Privacy Policy

1. What is personal data and what is processing of personal data. Main definitions

   
   

   Personal data is any information relating to you and that alone or in combination with other pieces of information gives the opportunity to a person that collects and processes such information to identify you as an individual.

   Processing of the personal data means any operation with your personal data, whether by automated means, as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

   Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; means you as a user of “Room A to Z”.

   Consent of the data subject/user is any freely given, specific, informed, and unambiguous indication of the data subject/user'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.

2. “Room A to Z” lawful bases for processing

   “Room A to Z” processes your personal data only when we have lawful bases. Specifically, “Room A to Z” processes your personal data if:

   • processing is based on the consent you have given. As such our newsletters, collection, analysis, and publication of user feedback and reviews, analysis of video lessons, and placement of different types of cookies is based on your consent;
   • processing is necessary to provide our services to you according to our Terms of Service which constitute a contract between you and us as regards to information services of “Room A to Z”;
   • processing is necessary for the purposes of our legitimate interests. Those legitimate interests are:
   • compliance with the financial and accounting legislation;
   • the assessment of “Room A to Z’s” business efficiency by analyzing website traffic and financial performance indicators;
   • promotion of “Room A to Z” through social media networks, media outlets, and affiliates, such as bloggers or influencers;
   • performance of the contracts with enterprise clients and provision of reports on their employees’ performance.
   • user session control and fraud prevention, ensuring the appropriate protection of personal data;
   • tutor verification and development of high-quality learning programs with tutors.
   • where necessary, compliance with applicable legislation (e.g., data subject request processing);
   • in exceptional cases, to protect your vital interests or vital interests of another natural person; or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

   In all cases, we will notify you about the applied legal basis for processing and other relevant details, before we start processing of your personal data on the specific legal basis, unless we are not able to do so in accordance with our obligations under any applicable legislation.

3. Data We Collect: Scope

   “Room A to Z” collects from you only the following information and only for the stated below purposes:

   1. Account for students

      “Room A to Z” collects and processes personal data submitted by you upon registration and further editing of settings in your Account. For the registration purposes, you submit your login credentials (username and passwords), first name, last name, and email. You may edit your Account with additional information at your sole discretion. Additional information may help you to get more from the Services, for instance, finding a necessary tutor. At the same time, you are not required to provide additional information, not specifically necessary for the registration, it is your choice.

   2. Account for tutors

      “Room A to Z” collects and processes personal data submitted by you upon registration and further editing of your Profile. For the registration purposes, you submit your login credentials (username and passwords), first name, last name, and email. You may edit your Profile with additional information at your sole discretion. Additional information may help you to get more from the Services, for instance, finding students. At the same time, you are not strictly required to provide additional information, not specifically necessary for the registration. Therefore, it is your choice whether to include additional data to your profile, or not, such as address, bank details, country, language skills, education, and work experience.

      Some personal data, such as users’ names, and location that is listed in your user profiles or derived from IP Addresses may be publicly visible to other users on the Services or to the web. We may implement a feature that permits you to choose what information is made public by changing your privacy setting in “Edit My Profile” within the Service.

   3. Posting of Information

      We process personal data freely submitted to you on “Room A to Z”. This may be survey you fill in on “Room A to Z” or feedback you provide us with. Irrespective of whether you are a registered user or not.

      “Room A to Z” may also process information provided by you (including content and messages) that you post on/through our Website, including personally identifiable information. By so doing, you acknowledge that any information you share through the Services will be available to “Room A to Z” and to other users of the Services (students/tutors). You also acknowledge that parts of your content cannot be deleted from the Service as it may be connected to the Lessons created by you and used by other users (students/tutors).

      From our turn and unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with the Terms of Service.

   4. Service Use, Cookies, and other Similar Technologies

      When you use our Services, we monitor and analyze web traffic and keep track of your behavior while using our Services. We may receive the information about your IP address, proxy server and operating system, the web browser or your mobile carrier and location based on phone settings.

      Please, specifically refer to our Cookies Policy for further details as to our use of cookies and similar technologies.

   5. Billing information

      Details of transactions you carry out through our Website (as ID, date and time of transaction).

   6. Enterprise

      When you wish to share your contact details for more information regarding “Room A to Z” one-on-one online language training for international teams, as name, email, company name and phone number.

   7. Sensitive data

      Unless you expressly agree, “Room A to Z” does not process your sensitive data.

4. Data We Collect: Purposes

   We may process your personal data you provided us voluntarily with for the purposes defined below. From our perspective, we process your personal data to personalize the use of “Room A to Z” to the fullest extent possible and to provide you with the high-quality Services under the Terms of Service.

   1. Provision of Services

      Primarily, we process your personal data to authorize access to our Services and to fulfill our obligations under the Terms of Service for Services provision. Specifically, we use your personal data upon registration to help others (be it a tutor or a student) to find your account or profile, schedule, give and/or take lessons, and track your learning progress.

      For you to use the Services you will need to provide payment (e.g., credit card details) and billing information through our partners – third party payment providers, which process your personal data encrypted and securely. Please see our Refund and Payment Policy for more information.

      For enterprise customers, we process personal data of their employees to create their accounts and connect with the most suitable tutors for further learning. Based on the data about lessons taken by such students, we provide the enterprise customer with statistical reports on their employees’ performance.

      Please note, that without the information provided by you under our Terms of Service, we will be unable to provide you with the functionality of our platform, connect you with other users, allow you to communicate with them and take/give lessons.

   2. Payment Services

      We use third-party payment providers to bill you through an online account payment in lieu of directly processing your credit/debit card information. Your paid balance for one or more lessons is safe in your account as we use an integrated iframe for checkouts from our partners-payment providers and tutors get payment for each confirmed lesson securely through third-party payment providers. Correspondingly all transactions are secured as our partners-payment providers use SSL encryption protection. All payment information is stored encrypted and securely by third-party payment providers. We do not store your payment information on our servers.

   3. “Tell-A-Friend”

      For referral service purposes named “Tell-A-Friend”, we generate a personalized referral link for you to share with your friends to sign them up.

   4. Communications

      We may also contact you via email and other ways, including through publicly available notices, for the Services-related purposes (welcoming letter, security and legal notices, announcements, “Room A to Z” updates, reminders, suggestions etc.). We could also use your data to enable you to communicate with other users through “Room A to Z”.

      We may contact you by email and other ways, including through publicly available notices, for service-related purposes (welcome letter, security and legal notices, announcements, “Room A to Z” updates, reminders, suggestions etc.). We may also use your data to enable you to communicate with other users through “Room A to Z”, including exchanging messages, conducting video calls, and/or leaving feedback about other users.

      Your contact data (including email, phone number, Skype name etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including:

      • Feature development and product updates;
      • Marketing activities, including publishing them on “Room A to Z” on other information resources;
      • Customer Support updates;
      • Other service updates for improving your experience.

      Your feedback will not be video recorded, audio recorded, or webcast by the Interviewer without obtaining consent from you first. The same applies to your voice and/or image recording.

      Having received the communications from us, you are always able to opt-out to such communications in each message, excluding legal notices, or change of user settings on “Room A to Z”.

   5. Marketing and promotion of “Room A to Z”

      We may process your first name, last name, and email on our mailing list or for the newsletter and send you messages with some commercial or promotional information about our Services. But do not worry, we will request your consent first, and you may always opt-out from our marketing messages, using the mechanisms described under the respective link in each message, and through the user settings available on “Room A to Z”.

      Also, please pay attention that we may use the information provided by you as feedback.

   6. Analytics and Development

      To find the points of interest in our Services and for the purposes of analytics, we monitor and analyze web traffic and keep track of your behavior within our Services. This enables us to provide services that are relevant to you and boost the quality of our Services. The data concerned within this activity are Cookies and Usage data, such as the parts of our Services you visit, the date and duration of your visit, and type of the device you used during your visit. All your data stated in this paragraph is collected and further processed in a manner that does not allow your identification. For these purposes, we use Google Analytics for Firebase, Hotjar Heat Maps & Recordings, Amplitude Analytics, Branch.io, Braze, and Intercom, the use of which ensures compliance with our privacy commitments.

      We may also carry out polls and surveys through “Room A to Z” using external GDPR-compliant services. You are not obliged to respond to them, and you may opt-out of such polls and surveys through user settings. To inform, optimize and serve you relevant advertising based on your past use of our Services, we may process your Usage Data and Cookies. Please, follow our Cookies Policy for additional information.

   7. Tutor verification and program preparation

      To ensure a high quality of lessons given by tutors on “Room A to Z”, we collect and process tutor credentials to verify their eligibility to teach subjects claimed by them. Besides that, we cooperate with the tutors and use their information to help them develop the learning programs.

   8. Support and Platform Supervision

      In case of any disputes on “Room A to Z” and other Services-connected issues, we may use data (including communications) to resolve such matters, supervise user behavior on the platform, and respond to any complaints or requests.

   9. Compliance with legal requirements

      We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and/or establish our legal rights.

   10. Fraud prevention

       Certain information, such as your log information, payment information and your behavior on the platform are subject to our supervision to prevent fraudulent activities on the platform and assisting you in managing your user sessions.

   11. Changes

       If “Room A to Z” decides to change the purposes of processing specified above, we will inform you about such changes prior to the use of your personal data within the newly set purposes. The notification on such changes will be sent to your email and you will have to provide your consent for the amended purposes unless the additional purpose of processing is compatible with those listed above.

       In case you do not want to provide us the requested personal data for the purposes specified above, you may not have access to certain functions of the Services.

5. How long will the personal data be processed and stored by “Room A to Z”?

   Your personal data will be stored by “Room A to Z” no longer than is necessary for the purposes for which the personal data is processed.

   Generally, “Room A to Z” retains your personal data if your account is active. In case your account expires, or you decide to delete your account “Room A to Z” retains your personal data not longer than 90 days after the account is expired.

   However, in case of conflict situations in progress “Room A to Z” may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defence of legal claims and for compliance with a legal obligation which requires processing by law to which the controller is subject in case of an expired account or in case data subject requested to delete his personal data. Upon the expiry of this period or earlier, if a conflict situation is settled, all personal data gets deleted

   In case your last activity on “Room A to Z”, as of the last payment date, was more than 180 (one hundred eighty) days ago, your account will be considered expired and gets deleted. Along with your account or profile all personal data processed by “Room A to Z” will be erased.

   As you are entitled to delete your account or profile after such a request it will be permanently removed within 30 days or earlier from our active systems, servers, and back-ups. By deleting your account or profile all your personal data will be removed as well within 90 days.

   Personal Data collected when you registered on our mailing list or for the newsletter will be stored if you are interested in receiving our emails. We consider that you are interested in this until you unsubscribe from the mailing list or from the newsletter by clicking the respective link contained in each of our emails.

   After the expiration of the retention period, “Room A to Z” shall terminate the processing of your personal data, unless otherwise is set by the relevant legislation.

6. Your rights as data subject regarding your personal data “Room A to Z” processes:

   • right of confirmation - to obtain from “Room A to Z” the confirmation as to whether personal data concerning you is being processed;
   • right of access to your personal data processed by “Room A to Z”;
   • right to rectification – ask “Room A to Z” to have incomplete personal data requiring corrections completed;
   • right to erasure (right to be forgotten) – request “Room A to Z” to erase personal data. In most cases “Room A to Z” will erase it unless otherwise required by legislation;
   • If one of the reasons applies, please contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately. These requests are free of charge.
   • If you believe that our use of your data violates your rights, you can lodge a complaint with the competent data protection authority.
   • Please, note that when the processing of your personal data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification and we will no longer process your data with such direct marketing purposes.
   • right of restriction of processing. For example, you could contest the accuracy of your personal data or in case “Room A to Z” is not interested in processing of your personal data any longer, but you want “Room A to Z” to do this for different reasons, for example, to bring some claim for somebody and, instead of the erasure of information, its processing will be just restricted.
   • right to data portability - to have your personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others;
   • right to object to processing of your personal data by “Room A to Z” when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us. The other case is if we process your data for the purposes of the legitimate interests pursued by us or by a third party and you believe that such interests are overridden by your interests or fundamental rights and freedoms. If you make a request with objection to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing;
   • Right to withdraw consent at any time by contacting us. After we at “Room A to Z” receive such withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data, unless otherwise is set by law.

7. Other Privacy Commitments

   1. Cross-border transfers

      We process your personal data both within the Estonia and outside Estonia. Although countries where we process data may have different laws, we take measures to ensure high privacy compliance.

   2. Time for reply and reaction

      “Room A to Z” will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if “Room A to Z” is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. “Room A to Z” will inform you of any such extension within one month of receipt of the request, together with the reasons of such delay.

   3. Security

      “Room A to Z” takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. For example, “Room A to Z” uses verified contractors that might have access to the data with which the relevant data processing agreements are signed.

   4. Children’s privacy

      The privacy of children is one of our concerns. “Room A to Z” Services are not intended for use by children under the age of 18 without the express permission of their parent or legal guardian. If you are under the age of 18 you will need to get your parent’s/legal guardian’s permission before submitting any personal data to “Room A to Z”. We may process the personal data of children under the age of 18 if data has been consensually provided by parents/legal guardians for the express purpose of using “Room A to Z” Services.

      We do not knowingly collect information from children and minors. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide information on our Website without their permission.

   5. Breach notifications

      If any personal data of yours would be under the breach, we would inform you and the respective data protection agencies as to the accidents without undue delay, if there are high risks of violation of your rights as data subject. We would also do our best to minimize any such risks.

   6. “Do Not Track” requests

      “Room A to Z” does not share personal data with third parties for their direct marketing purposes. Also, our Services do not support “Do Not Track” requests.

8. Legal Matters

   “Room A to Z” considers your use of its Service to be private. However, we may disclose your personal data stored in our databases, to:

   • comply with the law or legal process served on us;
   • enforce and investigate potential violations of this Privacy Policy; including use of this Service to participate in, or facilitate activities that violate the law;
   • investigate potentially fraudulent activities; or
   • protect the rights, property, or safety of “Room A to Z”, its employees, its customers, or the public.

   We hope this Privacy Policy helped you to understand how your personal data will be dealt here at “Room A to Z”. We will take care of your personal data, so you can use our Services and not to be concerned over your privacy. Should you have anything to tell us, e-mail us at support@roomatoz.com.

   We will be happy to receive any information or comment from you to make our platform better for our users.

   Your “Room A to Z” Team