When it comes to your Personal Data (“Personal Data”), EnglishLab.Net OÜ. (“EnglishLab.Net”, "ELN", “we”, “us”), as well as our employees, contractors and service providers are committed to providing you with transparency and choice. EnglishLab.Net is committed to providing reliable and trustworthy information to our customers using a variety of means, which are supported by a comprehensive privacy program. We aim to process Personal Data in accordance with applicable legislation, while taking into account and transparently balancing the relevant interests
of our customers, ourselves and other stakeholders.
This Privacy Statement (“Statement”) provides an overview of how EnglishLab.Net, via our websites, products and services, handle privacy, and how we protect your Personal Data.
This Privacy Statement applies to the EnglishLab.Net websites, products and services that link to or reference this Statement and describes how we handle Personal Data and the choices available to you regarding collection, process, access, and how to update, correct and delete your Personal Data. Additional information on our Personal Data practices may be provided in offer descriptions, contractual terms, supplemental privacy statements, or notices provided prior to or at the time of data collection. Certain EnglishLab.Net products and services may have additional specific privacy notices that describe how we handle Personal Data for those products and services. If any other privacy notice conflicts with this Privacy Statement, such specific notice will take precedence.
What This Statement Covers
This Statement describes the following general aspects of our collection and processing of Personal Data concerning you. Please refer to our complementary product and service privacy notices for additional detail
specific to those products and services.
• What Personal Data we collect;
• How Personal Data is used and for what purposes;
• When and why Personal Data is transferred to third parties;
• How we maintain the accuracy, integrity and security of your Personal Data;
• How your Personal data is retained and destroyed;
• What individual rights available to you as it pertains to your Personal Data;
• Where applicable, how we may process the Personal Data of children under 13 years of age; and
• Who you can contact if you have any questions regarding the use of your Personal Data.
Personal Data We Collect
When you visit and use our websites, products and services, we may collect data or ask you to provide certain data, including Personal Data, about you as you use our websites, products and services and interact with us, for the purpose of helping us manage our relationship with you. "Personal Data" is any data relating to an identified or identifiable individual, and may include name, address, email address, phone number, login (account number, password), marketing preferences, social media account, or your Needs and/or Motivations in regard to Learning and/or Teaching English or Any Other Language as a Foreign or Second Language. If we link other data with your Personal Data, we will treat that linked data as Personal Data. We also collect Personal Data from trusted third party sources and engage third-parties to collect Personal Data to assist us.
This data may include:
• Contact details, such as name, mailing address, email address and phone number;
• Your tax residency data;
• Shipping and billing data, including payment data;
• Data you provide to us to receive technical assistance or during customer service interactions;
• Data about your computer or device, including browser type and settings, IP address and traffic data
relating to your Internet connection; and
• EnglishLab.Net product performance data and details about how you use our products and services.
When you choose to provide us with Personal Data about third-parties, we will only use this data for the specific reason for which you elect to provide it. It is your responsibility to ensure that when you disclose to EnglishLab.Net Personal Data of individuals other than yourself – such as your contacts, your users or other third-parties – you abide by applicable privacy and data security laws, including informing users and third-parties that you are providing their Personal Data to EnglishLab.Net, informing them of how it will be transferred, used, or processed, securing appropriate legal permissions and safeguards required for such disclosures, transfers and processing. If you choose to provide EnglishLab.Net with a third-party's Personal Data (such as name, email, and phone number), you represent that you have the third-party's permission to do so. Examples include forwarding reference or sending job referrals. You also acknowledge that when we interact with such third-party individuals
whose Personal Data you share with us, it is our duty to inform them that we obtained their Personal Data from you. Where applicable, third-parties may unsubscribe from any future communication following the link provided in the initial message or as indicated in the “Contact Us” section of this Statement. If you believe that one of your contacts has provided us with your Personal Data and you would like to request that it be removed from our database, please contact us at email@example.com
If applicable, for more information about what Personal Data we process on a product basis, please refer to the relevant product and service privacy notices accessible below.
How We Process Your Personal Data
We use your Personal Data for the purposes outlined below as well as in the relevant Product Notices on the following grounds:
On the basis of fulfilling our contract with you or entering into a contractwith you on your request, in order to:
• Create and manage your EnglishLab.Net Accounts when needed to access communications and services;
• Verify your identity and entitlement to products or services, when you contact us or access our services;
• Update you on the status of your orders;
• Manage your subscriptions; and
• Provide you with technical and customer support.
On the basis of your consent, in order to:
• Subscribe you to a newsletter, send product updates or technical alerts;
• Send you marketing communications and information on new products, services and assets;
• Communicate with you about, and manage your participation in contests, offers or promotions;
• Solicit your opinion or feedback, provide opportunities for you to test software; and
• Provide you with interest-based ads on sites other than our own.
On the basis of legal obligations, we are obligated to, for instance, keep records for tax purposes or answer compelling orders and provide information to public authorities.
On the basis of our legitimate interest in the effective delivery of our products, services and communications to you as well as to our other customers and partners, in order to:
• Communicate commercial promotions and provide quotes for our products and services;
• Research and implement product improvements and product updates;
• Evaluate and improve the performance and quality of our products, services and websites;
• Provide you with a customized experience when you visit our websites;
• Allow interoperability within our applications;
• Secure our systems and applications;
• Allow for the provisioning of services;
• Enforce our legal rights; and
• Share your data with partners for sales conversions and lead generation.
We will only process any special categories of Personal Data (“Sensitive Personal Data”) relating to you for specific purposes outlined above or in relevant Product Notices, because either:
1. You have given us your explicit consent to process that data; or
2. The processing is necessary to carry out our obligations under employment, social security or social protection law;
3. The processing is necessary for the establishment, exercise or defense of legal claims; or
4. You have made the data public.
On the basis of our legitimate interest, we and our third-party partners, may combine the data we collect from you over time from our websites, products and services with data obtained from other sources. We combine your data with other sources to improve user experience on our websites and services we provide. In some instances, EnglishLab.Net and the third-parties we engage may automatically collect data through cookies, web logs and other similar applications. This data is used to better understand and improve the usability, performance, and effectiveness of our websites, products and services to help tailor content or offers for you. Please reference the "Tracking Technologies, Cookies & Do-Not-Track" section below for more information.
On the basis of legitimate interest, we process Personal Data for network and information security purposes. Pursuant to Recital (49) of the EU General Data Protection Regulation (“GDPR”), organizations have a recognized legitimate interest in collecting and processing Personal Data to the extent strictly necessary and proportionate for the purposes of ensuring network and information security. According to said Recital (49), network and information security means the ability of a network or of an information system to resist events, attacks or unlawful or malicious actions that could compromise the availability, authenticity, integrity and confidentiality of stored or transmitted data, or the security of the related services offered by, or accessible via those networks and systems.
Both as an organization in our own right, and as a provider of cybersecurity technologies and services which may include hosted and managed computer emergency and security incident response services, it is in our legitimate interests as well as in our customers’, as laid down in Article 6(1)(f) of the GDPR, to collect and process Personal Data to the extent strictly necessary and proportionate for the purposes of ensuring the security of our own, and of our customers’ networks and information systems. This includes the development of threat intelligence resources aimed at maintaining and improving on an ongoing basis the ability of networks and systems to resist unlawful or malicious actions and other harmful events (“cyber-threats”). The Personal Data we process for said purposes includes, without limitation, network traffic data related to cyber-threats such as:
• sender email addresses (e.g., of sources of SPAM);
• recipient email addresses (e.g., of victims of targeted email cyberattacks);
• reply-to email addresses (e.g., as configured by cybercriminals sending malicious email);
• filenames and execution paths (e.g., of malicious or otherwise harmful executable files attached to emails);
• URLs and associated page titles (e.g., of web pages broadcasting or hosting malicious or otherwise harmful contents); and/or
• IP addresses (e.g., of web servers and connected devices involved in the generation, distribution, conveyance, hosting, caching or other storage of cyber-threats such as malicious or otherwise harmful contents).
Depending on the context in which such data is collected, it may contain Personal Data concerning you or any other data subjects. However, in such cases, we will process the data concerned only to the extent strictly
necessary and proportionate to the purposes of detecting, blocking, reporting (by removing any personally identifiable elements) and mitigating the cyber-threats of concern to you, and to all organizations relying on our
products and services to secure their networks and systems. When processing Personal Data in this context, we will not seek to identify a data subject unless strictly indispensable to the remediation of the cyber-threats
concerned, or required by law.
If you believe that your Personal Data was unduly collected or is unduly processed by Digital Guardian for such purposes, please refer to the “Your Rights” and “Contact Us” sections below. Please be aware that if it is
determined that Personal Data concerning you is processed by EnglishLab.Net because it is necessary for the detection, blocking or mitigation of convicted cyber-threats, in line with GDPR Article 21(1), objection, rectification or erasure requests may be rejected. It is our compelling legitimate interests to protect our organization and our
customers from cyber threats, and therefore our interest may override your objection, rectification or erasure requests until you demonstrate the measures necessary to dissociate your Personal Data from any identified
Marketing and Community Networking
EnglishLab.Net has a legitimate interest in promoting our commercial offerings and to optimize the delivery of communications to that effect to our customers and audiences that are most likely to find them relevant. We will therefore collect and process data to that end as explained below. However, where we are legally required to obtain your consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you. If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication or e-mail.
In addition to the purposes described above, we may, in compliance with applicable legal requirements, use your Personal Data to provide you with advertisements, promotions and information about products and services
tailored to you and your needs. This may include demographic data or trend data provided by third-parties, where permitted. Contact details, including phone numbers, mail and email addresses, may be used to contact you. If you do not want us to use your Personal Data in this way, you can simply choose not to consent to such use of your data on the webpages and/or forms through which such Personal Data is collected. You can also exercise this right at any time by contacting us as explained below.
We may provide your data including the data about your interests in our products to Third-Parties for the purposes of serving you more relevant ads. Where we provide you with interest-based ads on a site other than our own, we do not track your other activities on that site. If you click on our ads, we will know only the domain you came from. For more information, please see the Tracking Technologies, Cookies & Do Not Track section below.
Data from Third-Parties
Third-parties may provide us with Personal Data they have collected about you from you or from further online and offline sources, such as marketing data from our partners and third-parties that is combined with information
we already have about you, to provide you with more relevant communications and better tailored offers. We make reasonable efforts to verify that the third-parties we engage for such purposes are reputable and law-abiding and we will not solicit them to disclose to us Personal Data we do not have a lawful purpose to collect and process. However, we are not liable for any processing of your Personal Data by such third-parties prior to, during or after them providing it to us. We may combine such Personal Data with the Personal Data we already have about you to provide you with a better experience, evaluate your interest in our products or improve the quality of our offerings.
Tracking Technologies, Cookies & Do-Not-Track
A cookie is a commonly used automated data collection tool. Cookies are small text files that are placed on your computer or device by websites that you visit or HTML-formatted emails you open, to make websites work, or
• Ensure the proper functioning of our websites and the proper delivery of legitimate electronic communications;
• Tailor information presented to you based on your browsing preferences, such as language and geographical region;
• Collect statistics regarding your website usage;
• Provide us with business and marketing information; and
• In some cases, to enable a third-party to deliver future advertising for our products and services to you when you visit certain websites owned by third-parties.
We use different kinds of cookies:
• Essential cookies are necessary to provide you with services and features available through our websites.
Without these cookies, services you may need, cannot be provided.
• Analytics or customization cookies collect data that is either used in aggregate form to help us understand how the website is being used or how effective our marketing campaigns are, or to help us customize the website for you.
• Advertising cookies and tracking scripts are used to make advertising messages more relevant to you.
They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly delivered and, in some cases, featuring ads based on your interests. If your website includes a
cookie management tool, you will find a hover button at the bottom of your screen.
If you do not wish to receive cookies you may be able to refuse them by not agreeing to the use of them upon entering the website. If you do so, we may be unable to offer you some of our functionalities, services or support.
If you have previously visited our websites, you may also have to delete any existing cookies from your browser.
We gather certain data automatically and store it in log files. This data may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp,
and/or click-stream data. We may combine this log data with other data we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
We use local storage, such as HTML5, to store content data and preferences. Third-parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store data. Various browsers may offer their own management tools for removing HTML5
There are different ways you can prevent tracking of your online activity. One of them is setting a preference in your browser that alerts websites you visit that you do not want them to collect certain data about you. This is referred to as a Do-Not-Track (“DNT”) signal. Please note that our websites may not recognize or act in response to DNT signals from web browsers. There is currently no universally-accepted standard for what a company should do when a DNT signal is detected. In the event a final standard is established, we will assess how to appropriately respond to these signals. For more detailed information about cookies, Do-Not-Track and other tracking technologies, please visit www.allaboutcookies.org and https://allaboutdnt.com.
Third-Party Data Collection
Cookies may also be placed by third-parties to deliver tailored information and content which may be of interest to you, such as promotions or offerings, when you visit third-party websites after you have left our websites. We do not permit these third-parties to collect Personal Data about you beyond such cookies (e.g., email address) on our site.
Social Media Features and Widgets
How to Opt out of Interest-based Advertising
browsing activities and interests. If you do not wish to receive cookies you may be able to refuse them If you wish to opt out of interest-based advertising, you can do so by not agreeing to the use of them upon entering the website. Please note that if you opt out, you will continueto receive generic ads not based on your interests.
Automated Individual Decision-Making and Profiling
Where EnglishLab.Net processes network traffic data for the purpose of network and information security based on our or our customers’ legitimate interest as outlined in the corresponding section of this Statement, automated decisions concerning particular data elements may occasionally be made. This could involve in particular assigning relative cyber security reputation scores to IP addresses and URLs based on objective cyber-threat indicators measured by our cyber-threat detection engines. Such indicators may be for instance the determination that malicious or otherwise harmful contents are hosted at a given URL, or are emanating from a given IP address. Such automatically-assigned reputation scores may be leveraged by you, by EnglishLab.Net, by our partners and by other customers to detect, block and mitigate the identified cyber-threats. They could therefore result in our products and services blocking network traffic coming from or going to such URLs and IP addresses. No such processing is intended to produce any other effect than protecting you, EnglishLab.Net, our partners and our other customers from cyber-threats. Should you nevertheless consider that such automated processing is unduly affecting you in a significant way, please contact directly the relevant data controller whose use of our products and services is thus impacting you. In case that data controller is EnglishLab.Net, please refer to the “Your Privacy Rights” and “Contact Us” sections of this Statement to raise your concerns and to seek our help in finding a satisfactory solution.
How We Disclose Your Personal Data
We do not sell, lease, rent or give away your Personal Data. We only disclose your Personal Data as described below, within EnglishLab.Net, with our partners, with service providers that process data on our behalf and with public authorities, as required by applicable law. Processing is only undertaken for the purposes described in this Statement and the relevant product and service privacy notices. If we disclose your Personal Data, we require its recipients to comply with adequate privacy and confidentiality requirements, and security standards.
We may provide your Personal Data to our partners for the purpose of allowing them to conduct EnglishLab.Net business. Our partners may use your Personal Data to communicate with you and others about EnglishLab.Net products or services. If you do not wish to receive
pomotional emails from our partners, you can unsubscribe directly using the unsubscribe link or tool provided in the partner’s email or other communication to you.
Service Providers Processing Data on Our Behalf
We may use contractors and service providers to process your Personal Data on our behalf for the purposes described in this Statement and the relevant product and service privacy notices accessible below. We contractually require service providers to keep data secure and confidential and we do not allow our data processors to disclose your Personal Data to others without our authorization, or to use it for their own purposes. However, if you have an independent relationship with these service providers their privacy statements will apply to such relationships. Such service providers may include in particular contact centers, payment card processors and marketing/survey/analytics suppliers.
In certain instances, it may be necessary for EnglishLab.Net to disclose your Personal Data to public authorities or as otherwise required by applicable law. No Personal Data will be disclosed to any public authority except in response to:
• A subpoena, warrant or other process issued by a court or other public authority of competent jurisdiction;
• A legal process having the same consequence as a court-issued request for data, in that if EnglishLab.Net were to refuse to provide such data, it would be in breach of local law, and it or its officers, executives or employees would be subject to liability for failing to honor such legal process;
• Where such disclosure is necessary for EnglishLab.Net to enforce its legal rights pursuant to applicable law;
• A request for data with the purpose of identifying and/or preventing credit card fraud; or
• Where such disclosure of Personal Data is necessary to prevent or lessen a serious and imminent threat of bodily or other significant harm to the data subject or other individuals potentially concerned.
Cross-Border Transfers of Personal Data among EnglishLab.Net Entities and to Third-Party Vendors
We are a global company and, as such, we process data in many countries. To conduct our business, and in accordance with this Statement, your Personal Data may be transferred to EnglishLab.Net in Estonia,
and to subsidiaries and third-party vendors of EnglishLab.Net located worldwide. All transfers will occur in compliance with data transfer requirements of applicable laws and regulations. Where Personal Data originating from the European Economic Area is transferred to EnglishLab.Net entities or to third-party vendors engaged by
EnglishLab.Net to process such Personal Data on our behalf who are located in countries that are not recognized by the European Commission as offering an adequate level of Personal Data protection, such transfers are covered by alternate appropriate safeguards, specifically standard data protection clauses adopted by the European Commission. If applicable to you, you may obtain copies of such safeguards by contacting firstname.lastname@example.org
In the process of continuing to develop our business, we may also occasionally acquire subsidiaries or other business entities. As a result of such transactions, and for maintaining a continued relationship with you, we may transfer your Personal Data to a related affiliate.
If we are involved in a reorganization, merger, acquisition or sale of our assets, your Personal Data may be transferred as part of that transaction. We will notify you of any such deal and outline your choices in that event.
How We Protect Your Personal Data
We take reasonable and appropriate administrative, technical, organizational, and physical security and risk management measures in accordance with applicable laws to ensure that your Personal Data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your Personal Data in our possession.
Securing Personal Data is an important aspect of protecting privacy. Our security organization applies policies, standards and supporting security controls at the level appropriate to the risk level and the services provided. In addition, appropriate security controls are communicated to application owners and technology teams across the business to support secure development of products and a secure operating environment.
We pay specific attention to the protection of Personal Data and the risks associated with processing this data.
Measures we take to protect Personal Data include:
We lock doors and file cabinets, control access to our facilities, implement a clean desk policy, and apply secure destruction to media containing your Personal Data.
We use network and information security technologies such as anti-virus and EnglishLab.Net endpoint protection software, encryption, intrusion detection and data loss prevention, and we monitor our systems and data centers to ensure that they comply with our security policies. For example confidential information is transmitted using Transport Layer Security (“TLS”) encryption.
We conduct regular company-wide, as well as role-specific and targeted training and awareness programs on security and privacy, to make sure that our employees and contractors understand the importance of protecting your Personal Data, and that they learn and maintain the necessary knowledge and skills effectively to protect it in
Personal Data Breaches
EnglishLab.Net takes every reasonable measure to prevent Personal Data breaches. When these do occur, we have a process in place to take swift action within our responsibilities. These actions will be consistent with the
role we have in relation to the products,services or processes affected by the breach. In all cases, we will work together with affected parties to minimize effects, to make all notifications and disclosures that are required by applicable law or otherwise warranted, and to take action to prevent future breaches. We systematically outline responsibilities in case of Personal Data breaches in our contracts, both with customers as well as with our vendors.
Storage of Your Personal Data
The data we collect from you may be stored, with risk-appropriate technical and organizational security measures applied to it, on in-house as well as third-party servers in Estonia, as well as anywhere EnglishLab.Net
or our vendors operate.
Links to Other Websites
Our websites may contain links to other websites, which are owned or operated by other companies. If you choose to visit any linked websites, we encourage you to review their privacy statements carefully, as they may differ from ours. We are not responsible for the content or privacy practices of websites that are owned by companies that are not within EnglishLab.Net Corporation. Our websites may also link to co-branded websites that are maintained by EnglishLab.Net and one or more of our business partners, who are collecting your Personal Data pursuant to their own privacy practices. We encourage you to read the privacy statements on any co-branded site to which you link for information on the privacy practices of that site.
Our websites are not directed to, nor do we knowingly collect data from, children under 13 years of age, except where explicitly described otherwise in the privacy notices of products and services designed specifically to assist you by providing child online protection features. In such cases, we will only collect and process Personal Data
related to any child under 13 years of age which you choose to disclose to us or otherwise instruct us to collect and process. Please refer to the specific applicable notices for important additional information.
Managing Your Personal Data
How long we retain or store your Personal Data
We will hold your Personal Data on our systems for the longest of the following periods:
1. As long as necessary to maintain our ongoing business relationship, or as needed to provide you with the products, services or information which you are entitled to or can otherwise reasonably expect to receive from us;
2. For as long as necessary for the
purpose for which we collected it or for which you supplied it to us in accordance with any product or service relevant activity or process;
3. Any retention period that is necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements; or
4. The end of the period in which litigation or investigations might arise in respect of our business relations or other interactions with you.
For the sake of clarity where EnglishLab.Net is a data controller processing your Personal Data for our own purposes, your Personal Data will be deleted or de-identified when it is no longer needed for its originally stated
processing purposes, or any additional compatible purpose for which EnglishLab.Net may lawfully further process such data.
Moreover, where EnglishLab.Net is a data processor processing your Personal Data for the purposes and on the instructions of another data controller or data processor, we will comply with the time limits agreed with that other Controller or Processor unless we are compelled by applicable laws and regulations to delete such data sooner, or to retain it further.
If applicable, for more information about how your Personal Data may subsequently be retained on a per product basis, please refer to the product and service specific supplemental information.
Your Privacy Rights
Subject to applicable laws, as an individual data subject, you may have the right:
a) to ask us to provide you with information regarding the Personal Data we process concerning you;
b) to rectify, update or complement inaccurate or incomplete Personal Data concerning you;
c) to delete or request the erasure of Personal Data concerning you;
d) in certain circumstances to obtain of us that we restrict the way in which we process Personal Data concerning you;
e) to withdraw any consent you may have given for us to process Personal Data concerning you;
f) to object to our processing of Personal Data concerning you on the basis of our, or of third-parties’ legitimate interests;
g) to obtain of us the portability of Personal Data concerning you which we process using automated means on the basis of your consent or of a contract you have entered into with us; and
h) in the European Economic Area, to lodge a privacy complaint with a supervisory authority if you are unhappy with the way we have handled your Personal Data or any privacy query or request that you have raised with us.
Where your exercise of any of the rights above is dependent on EnglishLab.Net’s action, we will abide by our legal obligation to take reasonable measures to ascertain your identity and the legitimacy of your request, and may ask you to disclose to us any information necessary for that purpose. We will respond to legitimate request within 1 (one) calendar month or 31 (thirty-one) calendar days (whichever is longer). In certain limited circumstances, we may need to extend our response period as permitted by applicable law. Pursuant to any such requests, we may
retain certain data necessary to prevent fraud or future abuse or as otherwise required or permitted by law, including to comply with legal obligations we are subject to, as well as to establish, exercise and defend our legal claims.
You may also update your EnglishLab.Net Email Preferences as well as unsubscribe from General Marketing Offers.
To exercise any of your rights, or if you have any other questions or complaints about our use of your Personal Data and its privacy, write or call our Privacy Team at the most convenient location below:
Call us: +372510217
Email us: email@example.com
Changes to this Statement
We reserve the right to revise or modify this Statement. In addition, we may update this Privacy Statement to reflect changes to our data practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.