Privacy Policy

ARTICLE 1: PREAMBLE

This privacy policy aims to inform users of the website: https://polytongue-academy.com (including the web application at https://hall.polytongue-academy.com)

• On how their personal data is collected. 
• On the rights they have regarding this data;
• On the recipients of this personal data;
• On the website’s cookie policy.

ARTICLE 2: PRINCIPLES RELATING TO THE COLLECTION AND PROCESSING OF PERSONAL DATA

In accordance with Article 5 of European Regulation 2016/679, personal data is:

• Processed lawfully, fairly, and transparently with regard to the data subject;
• Collected for specific purposes (see Article 3.1 herein), explicit and legitimate, and not processed subsequently in a manner incompatible with these purposes;
• Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date. All reasonable measures must be taken to ensure that personal data which are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

Processing shall be lawful only if, and to the extent that, at least one of the following applies:

• The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which the controller is subject;
• Processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED IN THE CONTEXT OF BROWSING ON THE SITE

Article 3.1: Data collected

The personal data collected in the course of our activity are: first name, last name, and email address. Additionally, for users who choose to link their Google account for authentication (students only) or for calendar synchronization (teachers only), we collect Google User Data: students’ name, email, and profile photo, and teachers’ calendar event details (time slots) necessary to provide the scheduling service.

Article 3.2: Data Retention and Deletion Disclosures

We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law. We store your personal information for a period of time that is consistent with our business purposes. Specifically, general account data is retained for as long as your account remains active to provide the service.

Users may request for their data to be deleted at any time through their dashboard by navigating to the account settings and confirming their intent by typing “DELETE” in the confirmation prompt. In such case, the associated Google User Data will be deleted automatically and immediately from our active systems. If a request is made by contacting us directly at data@polytongue-academy.com, we will delete or destroy the associated Google User Data within 15 days. When the data retention period expires for a given type of data, we will delete or destroy it.

Article 3.3: Data Sharing, Transfer, and Disclosure

We do not transfer or disclose your information to third parties for purposes other than the ones provided in this policy. Polytongue Academy does not share, transfer, or disclose Google User Data to third parties, except as strictly necessary to provide the platform’s core services. This includes sharing only in some cases the student’s first name and email address with their designated teachers solely to facilitate communication and the delivery of educational services; we do not share last names, Google Calendar information, or any other personal data between students and teachers. Teachers are contractually obligated to use this information only for educational purposes and to delete such data upon completion of the service or upon a formal deletion request. We do not sell Google User Data. We do not use Google User Data for advertising purposes or to build profiles for ad targeting. Our use and transfer of information received from Google APIs to any other app will adhere to the  Google API Services User Data Policy, including the Limited Use requirements

Article 3.4: Data Protection Mechanisms for Sensitive Data

Security procedures are in place to protect the confidentiality of your personal and Google User Data. We implement technical and organizational measures designed to prevent unauthorized access, loss, or disclosure of information processed by Polytongue Academy. We use industry-standard HTTPS (TLS) for all data transfers between Polytongue Academy and Google APIs, ensuring that your data is encrypted during transit. Access to our internal systems and user data is restricted to authorized personnel only, utilizing strict access controls and operational security protocols to maintain the integrity of your information. Where applicable, credentials and tokens are stored securely to prevent unauthorized use.

Article 3.5: Data hosting

The Polytongue Academy site is hosted by: Hostinger International Ltd. Address: 61 Lordou Vironos Street, 6023 Larnaca, Cyprus. Contact: https://www.hostinger.com/contact

Article 3.6: Cookie Policy

At Polytongue Academy, we respect your privacy and are committed to protecting your personal data. This privacy policy explains how we use the information we collect about you, including the use of cookies.

Personal data we collect:

• Name
• First name
• Email address

This data is collected for the purpose of improving the functionality of our website, providing the requested service, and sending newsletters only if the user agrees.

Use of cookies:

We use strictly necessary cookies for the proper functioning of the website. These cookies are essential for navigating the site and using its features. It is not necessary to obtain your consent for these cookies, but it is important for you to know that they are present and why they are necessary.

Consent for non-essential cookies:

For any other cookie that is not strictly necessary, we will ask for your consent before using them. We will provide you with accurate and specific information about the data that each cookie tracks and its purpose in clear language before receiving your consent.

Your rights:

In accordance with the amended Data Protection Act of January 6, 1978, and the GDPR, you have the right to access, rectify, object, delete, and limit information from cookies and other trackers. For this, please contact data@polytongue-academy.com.

You have the right to access, correct, or delete your personal data at any time. You can also withdraw your consent to the use of cookies that are not strictly necessary.

Contact:

If you have any questions about our privacy policy or the use of cookies, feel free to contact us via data@polytongue-academy.com.

ARTICLE 4: DATA CONTROLLER AND DATA PROTECTION OFFICER

Article 4.1: The data controller

Personal data is collected by Polytongue Academy SAS, with a capital of $500,000, whose registration number is 901443618.

The data controller can be contacted as follows:

By mail to the address: 3 Germay Drive, Wilmington, United States;

By phone, at +33756826226;

By email: contact@polytongue-academy.com

Article 4.2: The data protection officer

The data protection officer of the company or the data controller is:

[Javier Latorre, 3 Germay Drive, Wilmington, United States, data@polytongue-academy.com]

If you believe, after contacting us, that your “Computer and Freedoms” rights are not respected, you can inform the CNIL.

ARTICLE 5: USER RIGHTS REGARDING DATA COLLECTION AND PROCESSING

Any user concerned by the processing of their personal data may exercise the following rights, in accordance with European Regulation 2016/679 and the Data Protection Act (Law 78-17 of January 6, 1978):

• Right of access, rectification and right to erasure of data (laid down respectively in Articles 15, 16 and 17 of the RGPD) ;
• Right to data portability (article 20 of the RGPD);
• Right to limitation (Article 18 of the GDPR) and opposition to data processing (Article 21 of the GDPR);
• Right not to be subject to a decision based exclusively on an automated process;
• Right to determine the fate of data after death;
• Right to have recourse to the competent supervisory authority (Article 77 of the RGPD).

To exercise your rights, please write to Polytongue Academy, send an e-mail to data@polytongue-academy.com the address of Data Protection Officer.

In order for the data controller to process your request, you may be required to provide certain information, such as your full name, e-mail address and account, personal space or subscriber number. 

Consult the cnil.fr website for more information on your rights.

ARTICLE 6: CONDITIONS FOR MODIFYING THE PRIVACY POLICY

The publisher of the [Polytongue Academy] site reserves the right to modify the present Policy at any time in order to ensure that users of the site comply with current legislation. 

Any modifications shall not affect purchases previously made on the site, which shall remain subject to the Policy in force at the time of purchase and as accepted by the user at the time of purchase validation. 

The user is invited to familiarize himself/herself with this Policy each time he/she uses our services, without the need for formal notification. 

This policy, published on [15/01/2022], was updated on [20/12/2025].