POLÍTICA DE PRIVACIDADE ABA ENGLISH
Detailed information on Data Protection regarding the processing of student data:
Who is the Data Controller for your data?
Identity: ENGLISH WORLDWIDE, S.L. – CIF (Tax Identification No.): B64401482
Postal Address: C/ Aribau, 240, 08006 Barcelona
Data Protection Officer: www.abaenglish.com/dataprotectionofficer
Contact DPO: firstname.lastname@example.org
- What data we collect and what we do with it
- What technology we use
- Which advertising services we use
- What data protection rights you have and how you can exercise your rights
Who can I contact?
- Email: email@example.com
- Mail: ENGLISH WORLDWIDE, S.L. C/ Aribau, 240, 08006 Barcelona
Our Data Protection Officer or another data protection relevant contact can be reached at the email provided above.
What are my rights?
You may contact us at any time if you have any questions concerning your data privacy rights or if you wish to exercise any of the following rights afforded to you under the General Data Protection Regulation (2016/679; the “GDPR”). You have the:
- Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g. you can contact us if you wish to cancel a previously given consent to receive our newsletter)
- Right to access your data in accordance with Art. 15 GDPR (e.g. e.g. the right to be informed whether or not personal data about you is being processed, what personal data is being processed, and the purpose of the processing.
- Right to correct your data in accordance with Art. 16 GDPR (e.g. you can contact us if your e-mail address has changed and you would us to update the details we hold)
- Right to have your data deleted in accordance with Art. 17 GDPR (e.g. you can contact us if you want us to delete certain data that we have stored about you)
- Right to limit data collection in accordance with Art. 18 GDPR (e.g. you can contact us if you only want us to send you absolutely necessary e-mails)
- Right to data portability in accordance with Art. 20 GDPR (e.g. you can contact us to receive your data in a commonly used and machine-readable format if you want to upload it to another website)
- Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 lit f GDPR (e.g. you can contact the data protection supervisory authority directly)
If you wish to file a complaint with a national supervisory authority regarding our processing of your personal data, you may do so by contacting your local data protection authority (“local” meaning where you live or work, or where an alleged data breach has occurred).
The relevant authority in Spain is:
Agencia Española de Protección de Datos (AEPD)
C/ Jorge Juan, 6. 28001 Madrid
Information We Collect
Through the registration process, you will provide us with your name, e-mail address. You will also provide us with your payment transaction information if you choose to pay for ABA English services.
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, or your sending of messages and otherwise transmitting information to other users (“Activity Data”). We also collect technical data about how you interact with our Services through our Cookies (section below).
When you use ABA English in our app or on our website, we use a service named ABA English Service Gateway (https://gateway.abaenglish.com ) to log your activity. Gateway captures your usage data to keep track of your activity progress across all our Services and provide you a better experience.
We do collect the following data:
- Tech Specs
- Device type
- Operating system
- Script errors
- IP address
- Pages visited
- URL parameters
- Session duration
- Learning Activity
- Session progress
Storage periods and deletion of data
We only store your information for as long as is needed to fulfill our contractual or legal obligations or any other permissible purpose for which we have collected it, including to detect and prevent fraud or security incidents. When the applicable retention period has expired, we take measures to permanently delete the information, aggregate it, or anonymize it.
Visiting our website
If you merely wish to browse our website, we do not collect any personal data, with the exception of the data that your browser sends to us, e.g.:
- Pages and files accessed
- Date and time of access
- Transmitted data volume
- Browser version
- Status messages (i.e. whether the data transfer was successful)
- Information about your device (e.g. browser version, app version, operating system, language settings, device IDs)
- Previously visited pages (if you access our website via a link)
- Online identifiers (e.g. IP address, session IDs, cookies, device identifiers)
- Geographic data (e.g. city, postal code) (transmitted via IP address)
As a safeguard to protect your privacy, we delete or anonymise the IP address according to set deadlines. Therefore, all other data possibly attached to it can no longer be traced back to you. The information we retain is in anonymous form and is only used for statistical purposes to optimise our website. The purpose of temporarily storing this data is to establish a necessary connection between your device and our server as well as ensuring that our website loads effectively. Such data is therefore required to display the website on your screen, to avoid display problems and other technical error messages. The legal basis is our legitimate interest as laid out under Art. 6 para. 1 s. 1 lit f GDPR.
Providing the ABA ENGLISH services
This also includes
- The provision, personalisation and customisation of our ABA ENGLISH services (including their respective websites, apps and cross-device functions),
- Ensuring the general security, operability and stability of our services, including the prevention of cyber- attacks,
- Communication in regards to technical/security issues as well as contractual amendments (e.g. fraud warnings, account suspension or contract amendments) and,
- The implementation of campaigns and competitions.
Insofar as the purpose is the implementation of a contract agreed with you or the provision of a service requested by you, the legal basis is Art. 6 para. 1 s. 1 lit. b GDPR. Otherwise, the legal basis is Art. 6 para. 1 s. 1 lit f GDPR, whereby our legitimate interest lies in the above-mentioned purposes.
Your ABA ENGLISH account
In order to use our ABA ENGLISH language course, you need to register on our website/app. When you register on our website, we collect and store your basic data such as (student) name, e-mail address and password. In addition, when you subscribe to our Services or place an order with us, we collect payment details and record your agreement to our Terms and Conditions.
As a protective measure, the data you enter is transmitted via an encrypted connection – just like when you visit our website. After successful confirmation, your data will be stored until you decide to delete your information or your entire student account. The purpose of the requested data is to create a student account for the use of extended functions on the website. Registration is voluntary and can be revoked or the student data deleted at any time. The legal basis is your consent as laid out in Art. 6 para. 1 s. 1 lit a GDPR.
You have the possibility to contact us in different ways on our website or in our app. You can get in touch with us about general requests by writing to our customer service at firstname.lastname@example.org or contacting us through the methods described in our Help Centre. In this context we process data exclusively for the purpose of communicating with you. The legal basis for data processing is the fulfillment of the contract in accordance with Art. 6 para. 1 s. 1 lit b GDPR.
Whenever you complete a course or a live class in our app or on our website, all exercise results of yours are stored in your personal progress section. This data cannot be viewed by other students. The legal basis for data processing is the fulfillment of the contract in accordance with Art. 6 para. 1 s. 1 lit b GDPR.
Our ABA Live Classes service offers ABA users the opportunity to take part in digital language lessons in small groups (usually between 1 upt to 50 users). For this service, users meet together with a teacher and take part in a lesson. As part of the lesson, learning objectives are defined and language exercises are carried out, and the teacher supports the users as they learn the language. The personal data entered during registration by the user is processed as part of this service. The user’s name will therefore be visible to the teacher and to other participants.
ABA Live lessons are hosted on BigMarker, a US-based online meeting platform (https://www.bigmarker.com). We have signed a data processing agreement with BigMarker which includes the EU standard contractual clauses to ensure the safe transfer of your data.
In doing so, we have configured our settings provided by BigMarker in such a way that only necessary personal data is processed in order to provide the virtual lessons. Features such as attention tracking and other analytical options are always deactivated.
For further information on BigMarker’s privacy policies please see: https://www.bigmarker.com/privacy.
Research, artificial intelligence and machine learning
We process the data collected about our customers for scientific research in fields relevant to ABA ENGLISH. These are in particular the fields of machine learning, artificial intelligence, natural language processing and deep learning as well as tracking the efficiency of online learning processes. ABA ENGLISH’s research focuses on solving real, everyday problems of learning English and is intended to improve and develop the existing service offering. It goes without saying that we comply with recognised scientific data protection standards. This also means that we only process your data in anonymised or pseudonymised form, for example by replacing all identifiable data such as your name with other information.
Research at ABA ENGLISH includes the following purposes:
- The development of machine-learning methods that enable estimates, forecasts and analyses of the needs and interests of our students;
- The development of technical solutions to real customer problems that our customer service department encounters in everyday business;
- The improvement of speech recognition and the optimisation and individualisation of our learning units;
- The development of technical solutions to enhance and improve the student experience and prevent fraud.
The legal basis for the processing of your data for the research purposes described above is Art. 6 para. 1 s. 1 lit f GDPR, whereby our legitimate interests lie in the above-mentioned purposes.
Registration via Social Networks
In addition to our standard registration process, we offer you the ability to register with us using your existing account in Facebook or Google (collectively referred to as “Social Networks”) using the following plugins “Sign in with Facebook” or “Sign in with Google”). If you want to use one of these functions, you will be redirected to the page of the respective provider and navigated through the registration process.
To ensure the protection of your privacy, any data you submit is transmitted via a secure connection through the corresponding platform. We do not use your login details to access any personal information such as your friend lists or contacts, nor do we store any of this information for our own purposes. There is no permanent link between your ABA ENGLISH account and your account on Facebook. For further details on what kind of information Facebook collects on you please see their respective privacy statements: Facebook (https://facebook.com/policy.php), Google (https://policies.google.com/privacy?hl=en). The purpose of the data requested is the registration via an existing student account to use extended functionality on the ABA ENGLISH website. Registration via Social Networks is voluntary and can be withdrawn at any time by logging out of the relevant social media account. The legal basis is your consent as laid out under Art. 6 para. 1 s. 1 lit a GDPR.
If you are interested in receiving updates about our company or our products, you can subscribe to our newsletter. You will then receive an email in which you must click on a link to confirm receipt of the newsletter. We store the email address you provided until you unsubscribe from our newsletter. For this purpose, you will find a corresponding link to unsubscribe in every email of our newsletter. The delivery of the newsletter is carried out by a professional service provider.
As a safeguard to protect your privacy, we ask for a so-called “Double-Opt-In” to ensure that the registered email address actually belongs to you. Furthermore, we have entered into a data processing agreement with the assigned service provider. You also have the possibility to unsubscribe from the newsletter at any time and thus delete your email address from the service provider’s database. The purpose of the data requested is to send the newsletter to your personal email address in order to fulfil your request for updates about our company or our products. The legal basis is your consent in accordance with the European data protection requirements under Art. 6 para. 1 s. 1 lit a GDPR.
If you register for our ABA ENGLISH services, we will also send you marketing emails (advertising to existing customers). You can object to receiving these at any time by sending an e-mail to email@example.com
There is also a corresponding unsubscribe link in every marketing email. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR, based on our justified interest in advertising our products and services.
We use embedded graphics known as pixels in our newsletter emails to track whether or not an email has been opened and which links in the email have been clicked on in order to optimize our offers. We collect this data in pseudonymous form for general statistical evaluations as well as for the optimisation and further development of our content and customer communication. The data is not linked to your personal data. The legal basis for this is our aforementioned legitimate interest in accordance with Art. 6 para. 1 s. 1 lit. f GDPR. We use our marketing emails to share content that is most relevant to you and to better understand what our students are actually interested in. If you do not want us to analyse your usage behaviour, you can unsubscribe from our marketing emails or deactivate graphics in your email program by default. The data on your interaction with our marketing emails are stored pseudonymously to improve deliverability and to remedy technical defects; they are then eventually completely anonymised.
- Name of the website
- Expiration date of the cookie
- Any cookie value
Provided that cookies do not contain a specific expiration date, they are only saved temporarily and automatically deleted as soon as you close your browser or turn off the device. Cookies with expiration data remain saved even after you have closed your browser or turned off your device. These cookies are only removed once they have reached their expiry date or if you manually delete them.
We use the following three types of cookies on our website:
- required cookies (e.g cookies that required to display the website correctly for you and to store certain settings temporarily)
- functional and performance-related cookies (cookies that help us improve our website, e.g. to evaluate technical data from your visit and therefore avoid error messages)
- advertising and analytics cookies (cookies that provide analytics and personalized ads, e.g. you see ads for shoes if you had previously searched for shoes)
You can use your browser settings to configure, block, and delete cookies. If you delete all cookies from our website, you may find that some website features are not displayed properly. You can find helpful information and instructions for common browsers on the website of Your Online Choices
Cookies are only activated after you have granted express permission, with the exception of those cookies that are required for the technology to work. You can withdraw this permission at any time. You can find information on how to withdraw permission, as well as additional information, in the cookie configuration options.
We use YouTube to integrate videos. YouTube is operated by YouTube LLC with headquarters at 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google Inc. with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When playing the embedded videos, a connection to the YouTube servers is established and your IP address is transmitted for technical reasons. If you are also logged into your YouTube student account, YouTube will assign information on the videos you have viewed to your personal student account. You can prevent this assignment by logging out of your YouTube account and other Google Platform accounts before using our website.
The purpose of the data transfer is the integration of YouTube videos on our website, in order for our students to be able to access the displayed videos comfortably without leaving our website. The legal basis is your consent in accordance with Art. 6 Para. 1 a GDPR.
You can find additional information on Google Analytics’ use of data and data protection at https://marketingplatform.google.com/about/analytics/terms/de/ or at https://marketingplatform.google.com/about/. ABA ENGLISH only uses Google Analytics in combination with the gat._anonymizeIp(); expansion, so that IP addresses are only recorded in a shortened, i.e. anonymized form.
Google Conversion Tracking
Our website uses Google Conversion Tracking from Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (subsequently: Google), in order to record statistics on the use of our website and for the purpose of evaluating optimization of our services for you. Google AdWords places a cookie on your computer in the event that you have reached our website via a Google ad. If the student visits specific pages on the AdWords customer’s website, and if the cookie has not yet expired, Google and the customer can see that the student clicked on the ad and was directed to this page. Every AdWords customer receives a different cookie. Cookies can therefore not be tracked via AdWords customer’s websites. The information collected with help from the conversion cookies serves to create conversion statistics for AdWords customers who have decided to make use of conversion tracking. We receive information on the total number of students who have clicked on the advertisement and were forwarded to a page containing a conversion tracking tag. However, we do not receive any information that can be used to personally identify students.
The legal basis for use of this service is your consent as laid out in Art. 6 para 1 s. 1 lit. a GDPR, and consent is granted via our cookie banner. Consent can be withdrawn at any time via the cookie management portal.
Google Tag Manager
The legal basis for use is your consent in accordance with Art. 6 para. 1 s. 1 lit. a GDPR, which can be granted in our cookie banner. This consent can be revoked at any time via our cookie management tool.
Data shared with Facebook (only applies to registered students of Facebook)
We participate in a statistical program run by Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA, which identifies Facebook students who have a similar usage profile to our existing customers (“Facebook Custom Audiences – Statistical Twins”). As part of this program, email addresses of customers are transferred to Facebook in an anonymised form (as a so-called “hash”). It is no longer possible to derive the email address from the transmitted data. Facebook uses the same method to create a hash from the email addresses of their students, compares this anonymised data and determines whether one of our students is registered with Facebook with the same email address.
Facebook guarantees that they will not store this match or use it outside of this program. On this basis, third parties are then identified who use Facebook in a similar way to our customers and we are given the opportunity to address these people in a targeted manner. You will not receive any additional advertising or messages from us or from Facebook.
If you are not registered with Facebook under the same e-mail address you used to register with us, then Facebook will not receive any information about you. We will not under any circumstances be informed as to whether you are registered with Facebook and will also not receive any additional data on you.
We also use the web analytics service Hotjar from Hotjar Ltd. Hotjar Ltd. is a European company with their headquarters in Malta (Hotjar Ltd, Level 2, St. Julian’s Business Centre, 3, Elia Zammit Street, St. Julian‘s STJ 1000, Malta, Europe). This tool is used to record movement on websites using Hotjar (heat maps). This provides information, for example, on how far down the page users scroll, which buttons the users click and how often. It is also possible to get feedback directly from website users using this tool. This allows us to access valuable information in order to design our websites so that they are faster and more customer friendly.
When using this tool, we pay particular attention to protecting your personal data. We are only able to see which buttons were clicked, how the mouse moved, how far down the page you scroll, the device’s screen size, the type of device and browser information, geographical location (only the country), and the preferred language for displaying our website. Areas of the website that show personal data from yourself or a third party are automatically hidden by Hotjar and we are therefore restricted from accessing this information at any time.
The legal basis for use of this service is your consent as laid out in Art. 6 para. 1 S. 1 lit. a GDPR, and consent is granted via our cookie banner. Consent can be withdrawn at any time via our cookie management tool.
In order to constantly improve and optimize our product, we use mobile tracking technology. For this we use the services of Adjust GmbH, Saarbrücker Str. 38a, 10405 Berlin, Germany ().
We use Adjust to collect statistical data to help us improve our product. When you use our app, information from your mobile device is transmitted to us. The following data is collected: IP address, which is immediately anonymised, MAC address, anonymised Device ID (IDentifier For Advertisers – IDFA or Google Advertiser ID – GAID), browser type, language, Internet Service Provider, network status, time zone, URL of the access and exit page, time and date of access, clickstream data and other statistical information about the use of our services. There is no direct personal reference. The data collected in this way is used to create anonymous user profiles. We do not use this data to personally identify visitors to our websites without their consent. **As a protective measure**, we do not use individual data. We only use data in aggregated form for statistical evaluation. **The purpose** processing is to provide interest-related advertising content. **The legal basis** is your consent in accordance with Art. 6 para. 1 s. 1 lit. a GDPR.
We use service providers to optimize our online advertising outside of ABA ENGLISH. By optimisation, we mean that our advertising (e.g. ads on Facebook and Twitter, in Google search results or on other websites that make your advertising space available via an advertising network) is aimed at addressing only those people who might actually be interested in our offers (“personalisation”). For example, we can avoid showing ABA ENGLISH ads to individuals who have already signed up to our product. Personalized advertising also enables us to adapt our advertisements to the interests of other students who have never interacted with ABA ENGLISH before.
For this purpose, ABA ENGLISH services, as well as the services (especially websites, apps) of other companies that participate in the same advertising networks as we do (e.g. Google advertising network), contain special cookies or comparable technologies (e.g. pixel procedures) that are set by the respective providers and provide them with certain access data when using these services. Using this data, the respective providers can create a student profile to determine which websites and apps you use and derive your interests from this (your IP address is only transmitted for technical reasons but is not used for personalisation). The operator of an advertising network can then use this data to display personalized advertisements to you on all advertising spaces connected to their advertising network. For example, if you search for Italian language courses on Google, Google may use this information to show you our advertising for a free Italian test on another page that is also connected to the Google advertising network. Since we participate in the Facebook advertising network, we may, for example, ask Facebook to display our Facebook Ads only to Facebook members who have visited our site in the last month.
We process the personal data for the above-mentioned purposes on the basis of your expressly given consent.
We use Amplitude (https://amplitude.com/) as a third-party cloud-based product-analytics platform. When you use our Services, information from your browser or device is transmitted to Amplitude.
The following data is collected: IP address, Device ID (IDFV or random-generated alphanumeric string for the device ID), device type, browser type, operative system, language, version, Internet Service Provider, network Carrier, time zone, clickstream data and other information about the use of our services. There is no direct personal reference. The data collected in this way is used to create anonymous user profiles. We do not use this data to personally identify visitors to our websites without their consent. **As a protective measure**, we do not use individual data.
We only use data in aggregated form for statistical evaluation. **The purpose** processing is to provide insights to build better products. **The legal basis** is your consent in accordance with Art. 6 para. 1 s. 1 lit. a GDPR.
For further information on Amplitude’s privacy policies please see: https://amplitude.com/privacy.
Our app allows you to share content using the standard features of your mobile device through other services, such as email or social networking sites whose apps you have installed. Only when you actually tap the share feature will the data be transferred to the operating system of your mobile device and from there to the app (e.g. Twitter, Facebook, email client). The further processing of the data is governed by the data protection declarations of the respective apps.
The purpose and scope of the data collection and the further processing and use of the data by social networks as well as your rights and settings options for protecting your privacy can be found in the privacy policies of the respective networks:
When is your data shared?
Data collected by us will only be passed on if:
- you have given your express consent in accordance with Art. 6 para. 1 s. 1 lit. a GDPR,
- the disclosure pursuant to Art. 6 para. 1 s. 1 lit. f GDPR is necessary for the assertion, exercise or defense of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data,
- we are legally obliged to pass on the information in accordance with Art. 6 para. 1 s. 1 lit. c GDPR; or
- this is legally permissible and, according to Art. 6 para. 1 S. 1 lit. b GDPR, is necessary for the processing of contractual relationships with you or for the implementation of pre-contractual measures which are carried out at your request.
In addition, information may be passed on in connection with official enquiries, court orders and legal proceedings if this is necessary for legal prosecution or enforcement.
Payment Service Provider
We use payment service providers. Depending on which payment method you select on checkout, the payment service providers commissioned by ABA ENGLISH are responsible for collecting and processing your payment details (e.g. bank details or credit card data). In this respect the data protection declaration of the respective payment service provider applies.
ABA ENGLISH takes security precautions to guarantee that your data is protected from loss, alteration, or misuse. ABA ENGLISH does this with industry standard firewalls that are constantly being updated as well as other security systems. At the same time, the student should be aware that we cannot offer one hundred percent protection from attacks, due to the constant barrage of new viruses and means of attack on internet service’s secure data systems. ABA ENGLISH will pursue every attack on the data, regardless of who carried it out, under both civil and criminal law, and inform students in the event that their data has been compromised.
Last updated: November 2022