK GDPR.
Korea	Amazon Web Services Korea	Web and data hosting services, i.e., stores and processes a copy of your personal data on its servers for app functionality.	Transfers to a third country recognized as providing an adequate level of protection in accordance with Article 45 of the UK GDPR.
United States	Branch	Provides analytics and attribution services to measure and optimize app performance and marketing campaigns.	Adequacy regulation further to paragraph 5(1)(a) of Part 3 of Schedule 21 to the Data Protection Act 2018.
United States	Google Analytics	Provides website and app usage analytics to monitor and improve services and customer experience.	Adequacy regulation further to paragraph 5(1)(a) of Part 3 of Schedule 21 to the Data Protection Act 2018.
United States	RevenueCat	Facilitates in-app purchase and subscription management services.	Legally-approved standard data protection clauses for transfers from a controller to processor recognized or issued further to Article 46(2) of the UK GDPR. To obtain a copy of the adequacy finding, please contact our Data Protection Officer (see "How to contact us").

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.

Country	Recipient	Use by Recipient	Legal Applicability
Japan	Amazon Web Services Japan	Web and data hosting services, i.e., stores and processes a copy of your personal data on its servers for app functionality.	Adequacy decision: Commission Implementing Decision 2013/65/EU of 19 December 2012 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data by New Zealand.
Korea	Amazon Web Services Korea	Web and data hosting services, i.e., stores and processes a copy of your personal data on its servers for app functionality.	Commission Implementing Decision (EU) 2022/254 of 17 December 2021
United States	Branch	Provides analytics and attribution services to measure and optimize app performance and marketing campaigns.	Adequacy decision: Commission Implementing Decision 2013/65/EU of 19 December 2012 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data by New Zealand.
United States	Google Analytics	Provides website and app usage analytics to monitor and improve services and customer experience.	Adequacy decision: Commission Implementing Decision 2013/65/EU of 19 December 2012 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data by New Zealand.
United States	RevenueCat	Facilitates in-app purchase and subscription management services.	Legally-approved standard data protection clauses for transfers from a controller to a processor recognized or issued further to Article 46(2) of the EU GDPR. To obtain a copy of the adequacy finding, please contact our Data Protection Officer (see "How to contact us").

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:

Rights	Scope of Right
Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data—in certain circumstances, e.g., if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: at any time to your personal data being processed for direct marketing (including profiling) in certain other situations to our continued processing of your personal data, e.g., processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defense of legal claims
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
Right to withdraw consents	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time Withdrawal: You may withdraw consents by support@insta-english.net Effect: Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

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's Office (ICO) on individual's rights.

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

Email us at support@insta-english.net
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
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:

The Information Commissioner in the UK
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.
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.

Changes to This Privacy Policy

This privacy notice was published on January 1, 2025, and last updated on January 1, 2025.

We may change this privacy notice from time to time – when we do we will inform you via Website notification or email updates

Updating Your Personal Data

We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, e.g., your surname or address—see below "How to contact us". You can also update your personal data yourself via Users can update certain personal data, such as their name, email address, and preferences, directly through the InstaEnglish mobile app in the user account settings. For other types of personal information or if assistance is needed, users can contact InstaEnglish support via the email address provided in this privacy policy.

How to Contact Us

Individuals in the UK

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Email:
support@insta-english.net

Individuals in the EEA

We have appointed Yutaro Nishiyama to be our data protection representative within the EEA. Their contact details are support@insta-english.net.

Individuals within the EEA can contact us direct (see above) or contact our European representative.

Individuals Elsewhere

We have appointed Yutaro Nishiyama to be our data protection representative elsewhere. Their contact details are support@insta-english.net.

Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see "How to contact us" above).