We at Helen Doron Connect, Ltd. (“us
” or the “Company
”) respect your privacy and are committed to protect the privacy of our users (“user
” or “you
), mobile applications (“Apps
”) and other services made available by us online (collectively, the “Services”
). It also tells you the choices you can make about how the information you provide to us is used.
If you are under 16, be sure to get your parent(s)/guardian(s) to read and discuss it with you. You should always make sure you get the consent of your parent(s)/guardian(s) before giving any information or sending any materials to us.
and is incorporated therein by references.
Please note that in order for us to offer our English learning courses and related services and products, we will obtain additional information (offline) which is related to our students and their parents. We obtain their consent, in a separate consent form, prior to any collection and processing of such data.
If you are under 16, you will always need to get your parent(s)/guardian(s) permission before contacting and interacting with us.
· Parents’/Guardians’ Consent
· What types of information we collect and how we collect it
· Cookies and Google Analytics
· How we use the information we collect
· With whom we share the information, and for what purpose
· Your privacy rights
· For how long we retain the information we collect
· How do we safeguard your information
· International transfer
· How to contact us
We may need to check that your parent(s)/guardian(s) agree that you will use our Services. As part of this check, we may ask you for your parent’s/guardian’s contact details (e.g. email address or telephone number) so we can then contact them and obtain their consent.
We may also carry out checks to ensure that the contact details you have provided for your parent(s)/guardian(s) are your actual parent(s)/guardian(s). If we find out that you have given us fake details about your parent(s)/guardian(s) or if we do not get a reply from your parent(s)/guardian(s) within a reasonable time, we may be incapable to offer our Services to you.
What type of information we collect
We collect two types of data and information from our users.
- The first type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). This includes:
- Log-in information: In order to use our Services, you may be required to register/ log-in to the Services. As part of the process, we may collect your name, age, and e-mail address. If you are under 16, we may also ask you for your parent’s/guardian’s contact details (e.g. email address or telephone number), so we can then contact them and obtain their consent.
- Activity information: As part of our Services, we may collect Personal Information which is related to your activity on the Websites or Apps (e.g. what games have you participated in? what is the level you have reached? etc.). This information may help us to track and evaluate your level of English.
- Voluntary information: We also collect information which you provide us voluntarily. As part of our Services, you may provide us with Personal Information which is related to your place of residence, for the purpose of finding a learning center near you. Additionally, we collect your information when you respond to communications from us, contact our support, communicate with us via email or the Websites or share additional information about yourself or about others through your use of the Services.
- Device Information: We may also collect Personal Information from your device, such as IP address and other online identifiers (i.e. online data collected from user’s devices, applications and protocols which leave traces which may be used to identify users).
- Content: Helen Doron Connect Ltd. may upload posts or otherwise make available testimonials, photos, blogs, videos and other content (“Content“) on the Services, which may include your Personal Information. Such Content will only be used by us under your (or your parent(s)’/guardian(s)’, as applicable) consent. We as well as other users may see and share the Content, which is publicly available through the Services and through other platforms.
- The second type of information is un-identified and non-identifiable information pertaining to a user(s), which may be made available or gathered via the user’s use of the Services (“Non-personal Information”). We are not aware of the identity of the user from which the Non-personal Information was collected.
Non-personal Information which is being collected may include the following: i) your username and password; ii) information on your activity on the Services (e.g. pages viewed, online browsing, clicks, actions, timestamps, etc.); and aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).
If we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
Cookies and Google Analytics
A “cookie” is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to compile statistical data on your use of our Services.
Our website uses the following types of cookies:
- ‘session cookies’ which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
- ‘persistent cookies’ which are read only by our website, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
- ‘third party cookies’ which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who analyze our web access.
Cookies usually do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Service may not operate properly and your online experience may be limited.
How we use the information we collect
With whom we share the information we collect (“Recipients”)
- To set up your account and to provide our Services (e.g. online games, learning activities, etc.);
- To evaluate your level of English and track your progress;
- To help you locate an English learning center near you;
- To use your parent’s/guardian’s contact details and obtain their consent to your use of the Services (if you are under 16);
- To identify and authenticate your access to certain features of the Services;
- To display Content to other users and use it for marketing purposes (e.g. through social media platforms, websites, flyers, brochures, etc.);
- To perform a research or to conduct analytics in order to improve and customize our Services to our users’ needs and interests;
- To market our products and services to you (see below under “Marketing”).
- To detect and prevent illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services;
- To support and troubleshoot our Services, to respond to your queries and communicate with you;
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
- HD Members;
- subcontractors and other third party service providers;
- auditors or advisers of any of Company’s business processes; and
- potential purchasers or investors in the Company.
- Storing or processing Personal Information on our behalf (e.g. cloud computing service providers);
- Processing Personal information to assist us with our business operations (e.g. authenticate your access; auditing our operations, etc.);
- Performing research, technical diagnostics and analytics; and
- Communicating promotional and informational materials, in accordance with our marketing policy (see below under “Marketing”).
We may also disclose relevant Personal Information regarding your activity on the Websites or Apps (e.g. what games have you participated in? what is the level you have reached? etc.) and other relevant information you share with us (e.g. queries, feedbacks, etc.) with HD Members (e.g. teachers), which are associated with your English learning courses.
In all circumstances where Personal Information may become known to our HD Members, agents and outsourced service providers, there are confidentiality arrangements in place.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
Third party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via our Services (e.g. by clicking on a link to any other website or location) or via other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them.
You agree that we shall have no liability whatsoever with respect to such third party sites and services and your usage of them.
Lawful Basis for processing your Personal Data under the GDPR
If you are an individual from the European Economic Area (“EEA
“), please note that our legal basis for collecting and using your Personal Information will depend on the Personal Information collected and the specific context in which we collect it. We normally collect Personal Information from you only where: (a) we have your consent to do so, (b) where we need your Personal Information to perform a contract with you (e.g. to deliver the Service you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such Personal Information under applicable laws.
In some cases, we may need the Personal Information to protect your vital interests or those of another person.
Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your Personal Information, you have the right to object.
If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us through the contact details available below.
User rights and retention
We respect your privacy rights and therefore you may contact us at any time and request:
- to access, delete, change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted); or
- that we will cease any further use of your Personal Information (for example, you may ask that we will stop using or sharing your Personal Information with third parties) or that we shall remove your Personal Information (subject to any other legal obligation that may require us to keep the information).
Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at email@example.com
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable supervisory authority in your country of residence.
: if we collect Personal Information from your parent(s)/guardian(s) as part of the Services, we will treat such information in the same manner as we treat and safeguard your information, as stipulated in this policy, including with regards to the “privacy rights” detailed in this section.
How do we safeguard your information?
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of our users’ information, and prevent unauthorized use of any such information.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
Since we operate globally, it may be required to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to your Personal Information and that such transfer is in accordance with EU privacy and data protection regulations.
We and our HD Members may occasionally use Personal Information you have voluntarily shared with us, for the purpose of providing you with promotional materials, concerning our English learning courses and other related services and products.
Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by contacting by sending a blank message with the word “remove” to firstname.lastname@example.org
Please note that even if you unsubscribe from our mailing list, we may continue to send out periodic e-mails informing you of technical, service or security issues related to our Services.
How to contact us
If you have any general questions about the Services, please contact us at email@example.com
If you have any questions about this policy or the information that we collect about you and how we use it, please contact us at firstname.lastname@example.org
If you reside in the EU, you may also approach our EU representative:
EDPO (European Data Protection Office)
Details of Company
- By writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
- by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
Helen Doron Connect Ltd.,