GETLANGUAGE PRIVACY POLICY

1. Scope of this Privacy Policy

This Privacy Policy applies to personal data processed in connection with GETLANGUAGE services, including information collected through the website, registration and enquiry forms, email, telephone, messaging applications, Zoom lessons, learning platforms, payment processes and other communications with customers, students and prospective customers.

GETLANGUAGE provides online tuition and tutoring services. This Privacy Policy does not represent GETLANGUAGE as a licensed private school, Private Institute or Private Educational Centre in Cyprus.

2. Personal Data We May Collect

Depending on the services used, we may collect the following categories of personal data:

• Identification data, such as name, surname, age or date of birth where relevant.
• Parent or guardian details where the Student is under 18 years of age.
• Contact details, such as email address, telephone number and messaging contact details.
• Registration and account information relating to courses, tuition arrangements, lesson schedules and learning platforms.
• Learning-related information, such as language level, learning goals, attendance, homework, assessment results, progress notes and teacher feedback.
• Communications with GETLANGUAGE, including emails, messages, enquiries, complaints and support requests.
• Payment and transaction information, such as payment status, invoice information, transaction references and limited payment-related information. Full payment-card data is normally processed by the relevant payment provider rather than stored by GETLANGUAGE.
• Technical data relating to use of the website or online platforms, such as IP address, device or browser information, logs and cookie-related information where applicable.
• Audio, video, displayed names, screen-sharing content and classroom contributions where a group lesson is recorded using Zoom.

3. Information About Children

GETLANGUAGE provides tuition to children and young people. Where a Student is under 18, contractual and administrative information will normally be collected from or with the involvement of the Student's parent or legal guardian.

We seek to collect only the personal data reasonably necessary to provide the tuition service, communicate with the family, manage lessons and support the Student's learning.

Where processing is based on consent and applicable data-protection law requires parental authorisation because of the Student's age, GETLANGUAGE will seek the required authorisation from the parent or legal guardian.

Parents and guardians should not provide unnecessary sensitive information about a child unless it is genuinely relevant to the provision, accessibility or safety of the service.

4. Why We Process Personal Data

We may process personal data for the following purposes:

• responding to enquiries and arranging consultations or placement discussions;
• registering Students and administering tuition services;
• creating lesson schedules and managing attendance;
• providing individual and group lessons;
• assessing language level, learning needs and progress;
• communicating with Students, parents and guardians;
• providing homework, learning resources and access to digital learning tools;
• recording and making certain group lessons available for review for a limited period;
• processing payments, invoices and accounting records;
• managing cancellations, refunds, complaints and contractual matters;
• maintaining the security and integrity of our website, systems and learning environment;
• complying with legal, tax, accounting and regulatory obligations;
• establishing, exercising or defending legal claims;
• sending marketing communications where we have a lawful basis to do so.

5. Legal Bases for Processing

Depending on the circumstances, GETLANGUAGE relies on one or more of the following legal bases under the GDPR:

• Contract: where processing is necessary to enter into or perform a contract for tuition or related services.
• Legal obligation: where processing is necessary to comply with applicable legal, accounting, tax or regulatory requirements.
• Legitimate interests: where processing is necessary for legitimate business or educational-support purposes and those interests are not overridden by the rights and freedoms of the individual.
• Consent: where we specifically ask for consent and consent is the appropriate legal basis. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

Where special-category personal data is exceptionally processed, GETLANGUAGE will rely on an appropriate additional legal condition under applicable data-protection law.

6. Zoom Group-Lesson Recordings

GETLANGUAGE may record certain online group lessons using Zoom for educational purposes, including allowing enrolled Students to review a missed lesson and supporting continuity of learning.

A recording may include the Teacher's and Students' voices, video where cameras are enabled, displayed names, screen sharing, chat or other classroom contributions.

Group-lesson recordings are normally retained for 14 days from the date of the relevant lesson and may then be automatically or manually deleted.

Access to recordings is restricted to authorised persons as reasonably appropriate. Students and Customers must not reproduce, publish, forward, distribute or otherwise share lesson recordings with unauthorised persons.

Individual lessons are not routinely recorded unless this is separately agreed or clearly communicated.

7. Learning Platforms and Third-Party Services

GETLANGUAGE may use third-party services to deliver and administer tuition. These may include Zoom, Quizlet, learning-management systems, cloud storage, email and messaging services, website hosting and payment providers.

These providers may process personal data on our behalf or, in some circumstances, act as independent data controllers for their own purposes. Their own terms and privacy policies may also apply.

GETLANGUAGE seeks to use service providers that provide appropriate data-protection and security safeguards.

8. Payments

Payments may be made to Brainnet Limited through Bank of Cyprus, Revolut Bank, payment links, card-processing providers or other approved payment methods.

GETLANGUAGE may retain information necessary to identify and reconcile payments, issue invoices, handle refunds and comply with accounting and tax obligations. Full card credentials are normally processed directly by the relevant payment service provider and are not stored by GETLANGUAGE.

9. Sharing Personal Data

We do not sell personal data.

Personal data may be shared, where necessary and lawful, with:

• Teachers and authorised GETLANGUAGE personnel who need the information to provide or administer tuition;
• IT, hosting, cloud, communications and learning-platform providers;
• payment providers, banks, accountants and professional advisers;
• regulators, courts, law-enforcement bodies or public authorities where disclosure is required or permitted by law;
• other service providers acting on our instructions and subject to appropriate contractual or legal safeguards.

10. International Data Transfers

Some third-party technology or cloud providers may process or store personal data outside Cyprus or outside the European Economic Area.

Where personal data is transferred internationally, GETLANGUAGE will seek to ensure that the transfer is made using a lawful transfer mechanism and appropriate safeguards as required by applicable data-protection law, such as an adequacy decision or appropriate contractual safeguards.

11. Data Retention

GETLANGUAGE retains personal data only for as long as reasonably necessary for the purposes for which it was collected, taking into account contractual, educational, operational, legal, tax, accounting, dispute-resolution and security requirements.

• Zoom group-lesson recordings: normally 14 days from the relevant lesson.
• Active Student and Customer records: generally for the duration of the tuition relationship and for a reasonable period afterwards where needed for administration, queries or legal purposes.
• Financial, invoice and transaction records: for the period required by applicable accounting and tax law.
• Enquiries that do not result in a tuition relationship: retained only for a reasonable follow-up period unless there is another lawful reason to retain them.
• Data connected with complaints, disputes or legal claims: may be retained until the matter is resolved and for any applicable limitation period.

When personal data is no longer required, it will be deleted, anonymised or otherwise securely disposed of, subject to applicable legal requirements.

12. Security

GETLANGUAGE applies reasonable technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Access to personal data is limited to persons who reasonably need it for their role. No online system can be guaranteed to be completely secure, and Customers and Students should also protect passwords, meeting links and account credentials.

13. Your Data-Protection Rights

Subject to the conditions and limitations in applicable law, individuals may have the right to:

• request access to their personal data;
• request correction of inaccurate or incomplete personal data;
• request deletion of personal data in applicable circumstances;
• request restriction of processing;
• object to certain processing, including direct marketing;
• receive certain personal data in a portable format where the right to data portability applies;
• withdraw consent at any time where processing is based on consent;
• lodge a complaint with a competent data-protection supervisory authority.

To exercise a data-protection right in relation to GETLANGUAGE, contact brainnet.cy@gmail.com. We may need to verify identity before responding to a request.

14. Complaints to the Supervisory Authority

Individuals have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus or, where applicable, another competent supervisory authority in the European Union.

We encourage individuals to contact GETLANGUAGE first where appropriate so that we have an opportunity to address the concern.

15. Marketing Communications

GETLANGUAGE may send information about services, courses or related opportunities where permitted by law.

Where consent is required for marketing, we will seek it. A person may unsubscribe from marketing communications at any time by using an unsubscribe mechanism where provided or by contacting brainnet.cy@gmail.com.

Service communications relating to an active course, payment, lesson schedule, safety, contractual matter or account administration are not marketing communications.

16. Cookies and Website Technologies

The GETLANGUAGE website may use cookies or similar technologies that are necessary for website operation and, where enabled, analytics or other optional functions.

Where legally required, non-essential cookies will be used only after the appropriate choice or consent has been obtained. Further information may be provided in a separate Cookie Policy or cookie notice on the website.

17. Automated Decision-Making

GETLANGUAGE does not ordinarily make decisions producing legal or similarly significant effects on Students or Customers solely by automated means.

If this changes, we will provide the information required by applicable data-protection law.

18. Data Provided by Parents or Other Persons

Where a parent, guardian, employer or other authorised person provides personal data about a Student or another individual, that person should ensure that they are entitled to provide the information and, where appropriate, that the individual has been informed about this Privacy Policy.

19. Changes to this Privacy Policy

Brainnet Limited may update this Privacy Policy from time to time to reflect changes in law, technology, services or processing activities.

The current version will be published on https://getlanguage.online with its effective date. Material changes will be communicated where required by law.

20. Contact Us

For questions about this Privacy Policy, the processing of personal data, or the exercise of data-protection rights, please contact: