Privacy Policy

  1. General
    At English Direct, we care about your personal data, so we have prepared this Privacy Policy to explain how we collect, use and share it.
    This Privacy Policy (“Privacy Policy”) details the personal data English Direct, Inc. (“English Direct”, “we”, “us” or “our”) receives about you, how we process it and your rights and obligations in relation to your personal data. English Direct, Inc., a company registered at 5900 Penn Ave, Second Floor, Pittsburgh, PA 15206, United States of America is the data controller for the purposes of the General Data Protection Regulation (“GDPR”) and any relevant local legislation (“Data Protection Laws”).
    By using or accessing the Service, you agree to the terms of this Privacy Policy. Capitalized terms not defined here have the meanings set forth in the terms and conditions (the “Terms and Conditions”), located at www.English Direct.com/terms. We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy on the Website for at least 7 days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that 7 day period.
    If you are an employee, worker or contractor of English Direct, the information about how we handle your personal information is available in the English Direct internal knowledge base. With respect to employees based in Europe, we are committed to cooperating with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.

  2. Information We Collect
    This Privacy Policy explains how we collect, use and share your personal data.
    Information you provide
    Through the registration process, you will provide us with your name, e-mail address (or parent’s e-mail address), and age or date of birth. You will also provide us with your payment transaction information if you choose to pay for English Direct services.
    Activity Data
    When you use the Service, you will submit information and content to your profile. We will also generate data about your use of our Services including your engagement in educational activities on the Service, or your sending of messages and otherwise transmitting information to other users (“Activity Data”). We also collect technical data about how you interact with our Services; for more information, see Cookies.
    When you use English Direct in our app or on our website, we use a service named FullStory to log your activity. This provides us with a set of data and a session replay of your activity on English Direct in the form of a video. FullSory captures and analyzes your usage data to help us make your English Direct experience better.
    We only collect the data we need which means we don’t record:

    • Usernames

    • Names

    • Profile Images

    • Email addresses

    • Locations or bios on the Profile page

    • Passwords

  3. We do record the following data:
    Usage Patterns

    • Clicks

    • Mouse movements

    • Scrolling

    • Typing

  4. Tech Specs

    • Browser

    • Device type

    • Operating system

    • Viewfinder size

    • Script errors

    • IP address

  5. Navigation

    • Pages visited

    • Referrers

    • URL parameters

    • Session duration

  6. Learning Activity

    • Session progress

    • Answers

  7. You can disable FullStory activity recording by using the opt-out function on FullStory’s website here.
    Live Speaking Practice

    When you take a Live Speaking Lesson, we will use your computer's microphone throughout the lesson to speak to your tutor. You also have the option of using your camera to share your video with your tutor. English Direct records these audio and video lessons and retains them until you close your English Direct account. English Direct uses this data to help improve the quality of the lessons and for internal research purposes.
    English Direct does not share any of your personal data with your tutor. You are completely anonymous to them by default, and you can freely choose whether you show them your video or tell them any personal details such as your name during the conversation. English Direct only shares some basic skill level information with the tutor, prior to your lesson, so they understand how best to speak to you.
    Test Data
    If you register for the English Direct English Test, you will also provide us with your gender, native language, secondary school, and self-reported test scores for other exams. Each time you take a test you must also provide a photo of a current, valid driver’s license, passport, or other government issued ID and a take a photo of your face to verify your identity (“Testing ID”).
    When you use the Service to take an examination in the English Direct English Test you must provide access to your computer’s webcam and microphone. We will use them to record you and your screen during the entire examination period (“Testing Video”). While using the English Direct English Test, you will submit answers to questions and other information as part of the testing and evaluation process.
    Third Party Data
    We also collect information about you from third parties. For more information, see Information obtained by Third Parties.
    Product Research and Development
    We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We will record the video, audio and text transcriptions of this feedback together with any additional contact information you provide and will retain this data for two years.
    Please contact us at research@English Direct.com to:

    • Request more information about the research activities you have volunteered for.

    • Opt out of being contacted for research activities.

    • Request a copy of any research related data you have provided to us.

  8. Cookies
    When you enter the Website, we collect your browser type and your IP address (a unique address that identifies your computer on the Internet). When you use our mobile Application, we collect your device type, your device ID, and your IP address.
    In addition, we store 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. 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 (e.g., customized delivery of information).
    You can find more information about cookies and how to manage them at http://www.allaboutcookies.org.

  9. Information Obtained by Third Parties
    To support and enhance the Service, we work with a variety of third party advertising networks, marketing analytics service providers and website analysis firms, such as Google, Facebook, Oath, and Unity (collectively, “Third Party Advertising Service Providers”). These Third Party Advertising Service Providers collect and use personal data about your visits to and use of the Website and mobile Application, as well as other websites in order to serve you with advertisements and content tailored to meet your 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.
    You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the DAA Self-Regulatory Principles for Online Behavioral Advertising using their respective opt-out tools. The NAI's opt-out tool can be found here http://www.networkadvertising.org/choices/ and the DAA's opt out tool can be found here http://www.aboutads.info/choices/.
    In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.

  10. Use of information obtained by English Direct
    English Direct may occasionally send you service related and product change announcements through the general operation of the Service. We will send you reminder notifications to support the English Direct teaching methodology by reinforcing the learning cadence and help maintain your learning streak. We process your data to help provide you with the Service and offer personalized features, to understand and improve our Service and to keep our Service safe and secure.
    English Direct may use or share anonymous data collected through the Service, including Activity Data without limitation. As a business, it is critical that we perform our contract with you with the best service possible, and it is in our legitimate interests to perform these processing functions and to enable service e-mails by default to keep your data secure and provide our Service. You may opt out of any non-essential service e-mails at any time.
    We may also use your contact information to send you notifications regarding new services, offers and promotions offered by English Direct if you affirmatively consent to receive such communications.
    When you register with English Direct, some of your information is made public and available at various locations including English Direct.com/profile/your-username and English Direct.com/users/your-username. This will include the data from your English Direct Profile and Account (Name, Location, Bio, Username, User ID, Profile picture and English Direct Plus membership status); your followers and the people you follow; and your learning progress (XP, Streak, English Direct learning progressts, Daily Progress, Languages being learned, progress level, Crowns, Skills, Lessons undertaken, Lexemes and Strength). Tinycards decks you create are also public by default, but can be made visible to only you or to people you have shared a link with. Your English Direct account email address is not shown publicly. Third party websites may be able to read, collect and use your public information for their own purposes.
    Profile information is used by English Direct to be presented back to and edited by you when you access the Service and to be presented to other users. In some cases, other users may be able to supplement your profile, including by submitting comments (which can be deleted by you). English Direct uses this information to provide you with support, to send you essential notifications, to enforce our terms, conditions and policies, to communicate with you, to administer the Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes. English Direct’s Terms and Conditions provide the contractual lawful basis for these processing activities.
    English Direct English Test
    When you take a test in the English Direct English Test, we will use your computer's camera and microphone throughout the test to collect a Testing Video.
    We will process information in connection with the English Direct English Test comprising given name(s), surname(s), date of birth, gender, native language, country, secondary school, self-reported test scores for other exams, application IDs, a picture or scan of a current, valid driver’s license, passport or other government issued ID, your Testing ID, Testing Video, and answers to questions as part of the testing and evaluation process in order:

    • To provide accurate testing results to Score Recipient(s) (as defined below)

    • To compare your Testing ID to your Testing Video to ensure that the person who registered for the examination (and whose identity English Direct has validated) is the same person who took the examination

    • To store and review the Testing Video recording to validate that you took the examination without improper assistance

    • To evaluate your performance on the English Direct English Test, to report results and to evaluate the usefulness, accuracy and other aspects of the English Direct English Test

    • For our research team to validate and improve the examination, in an anonymized format

    • To analyze audio recordings of verbal responses to improve our ability to understand the spoken language

    • To share your Testing ID with your consent upon initiation of a dispute by a Score Recipient

  11. English Direct’s Terms and Conditions provide the contractual lawful basis for these English Test processing activities.
    English Direct ABC
    English Direct ABC is separate from the traditional English Direct Learning app and does not share any account information between the two. The English Direct ABC app is designed to be set up by parents and will ask you to provide your child’s age. This information is kept anonymously for research purposes and not tied to your personal data in any way. You can then choose to enable speaking exercises. Speech data is stored on your phone and uses Apple’s speech recognition service to convert your voice into text. No speech data is shared with English Direct. As a parent you also have the option of providing your email address so that English Direct may send you information about product updates and to ask you about participating in product research. If you do provide your email address you can unsubscribe any time by emailing literacy-feedback@English Direct.com or by clicking the unsubscribe link in any English Direct ABC emails. Your English Direct ABC data is backed up into Apple’s iCloud which allows you to synchronize and restore the data onto another Apple device.

  12. Sharing your personal data with third parties
    English Direct shares your personal data only when it is necessary to offer the Service, legally required, or permitted by you.
    We will provide personal data to hosting providers such as Amazon Web Services, search engine providers such as Google, analytics providers such as Crashlytics, and support providers such as ZenDesk.
    These data processors help us bring you the Service. For example, we may share your information in order to detect where or how you encountered a bug when using our mobile application. In connection with these operations, our service providers will have access to personal data for a limited time. When we utilize service providers for processing any personal data, we implement contractual protections limiting the use of that personal data to the provision of services to English Direct.
    We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the English Direct name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies.
    English Direct will share the complete and accurate results of English Direct English Tests with such institutions, including universities, potential employers, or other third parties, (collectively, “Score Recipients”) as specified when you send your results after finishing a test or when you apply a coupon sponsored by the Score Recipient before starting a test. These results will include your test score, a video of the interview section of your test, and your written responses to certain parts of the test. We will also share your full name, date of birth, e-mail address, and the photo you take of yourself. We will never share examination results with any party without your approval, except that anonymized examination results will be used by English Direct and its partners to improve the examination and for research and analysis. We will not share your Testing ID with any Score Recipients, except with your consent upon initiation of a dispute by a Score Recipient.
    If the ownership of all or substantially all of the English Direct business, or individual business units or assets owned by English Direct that are related to the Service, were to change, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain subject to this section.
    English Direct will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service.

  13. Data subject rights and data retention
    You can manage your account settings at https://www.English Direct.com/settings/account to update, amend, and correct your information.
    You also have the following rights in relation to the personal data we hold about you, unless provided otherwise by local law:

    • To request access to, or erasure of, the personal data we hold about you.

    • To request us to restrict the processing of the personal data we hold about you.

    • To object to us 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 export the personal data you have provided to English Direct in a format that can be transferred electronically to a third party.

    • To delete your account with English Direct by following the instructions available through the Service.

  14. English Direct will retain your data until your account is deleted, after which point we will retain anonymous data collected through the Service, including Activity Data, which may be used by English Direct and shared with third parties in any manner. Information associated with the English Direct English Test, including examination results and your Testing Video, will be collectively deleted from your English Direct account after five years have passed from the date you upload your test, but anonymized examination data, including your examination results and Testing Video, will be kept indefinitely by English Direct to improve the examination and for research and analysis.
    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 us 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.

  15. Third party websites and links
    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, English Direct would like to inform 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.
    Our Services contain links to other sites operated by third parties. English Direct does not control such other sites and is not responsible for their content, their privacy policies, or their use of personal data, including any personal or financial information collected by our third party payment processor to process payments for in-app purchases. English Direct’s inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

  16. California privacy rights
    Residents of California have the right to:

    • Know what personal information we collect about you and from where we collect it.

    • Access a copy of the personal information we hold about you.

    • Understand how we process your personal information and how it may be shared.

    • Opt out of having your personal information shared with certain third parties.

    • Request we delete your English Direct account and personal information.

  17. To make such a request, please send an email to privacy@English Direct.com.

  18. Children under age of digital consent
    We know that children deserve extra privacy protection. That’s why we treat child users differently to ensure their parents are in control and we only collect the bare minimum information we need to make English Direct work.
    When a user creates a English Direct account we collect their age and compare it to the local standard of child online consent depending on the country they registered in. We refer to users under this age as “child users”. Child users are permitted to create a user account but we ask them to provide their parent’s email address instead of their own. We also prevent child users from supplying their own name because we don’t need that information.
    After registration we will send an email notifying the parent about English Direct’s privacy and information practices regarding child users, including what personal data we collect and how we use, share, and protect that personal data. The email also explains how parents can request that English Direct access, change or delete the personal data about their child.
    Child users receive the following special treatment:

    • Lessons are made age appropriate by removing mature words like “beer” or “wine”.

    • Advertisements are set to family safe content.

    • The Profile page is hidden, preventing the child from stating their name, location or bio.

    • Uploading an avatar photo is disabled.

    • Promotional emails are disabled.

    • Leaderboards are disabled.

    • Discussion forums are disabled.

    • The child’s profile is made private and hidden from other users’ searches.

    • Other users are unable to follow the child.

    • The ability to follow other users or search for other users is disabled.

    • The ability to send an invitation email is disabled.

    • Finding friends on Facebook is disabled.

    • Social logins with Facebook, Google or Apple are disabled.

    • Social follow buttons for Twitter, Facebook and Instagram are disabled.

  19. In addition, all users under the age of 16 receive the following special treatment:

    • Advertisements are set to non-personalised.

    • Third party behavioral tracking is disabled.

    • Third party analytics is disabled.

  20. To prevent restricted users from amending these features, the settings will be hidden or grayed out. In the future, once we’re sure the user is old enough we will automatically remove the restrictions, reset the settings to their defaults and make the settings visible for them to configure how they choose.
    With regards to the Children's Online Privacy Protection Rule ("COPPA"), English Direct only collects personal information from children under the age of 13 for the sole purpose of performing internal operations of the Service. If we discover that we have unknowingly collected additional personal information from these children we will delete it. If you believe this to be the case, please contact us at privacy@English Direct.com.

  21. Links
    The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave the Service to read the privacy statements of other websites that collect personally identifiable information. This Privacy Policy applies only to information collected by English Direct via the Service.

  22. Information security
    English Direct has implemented administrative and technical safeguards it believes are appropriate to protect the confidentiality, integrity and availability of your personal data, Testing ID, User Photo, access credentials, and English Direct English Test results. However, given sufficient resources, a determined attacker could defeat those safeguards and may, as a result, gain access to the data we seek to protect.

Do Not Track
The Service is not designed to respond to “do not track” signals sent by some browsers.

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