Privacy policy
- Introduction
1.1 We are committed to safeguarding the privacy of [our website visitors, service users, individual customers and customer personnel].
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 On our website, cookies are used. When you first visit our website, we will ask for your permission to use cookies if those cookies are not necessarily required for the delivery of our website and services.
1.4 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of [our website and services], we will ask you to consent to our use of cookies when you first visit our website.
1.5 In this policy, “we”, “us” and “our” refer to FLAC Institute.[ For more information about us, see Section 14.]
1.6 We make use of YouTube API tools. You accept the Google Privacy Policy (http://www.google.com/policies/privacy) by using FluentU.
- Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).
- The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process[ and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data].
3.2 We may process data enabling us to get in touch with you (“contact data“).[ The contact data may include [your name, email address, telephone number, postal address and/or social media account identifiers].][ The source of the contact data is [you and/or your employer].][ If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.]
3.3 We may process [your website user account data] (“account data“).[ The account data may [include your account identifier, name, email address, profile pictures, and educational details, business name, account creation and modification dates, website settings and marketing preferences].][ The primary source of the account data is [you and/or your employer, although some elements of the account data may be generated by our website].][ If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.]
3.4 We may process [information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website] (“transaction data“).[ The transaction data may include [your name, your contact details, your payment card details (or other payment details) and the transaction details].][ The source of the transaction data is [you and/or our payment services provider].]
3.5 We may process [information contained in or relating to any communication that you send to us or that we send to you] (“communication data“). The communication data may include [the communication content and metadata associated with the communication].[ Our website will generate the metadata associated with communications made using the website contact forms.]
3.6 We may process [data about your use of our website and services] (“usage data“). The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is [our analytics tracking system].
3.7 We may process the personal information you supply when using our services (“service data“). Your usage logs and the stuff you have learnt on our service may be included in the service data. The processing of the service data could be done for the operation of our website, rendering of our services, maintaining back-ups of our databases, guaranteeing the safety of our website and services, and getting in touch with you. Consent is the legal justification for this processing.
3.8 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.9 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
3.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.11 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.13 We may process your personal data to deliver you advertising, including by serving and managing ads on the Offerings or on third party sites and to tailor ads based on your interests and browsing history. You can opt out by visiting the Network Advertising Initiative opt out page: http://optout.networkadvertising.org/#/ An exception to this is data for schools and group accounts. School, teacher, or student data will not be used for advertising in any form.
3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 4, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations – We may process [your personal data] for [the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control]. The legal basis for this processing is [our legitimate interests, namely [the proper administration of our website, services and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].
4.3 Publications – We may process [account data] for [the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the publication of content in the ordinary course of our operations]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].
4.4 Relationships and communications – We may process [contact data, account data, transaction data and/or communication data] for [the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling]. The legal basis for this processing is [our legitimate interests, namely [communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business]].
4.5 Direct marketing – We may process [contact data, account data and/or transaction data] for [the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [promoting our business and communicating marketing messages and offers to our website visitors and service users]].
4.6 Research and analysis – We may process [usage data and/or transaction data] for [the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [monitoring, supporting, improving and securing our website, services and business generally]].
4.7 Record keeping – We may process [your personal data] for [the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally]. The legal basis for this processing is our legitimate interests, namely [ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy].
4.8 Security – We may process [your personal data] for [the purposes of security and the prevention of fraud and other criminal activity]. The legal basis of this processing is our legitimate interests, namely [the protection of our website, services and business, and the protection of others].
4.9 Insurance and risk management – We may process [your personal data] where necessary for [the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice]. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks].
4.10 Legal claims – We may process [your personal data] where necessary for [the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure]. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others].
4.11 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
- Providing your personal data to others
5.1 We may disclose [your personal data] to [our insurers and/or professional advisers] insofar as reasonably necessary for the purposes of [obtaining or maintaining insurance coverage, managing risks, obtaining professional advice].
5.2 [Your personal data held in our website database] OR [[Identify personal data category or categories]] will be stored on the servers of our hosting services providers[ identified at www.bluehost.com
5.3 We may disclose [specify personal data category or categories] to [our suppliers or subcontractors insofar as reasonably necessary.
5.4 Financial transactions relating to [our website and services] [are] OR [may be] handled by our payment services providers, Paystack, Flutterwave and Stripe Atlas. We will share transaction data with our payment services providers only to the extent necessary for the purposes of [processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds]. You can find information about the payment services providers’ privacy policies and practices at https://paystack.com/terms https://flutterwave.com/ng/privacy-policy https://stripe.com/privacy
5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
6.2 We have offices in US. Transfers to this country will be protected by appropriate safeguards.
6.3 The hosting facilities for our website are situated in the US and Singapore. Transfers to each of these countries will be protected by appropriate safeguards.
6.4 You acknowledge that [personal data that you submit for publication through our website or services] may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
7.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data as follows:
(a) your email address and account history will be retained for a minimum period of 30 days following account deletion, and for a maximum period of 6 months following account deletion. You can delete your account at any time by going to your account settings.
7.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].
- About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
10.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website;
(b) status – we use cookies to help us to determine if you are logged into our website;
(c) personalisation – we use cookies to store information about your preferences and to personalise the website for you;
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(e) advertising – we use cookies to help us to display advertisements that will be relevant to you;
(f) analysis – we use cookies to help us to analyse the use and performance of our website and services; and
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
- Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy
11.3 We may publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.
11.4 We also use various other providers that may use cookies. These services include:
– Tawk, which we use for providing you customer support
– Instabug, which we use to gather user feedback from mobile apps to improve our service
– WebEngage, which we use to collect survey data to improve our service
– Chargebee, which we use to process payments
– Mixpanel, which we use to collect analytics data to improve our service
– Firebase, which we use to collect analytics data to improve our service
– Mailster, which we use for email marketing
– Facebook Ads, which we use to advertise (except for school/group accounts)
– Google Ads, which we use to advertise (except for school/group accounts)
- Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
- Amendments
13.1 We may update this policy from time to time by publishing a new version on our website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
13.3 We [may] OR [will] notify you of [changes] OR [significant changes] to this policy [by email].
- Our details
14.1 This website is owned and operated by International Center for Language Resources
14.2 We are registered in [US and Nigeria] under registration number 20206656317, RC1733373 and our registered offices are at Suite 206. 651 N Broad Street. Middletown. Delaware, USA 19709 and Plot 674 Maltina Depot St, Area 1, Abuja.
14.3 Our principal place of business is at Suite 206. 651 N Broad Street. Middletown. Delaware, USA 1970
14.4 You can contact us:
(a) by post, to the postal address given above;
(b) by email, using the email address published on our website from time to time.
- Data protection officer
16.1 Our data protection officer’s contact details are:
- Ebuka Jonah
- ebuka@flacinstitute.com
- Disputes
15.1 If you choose to visit the Site, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use including limitations on damages, arbitration of disputes, and application of the laws of the United States and specifically the laws of the State of Delaware.