Privacy Policy

<h2><strong>1. Definitions.</strong></h2>

<p>1.1. <strong>Consent:</strong> Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.</p>

<p>1.2. <strong>Data controller:</strong> Data controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.</p>

<p>1.3. <strong>Data processing:</strong> Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as recording, adaption, collection.</p>

<p>1.4. <strong>Data processor:</strong> Data processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.</p>

<p>1.5. <strong>GDPR:</strong> Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.</p>

<p>1.6. <strong>Services:</strong> All the available lessons, educational experience, exercises what Service Provider offers to the Users.</p>

<p>1.7. <strong>Personal Data Breach:</strong> Personal Data Breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.</p>

<p>1.8. <strong>Personal data:</strong> Personal data means any information relating to an identified or identifiable natural person.</p>

<p>1.9. <strong>Privacy Policy:</strong> means Service Provider’s Privacy Policy.</p>

<p>1.10. <strong>Service Provider:</strong> BTCL Software Bt., 2890 Tópart utca 5-7. lph. 1/2, Tata, Hungary, [email protected].</p>

<p>1.11. <strong>Supervisory authority:</strong> Supervisory authority means an independent public authority which is established by a Member State pursuant to Article 51.</p>

<p>1.12. <strong>Terms and Conditions:</strong> Terms and Conditions: means Terms and Conditions of Website.</p>

<p>1.13. <strong>User:</strong> any person who is over 13 years of age and has successfully completed the Registration on the Website, accepted the Terms and Conditions, and the Privacy Policy of the Service Provider.</p>

<p>1.14. <strong>Website:</strong></p>

<h2><strong>2. Principles of personal data processing.</strong></h2>

<p>2.1. <strong>Personal data shall be:</strong></p>

<p>2.1.1. processed lawfully, fairly and in transparent manner in relation to the data subject (<strong>lawfulness, fairness and transparency</strong>);</p

<p>2.1.2. collected only for specified, explicit and legitimate purposes and not further in a manner that is incompatible with those purposes (<strong>purpose limitation</strong>);</p>

<p>2.1.3. adequate, relevant, and limited what is necessary in relation to the purposes for which they are processed (<strong>data minimisation</strong>);</p>

<p>2.1.4. accurate and kept up to date, every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (<strong>accuracy</strong>);</p>

<p>2.1.5. kept in form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (<strong>storage limitation</strong>);</p>

<p>2.1.6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (<strong>integrity and confidentiality</strong>).</p>

<h2><strong>3. General.</strong></h2>

<p>3.1. At Service Provider, we care about your personal data, so we have prepared this Privacy Policy to explain how Service Provider collect and use it.</p>

<p>3.2. This Privacy Policy details the personal data Service Provider receives about you, and how to process it. Service Provider is registered at Frankfurt. Service Provider collects and uses the data for the purposes of the General Data Protection Regulation. Further information about registration you can find more details in Terms and Conditions.</p>

<p>3.3. Service Provider is entitled to amend the provisions of present Privacy Policy unilaterally. Service Provider discloses the modified Privacy Policy on the Website 10 days before it enters into force at last. User shall explicitly accept the modified Privacy Policy before it enters into force, otherwise the User will no longer be able to use the Services of the Website, and his/her Registration will be suspended.</p>

<h2><strong>4. Collecting Information.</strong></h2>

<p>4.1. Privacy Policy explains, how Service Provider collects and uses your personal data. Through the registration process, you will provide Service Provider your email address and your date of birth. Furthermore, you have to enter a password, which has to consist at least 8 letters and a number. During the use of the Service, you will submit information and content to your profile. Service Provider also generates different data about your educational activities (hereinafter: „<strong>Activity Data</strong>”), as well as, Service Provider also collects technical data (hereinafter: “<strong>Technical Data</strong>”) about, how you interact with the Services. Furthermore, Service Provider also collects information about the User’s test result. This type of data collections helps Service Provider to develop the user experience and help to improve the User’s language learning skills. As a result of this Activity Data and Technical Data collection Service Provider‘s software development program can help personalize the lessons and exercises by using artificial intelligence.</p>

<h2><strong>5. Sharing your personal data with third parties.</strong></h2>

<p>5.1. Service Provider does not share any of your personal data with third parties. You are completely anonymous. Service Provider will not 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.</p>

<h2><strong>6. Children under age of digital consent.</strong></h2>

<p>6.1. Service Provider provides some features and services intended for use by children. Service Provider might also use age-gating to restrict what services are available to children depending on the age of the user and the applicable laws of their country.</p>

<p>6.2. <span style="text-decoration: underline;">Children within the European Union:</span></p>

<p>6.2.1. Each European Union (EU) member state is permitted to legally define its own digital age of consent between 13 and 16. If consent of a parent/guardian is required, the user will input the e-mail address of an adult who will receive a request to approve the child’s account registration. In the absence of a country specific Act of Law, the age of consent will be set at 16.</p>

<p>6.2.2. These EU child users will receive the following service restrictions: they will not be able to use the service until their parent/guardian has provided consent for the child to do so. After the parent/guardian has given consent, the child will be allowed to access the full Service.</p>

<h2><strong>7. Cookies.</strong></h2>

<p>7.1. Service Provider uses HTTP cookie (hereinafter: “<strong>Cookie</strong>”) to improve its quality and develop the user experience. (Cookie is a small piece of data sent from Website and stored on the User’s computer, tablet or mobile device by the User’s web browser while the User is browsing. Cookie is not able to identify the User personally). In that case, if you do not want to Cookie be placed on your electronic device, you can set it on your browser, so the program will not allow the Cookie to collect browser information. However, you can allow the usage of Cookie, if you enter the website and accept it by one click, as a result Service Provider access your browser type, IP address as well.</p>

<h2><strong>8. Use of information obtained by Service Provider.</strong></h2>

<p>8.1. Service Provider may occasionally send you service related announcements through the general operation of the Service. Service Provider also sends you reminder notifications to support the teaching methodology and to help maintain your learning streak. When you register with Service Provider none of your personal data will be available online, especially your email address will not be shown publicly.</p>

<h2><strong>9. Rights of the Users relating to the personal data controlling.</strong></h2>

<p>9.1. Users have the following rights relating to the personal data controlling.</p>

<p>9.1.1. <strong>Right of access:</strong> Users could ask information about their personal data: What kind of personal data are under control by the Data processor, how long it will take, what is the purpose of the data control, is there any data transmission?</p>

<p>9.1.2. <strong>Right of correction:</strong> In that case if the User personal data had been registered wrong, Users have the right to fix, correct the mistakes.</p>

<p>9.1.3. <strong>Right of cancellation:</strong> Users have the right to ask the cancellation of their personal data in certain cases according to the GDPR.</p>

<p>9.1.4. <strong>Right of data proceedings restriction:</strong> Users have the right to ask the restriction of their data in certain cases according to the GDPR.</p>

<p>9.1.5. <strong>Right of consent withdrawal:</strong> Users have the right to withdraw their contribution at any time, which was given earlier to the Data controller.</p>

<p>9.1.6. <strong>Right to complain:</strong> Users have the right to submit a complaint to the Supervisory Authority about the violation their personal data.</p>

<p>9.1.7. <strong>Right of taking action:</strong> Users have the right to take legal action against the Data controller, if their personal data have been violated.</p>

<h2><strong>10. Personal Data Breach.</strong></h2>

<p>10.1. Data controller is obliged to inform the Supervisory Authority about the Personal data breach at least within 72 hours by the recognition. Data controller is not obliged to inform the Supervisory authority about the Personal data breach, if it has no impact on the natural person rights. If the notification has not been announced within 72 hours by the recognition, the Data controller has to proof the reason of the delay.</p>

<p>10.2. Data controller is obliged to inform the Supervisory authority about the Personal data breach by the recognition without any delay.</p>

<h2><strong>11. Assistance and Complaint handling.</strong></h2>

<p>11.1. If you need some help relating to the personal data control, or personal data process, you may contact the Service Provider.</p>

<h2><strong>12. Controlling activities relating to the personal data by the Provider</strong></h2>

<p>12.1. The purpose of the registration on the Website is to allow the access of the Service to the Users.</p>

<h2><strong>13. Data controlling process</strong></h2>

<p>13.1. <strong>Controlled personal data</strong>


<li>Email address, Date of birth, Password</li>

<li>Activity data: frequency of how often the User uses the Website, frequency of how often the User uses each learning method, average time of use of the Website, results of the User</li>

<li>Technical Data: Access through device / browser</li>


<p>13.2. <strong>Purpose of the data control:</strong>


<li>Sending system messages relating to the Services.</li>

<li>Personalizing Services.</li>


<p>13.3. <strong>Claim of the data control:</strong> GDPR Article 6. (1) b)</p>

<p>13.4. <strong>Time of the data control:</strong> From the registration till the User deletes his/her account.</p>

<p>13.5. <strong>Name of the data controller:</strong> Service Provider</p>

<p>13.6. <strong>Contact of the data controller:</strong> 2890 Tópart utca 5-7. lph. 1/2, Tata, Hungary, [email protected]</p>

<p>13.7. <strong>Is there any data transmission?</strong> No</p>

<p>13.8. <strong>Name of the data processor:</strong> None</p>

<p>13.9. <strong>Purpose of the data processing:</strong> None</p>

<p>13.10. <strong>Form of the data storage:</strong> Cloud</p>

<p>13.11. <strong>Type of the data storage:</strong> Electronic</p>

<p>13.12. <strong>Group of natural or legal person who are entitled to getting know the user’s personal data:</strong> None</p>

<p class="info_dialog_source">Date of the last modification: 26 May 2022.</p>