Privacy policy

Last update: August 28, 2024

Langzy.org (also: ”Software”) is a language learning platform and service of Skrivanek sp. z o.o (“Skrivanek”, „we”, „us”, „our”), available at www.langzy.org (“Website”) (collectively: “Services”).

In compliance with General Data Protection Regulation (EU) 2016/679 (“GDPR”), this Privacy Statement explains how the personal data of Langzy.org and the Website user is collected, used and shared. By using the Website and Software, you agree with the collection and processing of your personal data in accordance with the terms of this Privacy Statement

1. Data Controller and Contact Data

Skrivanek sp. z o.o., located in Warsaw, Plac Konstytucji 6/75, 00-550 Warszawa

Contact data of Data Protection Officer: iod@skrivanek.pl

2. Data Collection

2.1. [User provided data] We collect information that you provide to us when you subscribe to Langzy.org, register an account with us and use our services, or fill in forms on our website.  Such information includes:

  • Account Data: Username and password; e-mail address, professional title, company name (Commercial Customers)
  • Identity Data: Name, email, postal address or other identifiers
  • Communication: Name, email, phone, the contents of any message or attachments that you may send to us, and any other information you choose to provide.
  • Payment data: Arranged via 3rd party solution – STRIPE
  • User Content: text and audio messages that you store using your account
  • Marketing and Communication Data: Your contact and marketing preferences

Providing such information is voluntary but may be necessary to register and use our service or to provide you with some functionality available on the Website or Software.

2.2. [Data collected from third parties] We receive information about you from your social media provider if you register using a social media account, such as Google or Facebook accounts, or if you interact with us on a social media platform, using your social media account:

  • Social Media Data: Any personal data we receive depends on privacy setting selected on your social accounts

2.3. [Automatically collected data]We automatically collect certain information when you visit or interact with our Website and Software. This information includes:

  • Technical Data: IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technology used to access our Website and Software,
  • Activity data – log data, and other data regarding  your use of the Website or the Software.

When you browse our website, we may collect personal data using Cookies (data files placed on your device or computer often including anonymous unique identifier) and similar technologies (e.g., web beacons). Please see our Cookie Policy for more details.

3. Purpose and Legal Basis for Processing Data

We use the data for the following purposes:

3.1. To fulfil a Contract (GDPR art. 6(1)(b)) – fulfil contractual obligations to you, or at your request take steps prior to entering into contract with you, including: providing and managing our services, creating and maintaining your account, providing customer support, notifying you about changes to our services.

3.2. To achieve our Legitimate Interests (GDPR art. 6(1)(f)) – when those interests do not overweigh your interests and fundamental rights and freedoms. For example, we may process your data  in order to:

  • Improve and optimize our Website, services, marketing and user experience, e.g. with the help of data analytics or satisfaction surveys
  • Expand our business by sending you information of new services and offers of Skrivanek Group. For example, if permitted by applicable law, we may use your contact details to reach out to you if you started a trial of our services, started purchase process but did not complete, have used our services in the past , or in similar scenarios.
  • Respond to your comments and enquiries
  • Administer and protect our business and the Website, e.g. for IT security
  • Otherwise keep our business and services secure, and comply with applicable law, and to protect or exercise our legal claims or defend against legal claims
  • Share data within Skrivanek Holding SE  group of companies, with organization access to the Software was purchased and 4.3.

3.3. To fulfil Legal Obligations (GDPR art. 6(1)(c)) – For example to keep and process records for tax and accounting purposes

3.4. Based on your valid Consent (GDPR art. 6(1)(a))  which you have given us to process your data for specific purposes – e.g. enable non-essential cookies or similar technologies

4. Data Sharing

Skrivanek does not sell your personal data. We may disclose your data to:

4.1. Service providers who process data on our behalf, in particular companies that help us operate our services, provide hosting and IT-services, e-mail service, financial and accounting services, legal advisors, payment processors, customer satisfaction surveys, data analysis and marketing service, market research, etc. We only use providers which offer adequate processing and protection of your personal data.

4.2. AI features – We use AI features in our Software which are hosted services based on large language models (LLM) operated by third parties. If you subscribe to Langzy.org, you will interact with Artificial Intelligence (“AI”) tool, which  allows you to send text or audio messages to an AI virtual chat tutor in an open-ended conversational format.

When you interact with AI tool, your information will be shared with third parties providing LLM, such as OpenAI in order to generate response.

We have contractual agreements with our AI providers that obligate them to use adequate security means to protect personal data we share with them relating to our services and prohibit the use of customer data to train their own models.

However, you are responsible if you decide to submit any sensible, personal or otherwise protected information that is contained in your message.

4.3. Public authorities, such as law enforcement or tax authorities, if we are legally required to do so or need to protect our rights or the rights of third parties.

4.4. Our affiliates – additionally, we may share your personal data within Skrivanek Holding SE  group of companies (list here: https://www.skrivanekholding.cz/en/) Our affiliates may use the Personal Data we share in a manner consistent with this Privacy Statement.

4.5. If you use our services on the basis of our contract with a commercial Customer, we may share certain data (e.g. your learning progress, statistics) with this Customer if the contract provides so.

5. International Transfers and Guarantees (GDPR art.14(1)(f))

Generally, we process data on EU-based serves, however your Personal Data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), including the USA. For transfers to third party processors we have implemented different safeguards such as EU Standard Contractual Clauses or certification under the EU-US Privacy Shield, as the case may be.

6. Data Retention

Skrivanek will generally retain your personal data until your account is deleted. However, we may retain certain information longer if necessary to provide our services, defend our legitimate interests’ or those of third parties, comply with legal requirements, resolve or defend ourselves in disputes, investigate misuse or disruption of service or perform agreements. We may also retain anonymous data indefinitely.

7. Data Security

We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. Personal data provided to us in accordance with this policy will be encrypted in transit and at rest.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website.

8. Your Rights

You have the following rights in relation to your Personal Data:

8.1. Access your data and information relating to how it’s processed

8.2. Rectify or update your data 

8.3. Restrict how we process your data.

8.4. Transfer your data to a third party (right to data portability)

8.5. Object to our processing of your data

  • for direct marketing at any time
  • when our processing is based on our legitimate interests.

8.6. Have your data deleted from our records

8.7. Withdraw your consent—where we rely on consent as the legal basis for processing at any time.

8.8. Lodge a complaint with your local data protection authority

If you are unable to exercise your rights through your account, please submit your request to: iod@skrivanek.pl.

Please note these rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information that we are required by law or have compelling legitimate interests to keep.

9. Changes to this Privacy Statement

We may update this Privacy Statement from time to time. When we do, we will post an updated version on this page.