Privacy Policy

Last updated February 13th, 2024

We recognize that privacy is important. 

Kwiziq Limited (referred to as "Kwiziq", "we", "us" or "our" in this Privacy Policy) is the controller and responsible for your personal data

This Privacy Policy applies to all of the products, services and websites offered by Kwiziq  and tells you how we look after your personal data when you visit our websites (regardless of where you visit it from) and lets you know about your privacy rights and how the law protects you. If you have any questions about this Privacy Policy, please feel free to contact us.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Kwiziq Limited

Email address: info@kwiziq.com

Postal address: Suite 112, 264 Lavender Hill, London, SW11 1LJ, United Kingdom

Telephone number: +44 20 3813 4952

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. 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 policy of every website you visit.

Information we collect and how we use it

We offer services that do not require you to register for an account or provide any personal information to us. In order to provide our full range of services, we may collect the following types of information:

Information you provide

• Identity Data and Contact Data - When you sign up for a Kwiziq account or other Kwiziq service or promotion that requires registration, we ask you for personal information such as your title, name, email address and an account password; we store your password in an encrypted form so that even we do not know it. If you make a purchase we may ask for your address. We will use the data you provide to send you a series of on-boarding emails.
• Financial Data and Transactional Data - If we need to take credit card, financial or payment details from you, we will either use a regulated third party (such as PayPal, Google Checkout, or a service provided by a regulated bank) in which case they may store your financial details, or we will store data in an encrypted form. We will never store financial information you supply to us in a form which is not secure.
• Profile Data - We may provide the ability for you to create a public profile, including personal details and one or more photos of yourself. Your profile may also be linked to your Facebook account in which case some data may be shared with Facebook. You may need to adjust your Facebook privacy settings. Anything you write about yourself in the details section of your profile is publicly available and may be available for other users to see, therefore you should not post anything you wish to keep private here. Do not write contact details such as your email address on your profile except in the contact details fields which are private and remain unpublished unless you explicitly give permission to certain users to see them.
• Cookies - When you visit our website, we send one or more cookies to your computer or other device that uniquely identifies your browser. We use cookies to improve the quality of our service, including for storing user preferences. Kwiziq may use cookies to help us improve the relevancy of advertising campaigns you receive.
• Technical Data and Usage Data - When you access Kwiziq services, our servers automatically record information that your browser sends whenever you visit sections of our website and use or services. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. We may also collect any feedback or survey responses you provide to us.

Other data we may store about you

• We may collect data about your language knowledge based on your use of our services, tools and games in order to support your language learning and tailor our educational programmes to your specific needs. We retain the right to this data, but we collect it for your benefit. You can see the data we hold about you and your language skills using the various reports available on the site. You may also request to see all the data we hold about you and we will do our best to provide it directly (though we cannot guarantee to supply it in a particular form).
• User communications - When you send email or other communications to Kwiziq, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
• Links - Kwiziq may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our services, customized content and advertising.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data (also known as “sensitive data”) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey such as a Typeform survey; or
• give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies[, server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy below for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources such as: Facebook and Google Pixel.[s3] 
• Technical Data from the following parties:

(a)     analytics providers such as Google based outside the EU; and

(b)     advertising networks such as Facebook based inside OR outside the EU.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal, Google Checkout, or a service provided by a regulated bank based [inside OR outside] the EU].
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How we use your personal data

Kwiziq only processes personal information for the purposes described in this Privacy Policy and/or the supplementary privacy notices for specific services. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Please see the Glossary at the end of this Privacy Policy to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). We use Amazon Web Services (“AWS”) Short Email Services (who use servers based in the EU) to send our promotional messages.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time].

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, product/service experience or other transactions.

Cookies

Kwiziq utilises "cookies". A cookie is a piece of data stored on the user's hard drive containing information about the user. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Kwiziq uses cookies to keep track of how often you visit our site and any previous purchases as well as to deliver content specific to your interests. Most browsers are automatically set to accept cookies but you can alter the settings of your browser to prevent this - a good guide for all browsers is here. If you choose not to receive cookies, you may still use most of the features of our website, including to purchase items. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. [We may also share this information with third parties for this purpose.]

You can find more information about the individual cookies we use and the purposes for which we use them below.

Use of cookies

Here are the cookies we use and why.

•         Google Analytics
  e.g. _utma, _utmb, _utmc,_utmz, ga, gat
  These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. These cookies will expire after X.
•         Marketing cookies
  e.g. fr, _fbp
  These cookies allow us to send anonymous information to advertising partners to ensure any advertising is relevant to you. These cookies will expire after X.
•         CMS cookies
  KWIZIQID,kwiziq_persistent
  These are set by our content management system to mantain your session or "being logged in"; it also helps us to personalise your site experience. These cookies will expire after X.
•         JSESSIONID
  This is set by our SSL provider to validate your secure link to our site (see the security seal at the bottom of the page). This cookie will expire after X.
•         cc_cookie_accept
  This indicates that you have seen our cookie policy popup and have accepted it - we will keep reminding you until you have done so. We know this is annoying but it's an EU requirement. This cookie will expire after X.
•         Uvc
  A functional cooking set by AddToAny. This cookie is used to provide the social sharing functionality on our careers advice article pages. This cookie will expire after X.
•         __cfduid
  A necessary security cookie from CDN provider CloudFlare set by AddToAny. This cookie will expire after X.

In addition to the above, some of our "share" functions, such as Facebook Like or Tweet, set cookies for their own purposes.  These can vary and are not set explicitly by kwiziq.com - these too can be blocked by configuring your browser settings. 

Choices for personal information

When you sign up for a particular service that requires registration, we may ask you to provide additional personal information. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we wish to use this information in a manner different than the purpose for which it was collected, we will notify you and we will explain the legal basis which allows us to do so.  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

If we propose to use personal information for any purposes other than those described in this Privacy Policy and/or in the specific service privacy notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Privacy Policy and/or in the supplementary service privacy notices, unless we have obtained your prior consent.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Kwiziq features and services may not function properly if cookies are disabled.

Kwiziq may uses 3rd party advertising cookies such as Google's AdSense.

You can decline to submit personal information to any of our services, in which case Kwiziq may not be able to provide those services to you.

Information sharing

Kwiziq only shares personal information with other companies or individuals outside of Kwiziq in the following limited circumstances:

International transfers

Kwiziq processes personal information on our servers in the United States of America, United Kingdom, the Netherlands, Poland, Spain, and other countries. In some cases, we process personal information on a server outside your own country. We may process personal information to provide our own services. In some cases, we may process personal information on behalf of and according to the instructions of a third party, such as our advertising partners.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
•  Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

The data we store about your language skills may be made available to 3rd party language services that use our API in order that they can provide services to help you improve your language skills, but they may not store this data about you. For example, a 3rd party may have a game that helps improve vocabulary skills that, using our API, can work out what vocabulary you need to practice next in order to improve and then serve the content most suited to your needs.

We require opt-in consent for the sharing of any sensitive personal data.

We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Kwiziq, its users or the public as required or permitted by law.

If Kwiziq becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who searched for a particular term, or how many users reached a certain level of competence in a language. Such information does not identify you individually.

Please contact us using our website for any additional questions about the management or use of personal data.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage, processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to Kwiziq employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

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

Data integrity

Kwiziq processes personal information only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services or as otherwise permitted under this Policy. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see the section on your legal rights in the Glossary below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes (such as when we use third-party machine learning tools for rapid development), in which case we may use this information indefinitely without further notice to you.

Accessing, updating or deleting personal information

If you no longer wish us to hold data about you, then you can request that we purge your account and we will destroy any data we hold that could be used to identify you. We reserve the right to keep statistical or anonymised data. We will no longer have any way of knowing to whom the data once referred.

When you use Kwiziq services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or are extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Some of our services have different procedures to access, correct or delete users' personal information. We provide the details for these procedures in the specific privacy notices or FAQs for these services.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). Each version of this Privacy Policy will be identified at the top of the page by its effective date, and we will also keep prior versions of this Privacy Policy in an archive for your review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us.

Glossary

LAWFUL BASIS

‘Legitimate Interest’ means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

‘Performance of Contract’ means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

‘Comply with a legal obligation’ means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers [acting as processors] based United States, Holland, Poland, France who provide IT and system administration services.
• Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in United Kingdom, France who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Google, PayPal, HSBC, Facebook 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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. Alternatively, we could refuse to comply with your request 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 any person who has 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 try to respond to all legitimate requests within one month. Occasionally it could 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 and keep you updated.