Privacy policy
Introduction:
This MakesYouFluent Privacy Policy (hereinafter – the Privacy Policy) explains how “MakesYouFluent,” contact information: [email protected] (hereinafter – MakesYouFluent or the Data Controller), collects and uses your (hereinafter – the Data Subject) personal data.
According to the General Data Protection Regulation (EU 2016/679) (hereinafter – GDPR), personal data is considered any information about a natural person whose identity is identified or can be identified based on the processed personal data (hereinafter – Personal Data). Through this notice, in compliance with the GDPR, MakesYouFluent informs the current or prospective Data Subject about the Personal Data processed by MakesYouFluent.
This Privacy Policy describes MakesYouFluent policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. By using the Service, you agree with MakesYouFluent collection, use, and sharing of your personal information in accordance with the terms of this Privacy Policy.
We highly value and prioritize your privacy, therefore we do not knowingly attempt to receive excess information or infringe your right in any other way. Moreover, we recognize that information privacy is an ongoing responsibility, therefore we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.
1. Personal Information We Collect
In order to ensure the proper functioning of the website and (or) mobile app and provide you with high-quality services, to enter into and fulfill the contract with you, and to comply with the applicable legal requirements, we may process the following Personal Data:
| Purpose | Lawful basis | Personal data categories |
| User registration | Consent (Article 6(1)(a) of the GDPR) | Name, contact information |
| Fulfilling customer orders | Contractual necessity (Article 6(1)(b)) | Name, contact information, payment information |
| Provide membership services, including access to website and other content and discounts on purchases; fulfill customer subscriptions | Contractual necessity (Article 6(1)(b)) | Name, contact information, payment information |
| Provide access to purchased training | Contractual necessity (Article 6(1)(b)) | Name, contact information, payment information |
| Correspondence with website visitors | MakesYouFluent legitimate interest (Article 6(1)(f) of the GDPR) | Contact information, communication content, name. |
| Behavioural advertising | Consent (Article 6(1)(a) of the GDPR) | Name and contact information |
| Business intelligence | Consent (Article 6(1)(a) of the GDPR) | Cookies data |
| Improve products and services | MakesYouFluent legitimate interest (Article 6(1)(f) of the GDPR) | Anonymous website usage intelligence |
| Direct marketing | Consent (Article 6(1)(a) of the GDPR) | Name and contact information |
You may access some of MakesYouFluent’s services without providing personal data, as some information on our website is available to individuals who are not MakesYouFluent members. Certain personal information is necessary for MakesYouFluent to deliver the services you have purchased or requested, and to authenticate your identity, ensuring that we are engaging with you personally and not another individual.
2. Use of the MakesYouFluent Website and App
During your visit to the Site or App, we collect specific information about your device, including details about your web browser, IP address, time zone, and certain cookies installed on your device. As you navigate through the Site or App, we also gather information about the individual web pages or products you view, the websites or search terms that referred you to our Site, and how you interact with the Site or App. We refer to this automatically-collected information as “Device Information.”
As is common with most websites or apps, MakesYouFluent’s website and App collects certain information automatically and stores it in log files. This information may include internet protocol (IP) addresses, the region or general location where your device is accessing the internet, browser type, operating system, and other usage data regarding your interaction with the MakesYouFluent website or App, including a history of the pages you view. We use this information to improve the design and functionality of our Site and App to better meet our users’ needs. We may also use your IP address to diagnose server issues, administer the website, analyze trends, track visitor movements, and gather broad demographic information to understand visitor preferences.
MakesYouFluent has a legitimate interest in understanding how users, customers, and potential customers interact with its Site or App. This helps us offer more relevant products and services, communicate value to our sponsors and corporate members, and ensure we have adequate staffing to meet the needs of our users and customers.
We use the following technologies to collect Device Information:
- Cookies: These are data files placed on your device, often containing an anonymous unique identifier. To learn more about cookies and how to disable them, please visit our cookie notice. MakesYouFluent makes available a comprehensive cookie notice that describes the cookies used on MakesYouFluent website and provides information on how users can accept or reject them.
- Log Files: These track actions occurring on the Site and collect data such as your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- Web Beacons, Tags, and Pixels: These are electronic files used to record information about your browsing activities on the Site.
3. Do not Track
Please note that we do not modify our data collection and usage practices in response to Do Not Track signals from your browser.
4. Sharing Your Data With Others
We may disclose your personal data to any member within our group of companies, which includes subsidiaries, our ultimate holding company, and its subsidiaries, to the extent reasonably necessary for the purposes outlined in this notice. This may involve internal administrative purposes, as well as the provision or sharing of IT, payment, marketing services, or data centers within the group.
We may disclose your personal data to our insurers and/or professional advisers as reasonably necessary for obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or establishing, exercising, or defending legal claims in court proceedings or other judicial or administrative procedures.
To protect your personal data and fulfill our legal obligations, we may disclose your personal data to our anti-fraud, risks, and compliance providers.
For the purposes of processing your payments, transferring funds, and addressing payment-related complaints and queries, we may share your personal data with our payment service providers. We only share service data with our payment services providers to the extent necessary for these purposes. This may include, but is not limited to, transmitting your name, contact details, and payment transaction information to our payment service provider to facilitate payments securely and comply with applicable regulations. Our payment service provider currently is affiliated company 360 Mind, UAB, registered at Švitrigailos g. 11K-109, LT-03228 Vilnius, Lithuania.
In specific cases where it is reasonably necessary to provide particular services, we may disclose your personal data to other service providers. This includes server providers, email service providers, data analysis or marketing service providers, call centers, customer satisfaction surveys, or market research. We take all necessary measures to ensure that these subcontractors implement appropriate organizational and technical measures to safeguard the security and privacy of your personal data.
Additionally, we may disclose your personal data if it is necessary to comply with a legal obligation, protect your vital interests or those of another natural person, or for the establishment, exercise, or defense of legal claims.
The entities mentioned in this section may be located outside the European Union and European Economic Area.
5. Data transfer
The data we collect from you may be transferred to and stored outside the European Economic Area (EEA). In such cases, we will take all reasonable measures to ensure that your data is handled securely and in compliance with this privacy policy.
If we transfer your personal data to third countries, we will take the necessary measures, as required by applicable legal acts, to ensure the security of your data and the protection of your privacy. These measures may include: (i) transferring your personal data to countries that the European Commission has deemed to provide an adequate level of protection for personal data; (ii) signing standard contractual clauses for data transfer.
6. Data retention period
Your personal data processed for any purpose or purposes will not be retained for longer than necessary. In any case, the data will be kept for no longer than:
Account data:
Up to 5 (five) years following your last account update.
Service data:
Up to 5 (five) years following the end of service provision.
Purchase or service contracts:
10 (ten) years from the completion of the contract.
Consent for the processing of personal data:
2 (Two) years after the expiration of the retention period for personal data processed based on consent.
Messaging data:
Up to 2 (two) years following your consent or, in the case of messaging data sent to existing clients to maintain and enhance customer relations, up to 2 (two) years following the end of service provision, unless you withdraw your consent earlier or object to such processing.
Correspondence data:
Up to 6 (six) months following the end of the communication.
In certain cases, it may not be possible for us to specify in advance the exact periods for which your personal data will be retained. For instance, device data will be retained for as long as necessary for the relevant processing purposes.
Regardless of the other provisions in this section, we may retain your personal data if it is necessary to comply with a legal obligation, protect your vital interests or those of another natural person.
7. Behavioral Advertising
As outlined earlier, we process your Personal Information for the purpose of delivering targeted advertisements or marketing communications that we believe may be of interest to you. Such targeted advertising will only be conducted with your explicit consent. For further information on how targeted advertising operates, we encourage you to visit the Network Advertising Initiative’s (“NAI”) educational page http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You have the right to withdraw your consent at any time by selecting this button.
8. Your rights
8.1. Right to Access Your Personal Data: You have the right to access your personal data and learn how it is being processed.
8.2. Right to Rectify Data: You have the right to request the correction or supplementation of any incorrect, inaccurate, or incomplete personal data.
8.3. Right to Erasure (“Right to be Forgotten”): In certain cases, where not prohibited by law or where there is no obligation for the Data Controller to retain the relevant data, you have the right to request the deletion of personal data related to you.
8.4. Right to Restrict Data Processing: Under certain circumstances, you have the right to request that the Data Controller limit the processing of your personal data.
8.5. Right to Data Portability: Under specific conditions, you have the right to receive the personal data related to you, which you have provided to the Data Controller, and the right to transfer this data to another Data Controller.
8.6. Right to Object: You have the right to object to certain types of data processing and may withdraw any previously given consent regarding the processing of your personal data at any time.
8.7. Right Not to be Subject to Automated Decisions, Including Profiling: You have the right to request that decisions based solely on automated data processing, including profiling, which may have legal effects on you or significantly affect you, are not applied to you.
8.8. Right to Lodge a Complaint: If you believe that our actions or omissions infringe upon your rights or legal obligations, you have the right to lodge a complaint with data protection supervisory authorities. Residents of Lithuania may submit a complaint to the State Data Protection Inspectorate, more information is available at https://vdai.lrv.lt/lt/. If your habitual residence or place of work is in another country, you may file a complaint with the relevant supervisory authority in that country. For more information on data protection authorities in European Union/European Economic Area member states, please visit https://edpb.europa.eu/about-edpb/about-edpb/members_en. However, in all cases, we recommend contacting us first to seek a swift and effective resolution to any issue before submitting an official complaint to the supervisory authority.
9. Minors
The Site is not intended for individuals under the age of 18.
10. Contact Us
For more information about our privacy practices, if you have any questions, or if you wish to file a complaint, please contact us via email at [email protected].
Privacy Policy
1. How We Utilize Your Personal Information
Do we disclose your information to third parties (excluding business sales or purchases or similar events)? No.
At MakesYouFluent, we highly value your privacy and strive to maintain it. We prioritize the security of your personal information and do not store credit card details. All transactions are securely processed through our portal. When you visit MakesYouFluent or any related pages or sub-pages on our site, we collect information transmitted by your computer, tablet, or mobile phone. This information includes your computer’s IP address, device identifiers, operating system, location, standard web logs, and other available web data. Additionally, we gather information relevant to our services, such as the contact details you provide on our website, including your name, email address, home address, phone number, and similar information.
The Order Information we collect is primarily used to fulfill orders placed through the Site, which includes processing payment details, arranging shipment, and providing invoices and order confirmations. Moreover, we utilize this Order Information to:
- Communicate with you
- Screen orders for potential risk or fraud
- Provide you with information or advertising related to our products or services based on your preferences
The Device Information we collect aids in identifying potential risks and fraud, specifically through your IP address. Furthermore, it assists us in improving and optimizing our Site. For instance, we generate analytics to better understand how our customers browse and interact with the Site, as well as evaluate the effectiveness of our marketing and advertising campaigns.
2. Personal Information We Gather
Our primary objective in collecting personal information is to offer you a secure, seamless, efficient, and personalized experience. We may utilize your personal information to:
- Process your orders on MakesYouFluent
- Send you notifications regarding your transactions or shipments
- Enhance our customer support
- Customize, measure, and improve our services
- Tailor our website based on user behavior
- Provide targeted marketing, service update notices, and promotional offers in accordance with your communication preferences
- Conduct security checks related to the use of our services
- Contact you via email or your preferred communication method
During your visit to the Site, we collect specific information about your device, including details about your web browser, IP address, time zone, and certain cookies installed on your device. Additionally, as you navigate through the Site, we gather information about the individual web pages or products you view, the websites or search terms that referred you to our Site, and how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We employ the following technologies to collect Device Information:
- “Cookies” are data files placed on your device or computer, often including an anonymous unique identifier. To learn more about cookies and how to disable them, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site and collect data such as your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about your browsing activities on the Site.
Additionally, when you make a purchase or attempt to do so through the Site, we collect certain information, including your name, billing address, shipping address, payment information (such as credit card or debit card numbers), email address, and phone number. We refer to this information as “Order Information.”
When we mention “Personal Information” in this Privacy Policy, we encompass both Device Information and Order Information.
3. Do Not Track
Please note that we do not modify our data collection and usage practices in response to Do Not Track signals from your browser.
4. Sharing Your Data With Others
We may disclose your personal data to any member within our group of companies, which includes subsidiaries, our ultimate holding company, and its subsidiaries, to the extent reasonably necessary for the purposes outlined in this notice. This may involve internal administrative purposes, as well as the provision or sharing of IT, payment, marketing services, or data centers within the group.
We may disclose your personal data to our insurers and/or professional advisers as reasonably necessary for obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or establishing, exercising, or defending legal claims in court proceedings or other judicial or administrative procedures.
To protect your personal data and fulfill our legal obligations, we may disclose your personal data to our anti-fraud, risks, and compliance providers.
For the purposes of processing your payments, transferring funds, and addressing payment-related complaints and queries, we may share your personal data with our payment service providers. We only share service data with our payment services providers to the extent necessary for these purposes.
In specific cases where it is reasonably necessary to provide particular services, we may disclose your personal data to other service providers. This includes server providers, email service providers, data analysis or marketing service providers, call centers, customer satisfaction surveys, or market research. We take all necessary measures to ensure that these subcontractors implement appropriate organizational and technical measures to safeguard the security and privacy of your personal data.
Additionally, we may disclose your personal data if it is necessary to comply with a legal obligation, protect your vital interests or those of another natural person, or for the establishment, exercise, or defense of legal claims.
The entities mentioned in this section may be located outside the European Union and European Economic Area. If we transfer your personal data to these entities, we will take all necessary measures, as indicated in the relevant legal acts, to ensure the proper security of your privacy. This may include signing standard contractual clauses for data transfer. To obtain more information regarding the appropriate safeguards, please contact us via email at [email protected].
5. Data Retention Period
Your personal data processed for any purpose or purposes will not be retained for longer than necessary. In any case, the data will be kept for no longer than:
- Account data: Up to 5 (five) years following your last account update
- Service data: Up to 5 (five) years following the end of service provision
- Messaging data: Up to 2 (two) years following your consent or, in the case of messaging data sent to existing clients to maintain and enhance customer relations, up to 2 (two) years following the end of service provision, unless you withdraw your consent earlier or object to such processing
- Correspondence data: Up to 6 (six) months following the end of the communication
In certain cases, it may not be possible for us to specify in advance the exact periods for which your personal data will be retained. For instance, device data will be retained for as long as necessary for the relevant processing purposes.
Regardless of the other provisions in this section, we may retain your personal data if it is necessary to comply with a legal obligation, protect your vital interests or those of another natural person.
6. Behavioral Advertising
As explained earlier, we utilize your Personal Information to provide you with targeted advertisements or marketing communications that we believe may interest you. To learn more about how targeted advertising works, visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You have the option to opt out of targeted advertising using the following links:
7. Your Rights
If you are a resident of the European Union, you have the right to access the personal information we hold about you and request corrections, updates, or deletions. To exercise this right, please contact us using the contact information provided below.
Moreover, if you are an EU resident, please note that we process your information to fulfill contracts we may have with you (such as orders placed through the Site) or for our legitimate business interests as listed above. Additionally, please be aware that your information may be transferred outside of Europe, including to Canada and the United States.
8. Changes
We may periodically update this Privacy Policy to reflect changes in our practices or for operational, legal, or regulatory reasons.
9. Minors
The Site is not intended for individuals under the age of 18.
10. Contact Us
For more information about our privacy practices, if you have questions, or if you wish to file a complaint, please contact us via email at [email protected].