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  1. General

At ELITE, we care about your personal data, so we have prepared this Privacy Policy to explain how we collect, use and share it.

This Privacy Policy (“Privacy Policy”) details the personal data ELITE, Inc. (“ELITE”, “we”, “us” or “our”) receives about you, how we process it and your rights and obligations in relation to your personal data. ELITE LANGUAGE TRAINING, Inc., a company registered at apt. 5, No. 69, Vali Rahmi Bey, Menderes Street, Buca, Izmir, Turkey, is the data controller for the purposes of the General Data Protection Regulation (“GDPR”) and any relevant local legislation (“Data Protection Laws”).

By using or accessing the Service, you agree to the terms of this Privacy Policy. Capitalized terms not defined here have the meanings set forth in the terms and conditions (the “Terms and Conditions”), located at https://englishelite.app/terms/. We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy on the Website for at least 7 days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that 7-day period.

 

  1. Information We Collect

This Privacy Policy explains how we collect, use and share your personal data.

Information you provide

Through the registration process, you will provide us with your name, mobile number, and e-mail address. You will also provide us with your payment transaction information if you choose to pay for ELITE services.

Activity Data

When you use the Service, you will submit information and content to your profile. We  will  also  generate  data  about  your  use  of  our  Services  including    your

engagement in educational activities on the Service (“Activity Data”). We also collect technical data about how you interact with our Services.

We only collect the data we need which means we collect:

o          Usernames

o          Names

o          Email addresses

o          Passwords

o         Usage Patterns

o          Taps

o         Scrolling

o          Typing

o         Tech Specs

o          Device type

o          Operating system

o         Viewfinder   size

o         Script errors

o          IP address

o          Learning Activity

o          Session progress

o          Answers

Product Research and Development

We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We will record the video, audio and text transcriptions of this feedback together with any additional contact information you provide and will retain this data for two years.

Please contact us at info@englishelite.app to:

–           Request more information about the research activities you have volunteered for.

–           Opt out of being contacted for research activities.

–           Request a copy of any research related data you have provided to us.

  1. Cookies

When you enter the Website, we collect your browser type and your IP address (a unique address that identifies your computer on the Internet). When you use our mobile Application, we collect your device type, your device ID, and your IP address.

In addition, we store certain information from your browser using “cookies.” A cookie is a piece of data stored on the user’s computer tied to information about the user. We use session ID cookies to confirm that users are logged in. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies may be necessary to provide you certain features available on the Website (e.g., customized delivery of information).

You can find more information about cookies and how to manage them at http://www.allaboutcookies.org.

 

  1. Information Obtained by Third Parties

To support and enhance the Service, we work with a variety of third party advertising networks, marketing analytics service providers and website analysis firms, such as Google, and Firebase. These Third Party Advertising Service Providers collect and use personal data about your visits to and use of the Website and mobile Application.

Aggregate demographic and interest data will also be used for market research purposes.

In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.

 

  1. Use of information obtained by ELITE

ELITE may occasionally send you service related and product change announcements through the general operation of the Service. We will send you reminder notifications to support the ELITE teaching methodology. We process your data to help provide you with the Service and offer personalized features, to understand and improve our Service and to keep our Service safe and secure.

ELITE may use or share anonymous data collected through the Service, including Activity Data without limitation. As a business, it is critical that we perform our contract with you with the best service possible, and it is in our legitimate interests to perform these processing functions and to enable service e-mails by default to keep your data secure and provide our Service. You may opt out of any non- essential service e-mails at any time.

We may also use your contact information to send you notifications regarding new services, offers and promotions offered by ELITE if you affirmatively consent to receive such communications.

Profile information is used by ELITE to be presented back to and edited by you when you access the Service and to be presented to other users. ELITE uses this

information to provide you with support, to send you essential notifications, to enforce our terms, conditions and policies, to communicate with you, to administer the Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes. ELITE’s Terms and Conditions provide the contractual lawful basis for these processing activities.

 

 

  1. Sharing your personal data with third parties

ELITE shares your personal data only when it is necessary to offer the Service, legally required, or permitted by you.

We will provide personal data to hosting providers such as Amazon Web Services, search engine providers such as Google, analytics providers, and support providers.

These data processors help us bring you the Service. For example, we may share your information in order to detect where or how you encountered a bug when using our mobile application. In connection with these operations, our service providers will have access to personal data for a limited time. When we utilize service providers for processing any personal data, we implement contractual protections limiting the use of that personal data to the provision of services to ELITE.

We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the ELITE name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies.

If the ownership of all or substantially all of the ELITE business, or individual business units or assets owned by ELITE that are related to the Service, were to change, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain subject to this section.

ELITE will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service.

 

  1. Data subject rights and data retention

ELITE will retain your data until your account is logged out, after which point we will retain anonymous data collected through the Service, including Activity Data, which may be used by ELITE and shared with third parties in any manner.

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.

 

  1. Third party websites and links

Please note that you may have cookies placed on your computer by third party websites that refer you to our Service. Although we do not share your personal data with these third party websites unless it is reasonably necessary to offer the Service, they may be able to link certain non- personally identifiable information we transfer to them with personal data they previously collected from you. Please review the privacy policies of each website you visit to better understand their privacy practices. In addition, ELITE would like to inform you that anytime you click on links

(including advertising banners), which take you to third party websites, you will be subject to the third parties’ privacy policies.

Our Services contain links to other sites operated by third parties. ELITE does not control such other sites and is not responsible for their content, their privacy policies, or their use of personal data, including any personal or financial information collected by our third party payment processor to process payments for in-app purchases. ELITE’s inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

 

  1. Children under age of digital consent

ELITE English App is designed for people over the age of 16. When a user creates an ELITE account, we ask for their mobile numbers. After registration we will send a confirmation code to the given mobile number. So, the children are not supposed to be able to create an account in ELITE.

 

  1. Links

The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave the Service to read the privacy statements of other websites that collect personally identifiable information. This Privacy Policy applies only to information collected by ELITE via the Service.

 

  1. Information security

ELITE has implemented administrative and technical safeguards it believes are appropriate to protect the confidentiality, integrity and availability of your personal data, and access credentials. However, given sufficient resources, a determined attacker could defeat those safeguards and may, as a result, gain access to the data we seek to protect.

  1. Do Not Track

The Service is not designed to respond to “do not track” signals sent by some browsers.

 

  1. Contact Us

ELITE’s office is located within Turkey at:

apt. 5, No. 69, Vali Rahmi Bey, Menderes Street, Buca, Izmir, Turkey Phone: +90 531 292 9970

For all data privacy inquiries and any questions or concerns you have about this Privacy Policy, please contact our Data Protection Officer at privacy@englishelite.app.

For all support inquiries, please go to https://support.englishelite.app.