Privacy Policy
Personal data (hereinafter referred to as “data”) is processed by us only to the extent necessary and for the purpose of providing a functional and user-friendly website, including its content and the services offered therein.
In accordance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”), which came into force on 2 January 2022, “processing” means any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation, retrieval, use, disclosure, transmission, dissemination, alignment, restriction, erasure or destruction.
This Privacy Policy informs you about the nature, scope, purpose, duration and legal basis for the processing of personal data, where we decide either alone or jointly with others on the purposes and means of such processing. We also inform you about third-party components used for optimisation purposes, where third parties process data under their own responsibility.
This Privacy Policy is structured as follows:
- I. Information about us as the Data Controller
- II. Rights of Users and Data Subjects
- III. Data Breach Notification
- IV. Information on Data Processing
I. Information About Us as the Data Controller
The responsible party for this website in terms of data protection law is:
Lingyra Language Training Services LLC: 137, Al Mustaqbal street, Business Bay, Dubai, United Arab Emirates
Telephone: [+971 XX XXX XXXX] Email: [email protected]
II. Rights of Users and Data Subjects
In accordance with the UAE Federal Decree-Law No. 45 of 2021 (PDPL), users and data subjects have the following rights:
- Right of Access: The right to obtain confirmation as to whether data concerning them is being processed, and to receive information about the processed data, including copies thereof (PDPL Art. 6).
- Right to Rectification: The right to request correction or completion of inaccurate or incomplete data (PDPL Art. 7).
- Right to Erasure: The right to request the immediate deletion of their data, where there is no longer a legitimate purpose for its retention (PDPL Art. 8).
- Right to Restriction of Processing: The right to request that processing be restricted under certain circumstances (PDPL Art. 9).
- Right to Data Portability: The right to receive their personal data in a structured, commonly used and machine-readable format and to transmit it to another controller (PDPL Art. 10).
- Right to Object: The right to object to the processing of their data, in particular where data is processed for direct marketing purposes (PDPL Art. 11).
- Right to Withdraw Consent: Where processing is based on consent, data subjects have the right to withdraw consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal (PDPL Art. 4).
To exercise any of the above rights, please contact us at: [email protected]
You also have the right to lodge a complaint with the UAE Data Office, the competent supervisory authority under the PDPL, if you believe that the processing of your personal data violates applicable data protection regulations.
UAE Data Office: https://www.uaedataoffice.ae
III. Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of data subjects, we are obligated under the PDPL to notify the UAE Data Office without undue delay. Where the breach is likely to result in a high risk, we will also notify the affected data subjects directly, in accordance with our obligations under UAE law.
IV. Information on Data Processing
Your data processed when using our website will be deleted or blocked as soon as the purpose of storage no longer applies, provided no statutory retention obligations prevent deletion, and unless otherwise specified below for individual processing activities.
Server Data
For technical reasons, in particular to ensure a secure and stable website, data is transmitted by your browser to us or to our web hosting provider. These so-called server log files record, among other things, the type and version of your browser, the operating system, the website from which you accessed our site (referrer URL), the pages of our website you visit, the date and time of each access, and the IP address of the internet connection from which our website is used.
This data is stored temporarily and not combined with other data about you.
This storage is carried out on the basis of our legitimate interest in improving, stabilising, and securing our website, in accordance with the PDPL. The data is deleted after seven days at the latest, unless further retention is required for evidentiary purposes.
Newsletter and Marketing Information
Upon registration for our language courses, customers consent to receiving information about our offers, courses and news by email (newsletter/marketing communications). The personal data collected during course registration (in particular name and email address) is stored and used for this purpose.
This processing is based on the consent of the data subject in accordance with the PDPL. Consent may be withdrawn at any time with effect for the future, for example by sending an informal notification by email to [email protected].
Cookies
a) Session Cookies
Our website uses cookies — small text files or similar storage technologies placed on your device by your browser. These cookies process certain information such as your browser data, location data or IP address to make our website more user-friendly, effective and secure (e.g. enabling multi-language display or shopping cart functionality).
Where cookies are used for the purpose of initiating or fulfilling a contract, processing is based on contractual necessity under the PDPL. Where processing serves other purposes, it is based on our legitimate interest in improving the functionality of our website.
Session cookies are deleted when you close your browser.
b) Third-Party Cookies
Our website may also use cookies from partner companies for advertising, analytics or functional purposes. Details, including the purposes and legal bases for such third-party cookies, are set out in the relevant sections below.
c) How to Manage Cookies
You can prevent or restrict the installation of cookies through your browser settings and delete stored cookies at any time. Please refer to your browser’s help documentation for instructions. Note that restricting cookies may limit the full functionality of our website.
Contract Processing
Data you provide to us for the use of our services is processed for the purpose of contract fulfilment and is required for that purpose. Conclusion and performance of the contract is not possible without the provision of your data.
Processing is based on contractual necessity under the PDPL. Data is deleted upon full completion of the contract, subject to applicable commercial and tax retention obligations under UAE law.
Where necessary for delivery or payment purposes, your data may be shared with logistics or financial service providers. Such sharing is based on contractual necessity under the PDPL.
Customer Account / Registration
If you create a customer account on our website, the data you provide during registration (e.g. name, address, email address) will be collected and stored exclusively for pre-contractual purposes, contract fulfilment or customer relationship management (e.g. to provide an overview of your previous orders).
Processing is based on your consent and/or contractual necessity under the PDPL. You may withdraw your consent to the creation and maintenance of your customer account at any time by notifying us at [email protected]. Data will be deleted once processing is no longer necessary, subject to applicable retention obligations.
Contact Requests / Contact Options
If you contact us via contact form or email, the data you provide will be used to process your enquiry. Providing your data is necessary to process and respond to your request — without it, we may not be able to respond fully.
Processing is based on contractual necessity (pre-contractual measures) under the PDPL. Your data will be deleted once your enquiry has been fully resolved, unless statutory retention obligations apply.
User Contributions, Comments and Reviews
We offer you the opportunity to publish questions, answers, opinions or reviews (“contributions”) on our website. If you use this service, we will process and publish your contribution, the date and time of submission, and any pseudonym you may have used.
Processing is based on your consent under the PDPL. You may withdraw your consent at any time with effect for the future by notifying us.
We also process your IP address and email address on the basis of our legitimate interest in legal defence, should your contribution infringe the rights of third parties or otherwise be unlawful.
Subscription to Contributions
If you publish contributions on our website, we offer you the option to subscribe to follow-up contributions by third parties. To notify you of such contributions by email, we process your email address based on your consent under the PDPL. You may withdraw this consent at any time by notifying us or by clicking the unsubscribe link in any such email.
Google Analytics
Our website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
Google Analytics is used to analyse user behaviour on our website. This processing is based on our legitimate interest in the analysis, optimisation and economic operation of our website, in accordance with the PDPL.
Usage data such as IP address, location, time and frequency of visits is transmitted to and stored on Google servers in the USA. We use Google Analytics with the IP anonymisation function, which truncates IP addresses before transfer. Google states that it does not combine your IP address with other data.
For more information, see Google’s privacy policy: https://policies.google.com/privacy
To opt out of Google Analytics tracking, you may install the browser add-on available at: https://tools.google.com/dlpage/gaoptout
Note on International Data Transfers: When data is transferred to Google servers in the USA, we rely on appropriate safeguards in accordance with the PDPL’s requirements for cross-border data transfers, including standard contractual clauses or equivalent mechanisms recognised by the UAE Data Office.
Google Maps
Our website uses Google Maps to display our location and provide directions. This is a service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
When you access the Google Maps component, Google stores a cookie on your device via your browser and processes your user settings and data to display our location and generate directions.
Processing is based on our legitimate interest in optimising the functionality of our website, in accordance with the PDPL.
For more information: https://policies.google.com/privacy https://www.google.com/intl/en/help/terms_maps.html
Facebook Social Plugin
Our website uses the social plugin of the social network Facebook, operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (for EU/EEA users) and Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA (hereinafter “Facebook/Meta”).
If you visit a page on our website that contains this plugin, your browser establishes a direct connection to Facebook’s servers. If you are logged in to Facebook at the time, the information collected by the plugin may be associated with your Facebook account.
Processing is based on our legitimate interest in improving the quality of our website, in accordance with the PDPL.
For more information, see Facebook’s Data Policy: https://www.facebook.com/policy.php
YouTube
Our website uses YouTube, a video platform operated by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, a subsidiary of Google LLC.
We use YouTube with the Enhanced Privacy Mode, meaning data is only transmitted to YouTube’s servers when you actively start a video. YouTube will record at minimum your IP address, the date and time of access, and the page visited.
Processing is based on our legitimate interest in improving the quality of our website, in accordance with the PDPL.
For more information: https://policies.google.com/privacy
Google Remarketing / “Similar Audiences”
Our website uses Google’s Remarketing or “Similar Audiences” feature (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to display interest-based, personalised advertisements on third-party websites that participate in Google’s advertising network.
During your visit, Google stores a cookie on your device containing a numeric sequence. This cookie records your visit and use of our website in anonymised form. No personal data is passed on.
Processing is based on our legitimate interest in the analysis, optimisation and economic operation of our website, in accordance with the PDPL.
You can permanently deactivate this feature in your Google account settings.
You may also opt out via: https://www.youronlinechoices.com/
Online Job Applications / Job Postings
We offer the opportunity to apply for positions via our website. The applicant data you submit will be collected and processed electronically for the purpose of handling the application process.
Processing is based on contractual necessity (pre-employment measures) and our legitimate interest under the PDPL, in accordance with applicable UAE labour law.
If an employment contract is concluded, your application data will be stored in your personnel file for standard organisational and administrative purposes, in compliance with UAE labour regulations.
If your application is rejected, your data will be automatically deleted two months after notification of rejection, unless a longer retention period is required for legal defence purposes, in which case data may be retained for up to four months or until the conclusion of any legal proceedings.
If you expressly consent to longer storage (e.g. for inclusion in a candidate database), your data will be further processed on the basis of your consent under the PDPL. You may withdraw this consent at any time by notifying us.
Cross-Border Data Transfers
Where personal data is transferred outside the UAE (e.g. to service providers in the USA or EU), we ensure that appropriate safeguards are in place in accordance with Chapter 8 of the UAE PDPL, including adequacy decisions, standard contractual clauses, or other mechanisms approved by the UAE Data Office.
Retention Periods
Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable UAE laws and regulations, including commercial and tax retention obligations.
Changes to This Privacy Policy
We reserve the right to update this Privacy Policy from time to time to reflect changes in legal requirements or our data processing practices. The current version will always be available on our website. We recommend that you review this policy regularly.
