This section introduces us and our approaches to collecting your personal data.
If you are located in the United Kingdom (UK) or the European Economic Area (EEA), for the purposes of the General Data Protection Regulation (the “GDPR”) and any applicable national implementing legislation (together, the “Data Protection Laws”), the data controller is NaTakallam LLC of 2 Columbus Avenue, Apt 24A, New York, NY 10023.
What types of information do we collect about you and how do we use it?
This section outlines the types of personal data that we may collect from you.
- Information you give us. When you create an account with us, sign up for newsletters or access our services, you provide information to us. This information includes:
- your Skype details or other appropriate contact information to facilitate our lessons. Though we connect all users through our Website, all lessons will be conducted through Skype and other similar third party websites; and
- information that you provide on our Website. You give us information by filling in forms or applications on our Website or by corresponding with us by telephone, email or otherwise. This includes information you provide when you register or sign up for events, newsletters or publications on our Website, when you post content or communicate via our Website, when you report a problem with our Website and/or when you provide us with feedback on our services or complete surveys. This information includes: your first and last name, date of birth, job title, address, e-mail address, phone number and username, password, personal description and financial information. You must, at all times, ensure that the information you provide to us is accurate and complete, and that all registration details (where applicable) contain your real name, address and other requested details. You will notify us of any changes to these as soon as you are able so that we can update our records.
As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our Website, teaching, translation and interpretation services, we will use your information:
- to match student users with suitable conversation partners for the provision of language lessons;
- to connect student users and conversation partners through Skype and other similar service providers – this will involve sharing personal data with conversation partners to enable the lessons to take place;
- to connect you with our in-house translation and interpretation department for the provision of interpretation or translation services.
- to identify you, communicate with you by email, sign you up for newsletters that may be of interest and otherwise personalise our services for you;
- to carry out analysis and research to improve our services, publications, events and activities more generally;
- to make suggestions and recommendations to you, and to other users of our Website, about services that may be of interest to you or them;
- to give you information about the services we provide that are similar to those which you have already enquired about and/or submitted an application;
- to ensure that content from our Website is presented in the most effective manner for you and your computer;
- to notify you about changes to our language services; or
- if you have opted in to marketing, to communicate with you about products, services, promotions, events and other news and information we think will be of interest to you.
- Technical Usage Information. When you visit the Website, we automatically collect the information sent to us by your computer, mobile phone, or other access device. This information includes:
- technical information we collect about your computer, including the type of device you use and a unique device identifier. This may also include your internet protocol (IP) address, login information, operating system and browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- details of your visits to our Website including, but not limited to, the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), cookies and methods used to browse away from the page.
As it is in our legitimate interests to process your data to provide effective services and useful content to you, we collect this information in order to:
- personalise our Website to ensure content from the Website is presented in the most effective manner for you and your device;
- monitor and analyse trends, usage and activity in connection with our Website and services to improve the Website;
- administer the Website, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
- keep the Website safe and secure; or
- measure and understand the effectiveness of the content we serve to you and others.
How do we use your information for marketing?
This section explains the ways in which we use your personal data for marketing.
When you sign up to one of our language classes, you will be added to our email distribution list to receive our biweekly newsletter by email. We may also use your data, or permit selected third parties to use your data, to provide you with information about services which may be of interest to you by email.
If you do not want us to use your data in this way, please tick the relevant box situated on the form or page on which we collect your data. You can also opt-out of receiving future marketing communications from us at any time by following the directions contained in the e-mail to unsubscribe, or by contacting us at [email protected].
Our Website may, from time to time, contain links to and from third party websites. If you follow any of these links, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
For further information, please refer to our cookies policy.
Where do we store your personal data?
This section outlines our approaches to the storage of your personal data.
If you are located in the UK and the EEA, the information that we collect from you will be transferred to, and processed by third party vendors operating outside the EEA. To the extent that we transfer your personal data outside the EEA, we will ensure that all such data transfers are subject to suitable safeguards., such as the EU-US Privacy Shield framework of our third party vendors. .
Your personal data is also processed by staff operating outside the EEA who work for us. Such staff are engaged in, among other things, the provision of the services. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
The security of your personal data
Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification. Where a password is utilised to access certain parts of our Website, you are responsible for keeping this password confidential.
Our lessons between conversation partners and student users are held on third party websites such as Skype. These websites, including Skype, will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.
How do we share your personal data?
This section outlines the circumstances within which third party disclosure may be necessary.
We may disclose your personal information to selected recipients, including but not limited to:
- Google Analytics, to assist us in the improvement and optimisation of our Website;
- social media providers, such as Facebook, to allow us to correspond with our partner organisations for translation and interpretation services;
- third party translation and interpretation services, such as Smartling, Memsource and Crowdin, to allow us to provide translation and interpretation to end users;
- automation platforms, such as Mailchimp, as part of our communications and marketing efforts;
- technology companies, such as Visual Compliance, to allow us to vet individuals as part of our HR and talent acquisition efforts;
- cloud based SaaS companies, such as Survey Monkey, to allow us to create surveys for our students and assist with their language learning; or
- the extent necessary, in the event of a reorganisation and/or a restructuring of NaTakallam.
We may also disclose data obtained from our Website to academic institutions and research bodies for research purposes. However, we do not accept any responsibility or liability for the standards of data security and privacy maintained by these third parties.
We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- comply with a legal obligation, process or request;
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction);
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof; or
- detect, prevent or otherwise address security, fraud or technical issues.
How long do we retain your personal data for?
This section outlines the length of time during which your personal data will be held by us.
We will retain your information as follows:
- if you contact us via email we will keep your data for two (2) years if your account remains inactive after this initial contact – otherwise your personal data will be retained for seven (7) years;
- your technical usage information for seven (7) years; and
- data on your use of our: language lessons, translation or interpretation services, for seven (7) years.
What are your rights in relation to the information that we collect about you?
This section outlines your rights in relation to your personal data.
If you are located in the UK or the EEA, you have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with. You also have the right to ask us to correct your personal data where it is inaccurate or incomplete [and we will endeavour to do so without undue delay].
In certain circumstances, you have the right to ask us to delete the personal data we hold about you:
- where you believe that it is no longer necessary for us to hold your personal data;
- where we are processing your personal data on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing; or
- where you believe the personal data we hold about you is being unlawfully processed by us.
In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data:
- where you believe the personal data we hold about you is inaccurate and while we verify accuracy;
- where we want to erase your personal data as the processing is unlawful but you want us to continue to store it;
- where we no longer need your personal data for the purposes of our processing but you require us to retain the data for the establishment, exercise or defence of legal claims; or
- where you have objected to us processing your personal data based on our legitimate interests and we are considering your objection.
In addition, you can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.
To exercise any of these rights above, please contact Aline Sara at [email protected]. In addition, you have the right to complain to the Information Commissioner’s Office or other applicable data protection supervisory authority.
Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals, where there are overriding public interest reasons or where we are required by law to retain your personal data.
When do we process information relating to minors?
This section outlines how we process children’s personal data.
Through our school partnerships and K-12 initiatives, we may process personal data belonging to children under the age of 1816. This processing will allow us to offer language tuition to children outside the classroom and to match them with suitable conversation partners tailored to their interests, language proficiency, availability and gender preferences. If we process personal data belonging to children under the age of 1816, we will gain consent from their parent or guardian before such information is captured.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at [email protected] and we will endeavour to deal with your request. This is without prejudice to your right to launch a claim with [the Information Commissioner’s Office] or the data protection supervisory authority in the EU country in which you live or work where you think we have infringed any Data Protection Laws.