PRIVACY POLICY
We, Intap Labs Private Limited (hereinafter referred to as the “Company”) having its registered office at S.B.- One Bapu Nagar, J.L.N. Marg, Jaipur - 302015, India, represented by its members, where such expression shall, unless repugnant to the context thereof, be deemed to include its respective legal heirs, representatives, administrators, permitted successors and assigns. The creator of this Privacy Policy ensures steady commitment to Your privacy with regard to the protection of your invaluable information. This privacy policy contains information about an online website called helloenglish.com (hereinafter referred to as the “Website”). In order to provide You with Our uninterrupted use of services, We may collect and, in some circumstances, disclose information about you with your permission. To ensure better protection of Your privacy, We provide this notice explaining Our information collection and disclosure policies, and the choices You make about the way Your information is collected and used.
This Privacy Policy shall be in compliance with the General Data Protection Regulation (GDPR) in effect from May 25, 2018 and any and all provisions that may read to the contrary shall be deemed to be void and unenforceable as of that date. If you do not agree with the terms and conditions of our Privacy Policy, including in relation to the manner of collection or use of your information, please do not use or access the Site. If you have any questions or concerns regarding this Privacy Policy, you should contact our Customer Support Desk at contact@culturealley.com (mailto:contact@culturealley.com) or call on +91 8764221100.
ANY CAPITALIZED WORDS USED HENCEFORTH SHALL HAVE THE MEANING ACCORDED TO THEM UNDER THIS AGREEMENT. FURTHER, ALL HEADING USED HEREIN ARE ONLY FOR THE PURPOSE OF ARRANGING THE VARIOUS PROVISIONS OF THE AGREEMENT IN ANY MANNER. NEITHER THE USER NOR THE CREATERS OF THIS PRIVACY POLICY MAY USE THE HEADING TO INTERPRET THE PROVISIONS CONTAINED WITHIN IT IN ANY MANNER.
1. “We”, “Our”, and “Us” shall mean and refer to the creators of this privacy policy.
2. “You”, “Your”, “Yourself” and “User” shall mean and refer to natural and legal individuals who use the Website.
3. “Personal Information” shall mean and refer to any personally identifiable information that We may collect from You. For removal of any doubts, please refer to Clause 2.
4. “Third Parties” refer to any website, company or individual apart from the User and the creator of this Website.
We are committed to respecting Your online privacy. We further recognize Your need for appropriate protection and management of any Personal Information You share with us. We may collect the following information:
1. Personal data such as, but not limited to, Name, Address, Location, Password, Email ID, Mobile Number, etc.
2. Tracking Information such as, but not limited to the IP address of your device and Device ID when connected to the Internet. [This information may include the URL that you just came from (whether this URL is on the Website or not), which URL you next go to (whether this URL is on the Website or not), your computer browser information, and other information associated with your interaction with the Site.
3. To use the Services of the Website, we may collect data such as, but not limited to collecting audio, image etc.
This privacy policy also applies to data we collect from users who are not registered as members of this site, including, but not limited to, browsing behaviour, pages viewed etc. We also collect and store personal information provided by you from time to time on the Site. We only collect and use such information from you that we consider necessary for achieving a seamless, efficient and safe experience, customized to your needs including:
1. To enable the provision of services opted for by you;
2. To communicate necessary account and service related information from time to time;
3. To allow you to receive quality customer care services;
4. To comply with applicable laws, rules and regulations
Where any service requested by you involves a third party, such information as is reasonably necessary by the Company to carry out your service request may be shared with such third party.
We also do use your contact information to send you offers based on your interests and prior activity. The Company may also use contact information internally to direct its efforts for service improvement, but shall immediately delete all such information upon withdrawal of your consent for the same through our ‘unsubscribe’ button or through an email to be sent to contact@culturealley.com.
We collect and store your search details on the Website, including your search history, the usage of the website and the features and time you have used the website for. We collect any communications between you and the Freelancers who work for the Website.
Further, you may from time to time choose to provide payment related financial information (credit card, debit card, bank account details, billing address etc.) on the Site. We are committed to keeping all such sensitive data/information safe at all times and ensure that such data/information is only transacted over secure Site of approved payment gateways which are digitally encrypted, and provide the highest possible degree of care available under the technology presently in use. We shall collect and store all such information in our internal Company servers for a finite period of time, as long as you are a User of the Website, and shall immediately delete all such information upon expiry of your Usership. We shall also delete all aforementioned communication between you and the Freelancers upon withdrawal of Usership of any single Party to the communication.
The Company will not use your financial information for any purpose other than to complete a transaction with you. To the extent possible, we provide you the option of not divulging any specific information that you wish for us not to collect, store or use. You may also choose not to use a particular service or feature on the Site, and opt out of any non-essential communications from the Website. Further, transacting over the internet has inherent risks which can only be avoided by following security practices yourself, such as not revealing account/login related information to any other person and informing our customer care team about any suspicious activity or where your account has/may has been compromised.
At every stage prior to, during or after information collection, you have the right to access all personally identifiable information provided, rectify or alter all personally identifiable information provided, restrict the level of information to be retained as per your sole discretion and object to the retention, use and potential disclosure of the personally identifiable information.
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. Hello English records these audio and video lessons and retains them until you close your Hello English account. Hello English uses this data to help improve the quality of the lessons and for internal research purposes.
Hello English 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. Hello English only shares some basic skill level information with the tutor, prior to your lesson, so they understand how best to speak to you.
Some lessons involve you speaking into the app. To recognize speech your audio may be sent to a third party provider such as Google, Apple, or Amazon Web Services. We may ask you to allow Hello English to collect and analyze your speech data to help us understand the effectiveness of our lessons, and to improve the product. If you choose not to share your audio with us, or if we haven’t asked you yet, then your audio will not be used in this way. Any audio you agree to send to Hello English is anonymized when it reaches our servers to ensure that no trace of your personal data remains attached to the audio.
We need to collect your and your child's Personal Data to provide our services to you and your child. We are committed to protecting the privacy of children who use our sites and applications. Whenever we refer to a “child” in this privacy policy, we mean a child under the age of 13 for US users, and under the age of 16 for EU users.
US Child Users
If your child is located in the United States of America, we handle their Personal Data in compliance with the Children's Online Privacy Protection Act (“COPPA”). COPPA applies to child users who are under the age of 13.
COPPA requires that we receive verifiable parental consent from the child's parent or legal guardian before the collection, use, or disclosure of the child's Personal Data. To learn more about how we receive this parental consent, what personal data we collect from children, how we use this data, including when we disclose it, go to COPPA Direct Notice to Parents. We display this notice to all parents and guardians when soliciting and obtaining verifiable parental consent.
If you are a parent or guardian and you believe that your child has provided us with Personal Data without your consent, please contact us at contact@culturealley.com . We will dispose of that data in accordance with applicable laws and regulations.
Parents can always refuse to permit us to collect further Personal Data, request to review their child's Personal Data, or request that we delete from our records the personal data collected from or about their child. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service, as the nature of our services requires collection of Personal Data. To exercise any of these options, please contact us at contact@culturealley.com. Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any personal data.
If your child is a resident of a Member State of the European Union, we will treat their Personal Data as a child's Personal Data if they are under 16 years of age, and receive consent of the holder of parental responsibility as required for the processing of Personal Data. All residents of the European Union further have specific rights granted by the General Data Protection Regulation (“GDPR”). See Annexure to this privacy policy.
Categories of Personal Data that we may collect and process are as follows:
The information provided by You shall be used to
1. Contact You when necessary and is also used for targeted marketing campaigns i.e. email marketing, remarketing, look alike campaigns etc., to conduct surveys, learn more about You by linking Your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers;
2. Improve and develop new products, services, and features;
3. Analyze purchase, usage and traffic data.
For more details about the nature of such communications, please refer to our Terms of Service. Further, Your personal data and Sensitive Personal data may be collected and stored by Us for internal record.
We use Your tracking information such as IP addresses, and or Device ID to help identify you and to gather broad demographic information. We will not sell, license or trade Your personal information. We will not share your personal information with others unless they are acting under our instructions or we are required to do so by law.
Information collected via Our server logs includes users' IP addresses and the pages visited; this will be used to manage the web system and troubleshoot problems. We also use third-party analytics, tracking, optimization and targeting tools to understand how users engage with our website so that we can improve it and cater personalized content/ads according to their preferences.
Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. If the same is not identified to you, you have the right to request the Company to elucidate the purpose of collection of said personal information, pending fulfilment of which you shall not be mandated to disclose any information whatsoever.
We will collect and use your personal information solely with the objective of fulfilling those purposes specified by us, within the scope of consent of the individual concerned or as required by law. We will only retain personal information as long as necessary for the fulfilment of those purposes. We will collect personal information by lawful and fair means and with the knowledge and consent of the individual concerned.
Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
We process your Personal Data by relying on one or more of the following lawful bases:
Where the processing is based on your consent, you have the right to withdraw your consent at any point in time. Please note that should the withdrawal of consent result in us not being able to continue offering our products and services to you, we reserve the right to withdraw or cease our products and services to you upon your consent withdrawal. You may withdraw consent by contacting us with a written request to the contact details specified below in the ‘Contact Us’ section. Upon receipt of your request to withdraw your consent, the consequences of withdrawal may be communicated to you. Upon your agreement to the same, your request for withdrawal will be processed.
For information on how we obtain verifiable parental consent for the processing of US child users' Personal Data, see section US Child Users above.
We use data collection devices such as “cookies” on certain pages of our Websites. “Cookies” are small files sited on your hard drive that assist us in providing customized services. We also offer certain features that are only available through the use of a “cookie”. Cookies can also help us provide information, which is targeted to your interests. Cookies may be used to identify logged in or registered users. Our Website uses session cookies to ensure that you have a good experience. These cookies contain a unique number, your 'session ID', which allows our server to recognise your computer and 'remember' what you've done on the site. The benefits of this are:
1. You only need to log in once if you're navigating secure areas of the site
2. Our server can distinguish between your computer and other users, so you can see the information that you have requested.
You can choose to accept or decline cookies by modifying your browser settings if you prefer. This may prevent you from taking full advantage of the Website. We also use various third-party cookies for usage, behavioural, analytics and preferences data. The following are the different types of Cookies used on the Website:
1. Authentication cookies: To identify the user and share the content that he or she requested for.
2. Functionality cookies: For customized user experience and resuming past course progress.
3. Tracking, optimization and targeting cookies: To capture usage metric on device, operating system, browser etc. To capture behavioral metrics for better content delivery. To cater and suggest most suited products and services.
Cookies table:
The Website uses the following Cookies:
Purpose | Cookie Name | Host |
Authentication | helloenglishEmail | Hello english |
JSESSIONID | ||
Functionality | olfsk | olark live chat |
hblid | ||
Tracking, optimization and targeting cookies | intaplabspvtltd-_zldp | |
_gid | Google analytics | |
_ga | ||
AWSELB | AWS |
We use Google Analytics to help us to understand how you make use of Our content and work out how we can make things better. These cookies follow your progress through our website, collecting anonymous data on where you have come from, which pages you visit, and how long you spend on the site. This data is then stored by Google in order to create reports. These cookies do not store your personal data.
The information generated by the cookie about your use of the Website, including your IP address, may be transmitted to and stored by Google on servers in the United States. Google may use this information for the purpose of evaluating your use of the website, compiling reports on website activity for us and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
The Google website contains further information about Analytics and a copy of Google's privacy policy pages.
We also use Facebook Analytics to measure and generate ads on our behalf about products and services tailored to your interests. Upon visiting our Site, we would provide Facebook with a unique cookie containing information about your interaction with us on our Site and Facebook would use this data to generate specific ads for us when you sign in to your Facebook account. Data collected in this way is anonymous to us, which means we cannot see the personal data of individual users; however, this data is saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at Facebook.com/about/privacy/.
The Website may include advertisements, hyperlinks to other websites, applications, content or resources. We have no control over any websites or resources, which are provided by companies or persons other than Us. You acknowledge and agree that We are not responsible for the availability of any such external sites or resources, and do not endorse any advertising, services/products or other materials on or available from such websites or resources. You acknowledge and agree that We are not liable for any loss or damage which may be incurred by you as a result of the availability of those external sites or resources, or as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, products or other materials on, or available from, such websites or resources. These external websites and resource providers may have their own privacy policies governing the collection, storage, retention and disclosure of Your Personal Information that You may be subject to. We recommend that You enter the external Website and review their privacy policy. If you require a list of third-party links on our Website, please write to us at contact@culturealley.com (mailto:contact@culturealley.com) and we will provide you with the same.
Unless subject to an exemption, you have the following rights with respect to your personal data:
1. The right to request a copy of your personal data which we hold about you;
2. The right to request for any correction to any personal data if it is found to be inaccurate or out of date;
3. The right to withdraw Your consent to the processing at any time;
4. The right to object to the processing of personal data;
5. The right to lodge a complaint with a supervisory authority
6. The right to obtain information as to whether personal data are transferred to a third country or to an international organization.
You further acknowledge that the Website may contain information which is designated confidential by Us and that you shall not disclose such information without our prior written consent. Your information is regarded as confidential and therefore will not be divulged to any third party, unless if legally required to do so to the appropriate authorities. We will not sell, share, or rent your personal information to any third party or use your e-mail address for unsolicited mail. Any emails sent by us will only be in connection with the provision of agreed services, and you retain sole discretion to seek for discontinuation of such communications at any point of time.
Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are on our Websites or on other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. To the extent that we use third party advertisers, they adhere to their own privacy policies. Since we do not control the privacy policies of the third parties, you are subject to ask questions before you disclose your personal information to others.
We may use third parties in the provision of our products and services to you. We may share your Personal Data with such third parties. We have appropriate contracts in place with all such third parties. This means that they are not permitted to do anything with your Personal Data which is outside of the scope specified by us. They are committed to hold your Personal Data securely and retain it only for the period specified in our contracts with them
We may disclose your Personal Data to the following third parties:
We shall not sell any Personal Data of yours and/ or the children for the purpose of marketing, advertising, or any other third-party use, except in accordance with express consent obtained from you.
We always strive to keep your and your child's Personal Data safe.
The security of your and your child's Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
An Adult User can review or change the information they provided when registering for the Services, including by adding or removing Child Users to the Account, by updating information through the Parent Section of the Services by emailing Company support. In addition, at any time, Users may contact us to request that we provide for their review, or delete from our records, any Personal Information they have provided about Child Users associated with their Account, or to cease collecting Personal Information from those Child Users, as applicable. Please keep in mind that a request to delete Personal Information may lead to the cancellation of your Account.
When we change or delete any Personal Information at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules.
When you sign up to become a Member, you will also be asked to choose a password. You are entirely responsible for maintaining the confidentiality of your password. It is important that you protect it against unauthorized access of your account and information by choosing your password carefully, and keeping your password and computer secure by signing out after using our services.
You agree not to use the account, username, email address or password of another Member at any time or to disclose your password to any third party. You are responsible for all actions taken with your login information and password, including fees. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password. You agree to notify us immediately if you suspect any consistent unauthorized use of your account or access to your password even after changing it.
Each paragraph of this privacy policy shall be and remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of the agreement. The decision or declaration that one or more of the paragraphs are null and void shall have no effect on the remaining paragraphs of this privacy policy.
Our Privacy Policy may change from time to time. The most current version of the policy will govern our use of your information and will always be at the Website.
As a responsible company, we do not use automatic decision-making or profiling.
To withdraw your consent, or to request the download or delete your data with us for any or all our products & services at any time, please email to contact@culturealley.com from your registered email address.
Additional rights are applicable to EU residents, which are provided ANNEXURE.
If you have any questions or concerns regarding this privacy policy, you should contact us by sending an email to contact@culturealley.com.
The below rights are available to you if you are an EU resident:
Upon request, You have the right to get confirmation as to whether or not We are processing Your Personal Data, a copy of Your Personal Data and any other additional information as specified by the General Data Protection Regulation (EU-GDPR).
Upon request, You have the right to get Your inaccurate Personal Data rectified and Your incomplete Personal Data completed.
Upon request, You have the right to obtain erasure or deletion of Your Personal Data on the grounds specified by EU-GDPR, unless there is any exception specified by EU-GDPR that is preventing us from executing your right.
Upon request, You have the right to request restriction of processing of Your Personal Data on the grounds specified by EU-GDPR.
Upon request, You have right to receive and/or transmitted to any other organization, Your Personal Data which You have provided to Us in a structured, commonly used and machine-readable format on the grounds specified by EU-GDPR, unless there is any exception specified by EU-GDPR that is preventing us from executing your right.
Upon request, You have the right to object to the processing of your Personal Data on the grounds specified by EU-GDPR.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning You.
You have the right to lodge a complaint with a supervisory authority, specifically in the Member State of Your habitual residence, place of work or place of an alleged infringement of the General Data Protection Regulation.
You can identify the supervising authority of your concern by visiting