[last updated June 2024]

We take your privacy seriously, and we have drafted this policy to explain what information we collect about you, what we do with it, how we store it, and your rights.

‘Personal information’ directly identifies you, such as your name and email address, or data that could be used, on its own or combined with other data, to identify you.

In general, we only use your personal information to deliver our services and send you information about them. We never sell or give away your personal information.

What kind of data is collected?

Our company collects the following set of data and information:

• Personal identification information (name, email address, phone number)
• Images 
• Videos 
• Audio 

1. Staying Anonymous

You can browse our online services anonymously. However, if you request information or sign up for/purchase a subscription or free lesson, you must identify yourself. At that point, we will start collecting your personal information. If you do not give us personal information, it will affect our ability to provide you with the requested information or to deliver our products or services.

2. Collecting personal information

We aim to always collect only the minimum information needed for our services. For example, if you sign up for a free lesson, we will collect and use your email address. As you would expect, the more involved you are with us, the more information we will collect about you.

We collect information about you mainly when you give it to us, which can happen in various ways.

We may process the following categories of personal information about you:

• Communication data: This includes any communication that you send to us. This might be when you request a free lesson, join our mailing list, or contact us through the contact form on our website, through email, text, social media messaging, social media posting or any other communication you send us. If you sign in using social media, we receive (by your consent) additional information such as your profile picture and social profile ID. We process this data to communicate with you, for record-keeping, and for establishing, pursuing, or defending legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records, and to establish, pursue, or defend legal claims.
• Customer Data: This includes data you give us when you purchase goods and/or services from us, including any of our courses, live classes, or digital downloads. This will include basic information about you and the information we require for billing purposes such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details, and card details (last digits only). We use third-party services for processing payments such as NHN KCP (in Korea), PayPal, and/or Stripe, and we do not receive or store your full card payment information. We process this data to supply the goods and/or services you have expressed an interest in or purchased, and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract, and our legitimate business interest in keeping records for accounting purposes.
• User Data: This includes data about how you use our website and any online services, together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases, and to enable publication and administration of our website, other online services, and business. Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and our business.
• Technical Data: This includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings, and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We also use our own cookies for functions such as checking if you are logged in and which products you have access to. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you, and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests, which in this case enable us to properly administer our website and our business, grow our business, and decide our marketing strategy.
• Marketing Data: This includes your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our leader boards and promotions such as competitions and giveaways (if any), to deliver relevant website content and advertisements to you, and measure or understand the effectiveness of this advertising. We also use cookies to track where sales on our website come from so we can attribute sources of sales. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop our products, to grow our business, and to decide our marketing strategy.
• We may use Customer Data, User Data, Technical Data, and Marketing Data to deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we serve you. We may use cookies and tracking pixels (e.g. Facebook pixels) for retargeting to do this. Our lawful ground for this processing is a legitimate interest, which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
• We may also use your personal information to make automated decisions about you. For instance, our email manager may monitor which emails you open and use this information to automatically manage future emails you receive. Our lawful ground for this processing is our legitimate interests, which in this case are to study how customers use our products/services and to grow our business.

3. Collecting information from third parties

As discussed above, we collect personal information about you when you give it to us and when it is collected by our website however we may also collect personal information that is given to us or available to us by a third party (for example, information that you have made available on a public platform like a discussion site).

We may receive data from third-party analytics providers and advertising networks like Google and Facebook.

This information forms part of the personal information described in this policy. We will not intentionally collect personal information that is unintentionally disclosed.

4. Collecting sensitive information

We do not intend to collect sensitive information about you and request you never disclose information about your health, racial or ethnic origin, political opinions, religious beliefs or sexual orientation on our website or any blog or social media account associated with our website or business. If you do post this information on any of our platforms (for instance you might accidentally tell someone in a discussion that your ethnicity is Korean), we will not intentionally store this information on our file however it may be stored on the platform you posted it on, and we have no control over such storage.

5. Children’s privacy

Our services are not designed to be used by minors under 18, and we do not intend to collect information about such minors. If you have a child who you would like to use our services, you will need to set up an account in your own name and then supervise their access to your account. We will make reasonable endeavors to delete any details of users under the age of 18 years when a parent or guardian has notified us that any such details have been obtained. By providing us with your data, you warrant to us, that you are over the age of 18.

6. Reviews

Suppose you provide us with a review or testimonial. In that case, you give us your consent to use your name, likeness, web address, the product you are reviewing and the date of service delivery to be displayed on our website or in our other marketing material, together with the content of the testimonial that you provide. If you provide your review or testimonial by YouTube clip, you also consent us to use this. We may store and/or use your review for as long as the information is relevant to our business. We process this information based on your consent, which you may withdraw.

7. Marketing Communications

Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). We may sometimes recommend sharing your information with a third party for their marketing purposes. We will get your express consent before we share your personal data with any third party for their own marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. You can also email us at contact@zippylearner.com to request your details be removed from our marketing list.

If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided for other transactions, such as purchases.

8. Social Networking Services and links to other websites

You can connect with us via our social media pages for example on Facebook, YouTube, and Twitter following our Rules of Conduct for Social Media. We may also provide links to other websites or use social networking services to communicate with the public about our work.

We may collect your personal information when you communicate with us using these services. The social networking service will also handle your personal information for its own purposes and have its own privacy policies. You should become familiar with the privacy policies of any service you use.

9. How we use Cookies and other identifiers

We use a range of tools provided by third parties, including our website host, third-party service providers, and search engine browsers, to collect or view access and traffic information for statistical, reporting, and maintenance purposes. Third-party providers have their own privacy policies. We may also use tracking pixels, cookies, and session tools to improve your experience when accessing our online services.

The data collected by cookies does not usually identify you, but it may be combined with other information to identify you. Suppose we identify you using information from cookies. In that case, we may use that information to track how you use our online services, send you information more specific to your needs, or invite you to purchase our services.

The kind of information that can be collected includes:

• device-specific information such as mobile network information
• server logs including your IP address, the times you use our services and system activity
• location information including IP address, GPS, and Wi-Fi access points
• local storage availability

We use the information to help to track your use of our online services to improve your user experience and the quality of our services.

10. Use and disclosure of personal information

In summary, as a legitimate business interest, the personal information we collect about you is used:

• to verify your identity
• to enable you to use our services
• to process orders, subscriptions, and inquiries
• to provide you with information about products and services that may interest you
• to provide you with personalized service or special opportunities
• to allow you to participate in interactive features of our online services
• to run competitions, prize draws, and promotions (if any)
• to facilitate our internal business operations
• to improve our products or services and in planning new products or services
• to conduct market research surveys in relation to our services
• to monitor compliance with our terms and conditions

With your consent or at your request, we may:

• Share your contact information with third-party organizations who offer products or services that may be of interest to you (if you agree to receive such information)

We may also disclose your information to:

• Other companies in our group who provide services to us.
• Third-party suppliers we engage to provide services that involve processing data on our behalf, such as IT and system administration services and website developers, will be required to use that information only to provide the services we have requested and in compliance with the provisions of this privacy policy (or equivalent standards).
• Payment of third parties if there is a dispute over a payment. For example, suppose PayPal contacts us regarding a dispute over a payment. In that case, we will provide PayPal with user activity information such as IP address, course enrollment and activity linked to the IP address, billing details on our system, etc. to allow the payment dispute to be resolved.
• Professional advisers include accountants, lawyers, bankers, auditors, and insurers.
• Government bodies that require us to report processing activities.
• Third parties where we are required to by the law and reserve the right to fully co-operate with any law enforcement authorities or court order requiring or requesting us to disclose the identity or other usage details of any user of our online services, or by a properly executed court order, or as otherwise required to do so by law.

11. Security and overseas recipients

We are committed to ensuring that your information is secure to industry standards; however, no system can be 100% secure, and, provided we have acted by this policy, we are not responsible for any loss you may suffer should your personal information be unlawfully accessed.

Using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. For example, our hosting and storage are managed by Hostinger who have their data centers in Europe, Asia, North America, and South America and maintain several security measures worldwide. Not all countries have the same level of privacy protection as the country you reside in. You acknowledge and agree to our processing of personal data across international borders in this way. We will do our best to ensure your data is protected to a similar standard as set out in this policy by using third party providers with similar privacy protections.

We will also take reasonable steps to protect all personal information within our direct control from misuse, interference, loss, unauthorized access, unlawful or accidental destruction, modification, or disclosure. To prevent unauthorized access or disclosure, we use respected hosting services, firewalls, and other electronic security procedures and managerial procedures to safeguard and secure the information we collect from you.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

All hard-copy records we keep are stored in South Korea.

12. Opt-out/ unsubscribe

We will allow you to opt in to receive information about our products or services. You can change your preferences at any time using the unsubscribe options in the emails you receive.

If you would like to delete your account with us, you may do so by contacting us at contact@zippylearner.com and requesting that your account and non-transaction data be deleted. Please note that this will not delete all personal information from our system, as we retain your information in other areas. For example, we will still retain your purchase history and transaction data.

If you continue to receive communications you have unsubscribed from, please contact us via email at contact@zippylearner.com and we will remedy the problem.

13. Data retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it, including satisfying any legal, accounting, or reporting requirements.

When deciding how long to keep the data, we consider its amount, nature, sensitivity, potential risk of harm from unauthorized use or disclosure, processing purposes, and whether these can be achieved by other means and legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for some time even after they stop being customers.

In some circumstances, we may anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

14. Third-Party Links

Our website(s) may include links to third-party websites, plugins, and applications. Clicking or enabling those links may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

15. Updates

We regularly review and update our privacy policy from time to time. The updated provisions will apply from the date they are posted on our website, so we recommend that you re-visit this privacy policy when you use our online services.

16. Accessing and correcting your personal information – Your legal rights

Under data protection laws you have rights (depending on your country of origin) in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, object to processing, portability of data, and (where the lawful ground of processing is consent) to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at contact@zippylearner.com for assistance.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive or refuse to comply with it in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone with no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We will record and store all information exchanged while exercising your rights under this clause for record-keeping purposes.

Furthermore, we try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex, or you have made a number of requests. In this case, we will notify you.

If you request to have your information erased (also known as the right to be forgotten), we will, if appropriate, delete your personal information from our active business operating system. Your personal information will however continue to be stored within our backup(s) as we are unable to delete specific items from our backup. It will be deleted at the next scheduled backup deletion. We will keep a log of your request to be forgotten so that, should our backup be used to restore our operating system while your personal information is still stored, your personal information will again be removed from our active system upon restoration.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office in your country. For instance, in South Korea, you can contact the Korea Internet and Security Agency at privacy.kisa.or.kr. We would be grateful if you would contact us first if you have a complaint so that we can try to resolve it for you.