PRIVACY POLICY

1. About this Privacy Policy

This Privacy Policy explains how [company name] collects, uses, stores, and protects personal data when individuals access or use lingnity.com (the “Platform”).
The Platform provides online language-learning products, including individual Lessons, Courses, Packs, Extras, and supporting educational materials.
This Privacy Policy applies when a person:
visits the Platform;
creates or uses an Account;
purchases a Learning Product;
accesses purchased Content;
contacts the Company;
requests support or a refund; or
otherwise uses the Platform and its Services.
The Platform is owned and operated by:
Company: [company name]
Company number: [company number]
Registered office: [registered address]
Website: lingnity.com
Email: hello@lingnity.com
For the purposes of the UK GDPR and the Data Protection Act 2018, the Company is the controller of the personal data described in this Privacy Policy.

2. Personal data we collect

The Company collects only the personal data reasonably required to operate the Platform, manage Accounts, process Purchases, and provide access to Learning Products.

2.1 Account and contact data

When a User creates or manages an Account, the Company may collect:
username;
email address;
password in protected or hashed form;
Account registration date;
Account status;
last login information; and
information provided when updating the Account.
The Company does not have access to the User’s original password where passwords are stored in hashed form.

2.2 Purchase and transaction data

When a User makes a Purchase, the Company may collect:
the Learning Product purchased;
order or transaction number;
purchase date and time;
purchase amount;
currency;
payment status;
promotional code information; and
refund or cancellation information.
The Company does not normally collect or store complete payment-card numbers, card security codes, or online-banking credentials.

2.3 Learning and access data

To provide access to purchased Learning Products, the Company may process limited information concerning:
Lessons, Courses, Packs, or Extras purchased;
Content available to the User;
achievements linked to completed Content; and
access granted, removed, restored, or corrected by an authorised administrator.
This information is used to display purchased Content, maintain progress, prevent duplicate Purchases, and restore access where necessary.

2.4 Communications

When a User contacts the Company, the Company may collect:
name or username;
email address;
Account details;
order details;
the contents of the communication;
attachments provided by the User; and
records of the Company’s response.
Users should not send unnecessary confidential information or special category data when contacting the Company.

2.5 Technical and security data

The Platform may automatically process limited technical information required for operation and security, including:
IP address;
browser type;
device type;
login date and time;
session information;
failed login attempts;
security events; and
technical error records.
This information is not used for behavioural advertising or marketing analytics.

3. How personal data is collected

The Company collects personal data:
directly from the User during registration;
when the User updates an Account;
when the User places an order;
when the User accesses Learning Products;
when the User contacts the Company;
automatically through essential website and security functions; and
from the payment provider when it confirms or rejects a transaction.
The payment provider may send the Company limited transaction information required to confirm payment, activate access, investigate payment issues, or process a refund.

4. How we use personal data

The Company uses personal data to:
create and manage Accounts;
authenticate Users;
process orders;
confirm payment status;
provide access to purchased Learning Products;
maintain purchase history;
record lesson and course completion;
manage promotional codes;
restore access following technical issues;
provide customer support;
respond to complaints and refund requests;
protect Accounts and the Platform;
prevent fraud, misuse, and unauthorised access; and
enforce the Terms of Use.
The Company does not use personal data for third-party advertising, profiling for advertising purposes, or unsolicited marketing under the processing activities described in this Privacy Policy.

5. Lawful bases for processing

The Company processes personal data only where a lawful basis applies.

5.1 Performance of a contract

The Company relies on performance of a contract where processing is necessary to:
create and operate the User’s Account;
process a Purchase;
provide access to a Learning Product;
maintain purchase and access records;
provide support relating to a Purchase;
process a valid cancellation or refund request; or
perform obligations under the Terms of Use.
Without the required Account and transaction data, the Company may be unable to create an Account, complete a Purchase, or provide access to purchased Content.

5.2 Legal obligation

The Company may process and retain personal data where necessary to comply with:
tax requirements;
accounting requirements;
consumer-protection law;
fraud-prevention obligations;
court orders;
regulatory requests; or
other applicable legal duties.

5.3 Legitimate interests

The Company may rely on legitimate interests where processing is necessary to:
protect the Platform and its Users;
prevent fraud and unauthorised access;
secure Accounts;
investigate technical problems;
maintain accurate business records;
enforce the Terms of Use;
manage disputes;
establish or defend legal claims; or
improve the reliability and security of essential Platform functions.
The Company considers the effect of this processing on Users and does not rely on legitimate interests where the User’s rights and interests override the Company’s interests.

5.4 Consent

The Company does not rely on consent to process data that is necessary to create an Account, complete a Purchase, or provide a Learning Product.
Where the Company introduces an optional activity that legally requires consent, the User will be asked to provide a separate and clear choice. Consent may be withdrawn at any time, without affecting processing completed before withdrawal.

6. Payments

Payments are processed through a third-party payment service provider.
The User submits payment-card or banking information directly to the payment provider through its secure payment interface. The payment provider processes this information under its own privacy terms and security procedures.
The Company normally receives only limited information, such as:
payment confirmation or refusal;
transaction reference;
amount paid;
currency;
payment date;
refund status; and
limited payer information where provided by the payment provider.
The Company does not normally receive or store complete payment-card details.
The payment provider may carry out identity, security, fraud, or payment-verification checks according to its own legal obligations and privacy policy.
The Platform should identify the payment provider at checkout or in the relevant payment notice.
Payment provider: [payment provider name]
Payment provider privacy policy: [link]

7. Sharing personal data

The Company does not sell personal data.
Personal data may be disclosed only where necessary to:
the payment provider, for payment processing and refunds;
banks, card issuers, or payment networks involved in a transaction;
courts, regulators, law-enforcement bodies, or public authorities where disclosure is required by law;
legal, accounting, or professional advisers where necessary to obtain advice or manage a dispute;
a purchaser, successor, or acquiring organisation in connection with a lawful sale, merger, restructuring, or transfer of the Platform; or
another party where the User has authorised the disclosure.
Where a service provider processes personal data on the Company’s behalf, the Company will require the provider to protect the data and use it only for authorised purposes.
The Company will not disclose personal data to unrelated third parties for their own advertising or marketing purposes.

8. International data transfers

The Company is established in England and Wales.
The payment provider or its supporting infrastructure may process personal data outside the United Kingdom.
Where personal data is transferred outside the United Kingdom, the Company will take reasonable steps to ensure that the transfer is permitted under applicable data-protection law.
Depending on the destination and circumstances, appropriate protection may include:
a UK adequacy regulation;
the UK International Data Transfer Agreement;
the UK Addendum to approved standard contractual clauses;
another legally recognised safeguard; or
a permitted statutory exception.
Further information about relevant transfer safeguards may be requested by contacting [privacy email].

9. Data retention

The Company retains personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.
The following retention principles apply:

9.1 Account data

Account information is normally retained while the Account remains active.
After an Account is closed, some information may be retained for a reasonable period to:
confirm the closure;
prevent fraud or repeated misuse;
resolve disputes;
protect legal rights; or
comply with legal obligations.

9.2 Purchase and transaction data

Purchase, payment-confirmation, refund, and accounting records are retained for the period required by applicable tax, accounting, consumer-protection, and record-keeping laws.

9.3 Learning and access data

Learning access, ownership, and completion data may be retained while the Account remains active and while the User continues to have access to purchased Learning Products.
This information may be deleted or anonymised after Account closure, unless continued retention is required for transaction records, disputes, security, or legal obligations.

9.4 Communications

Support requests and complaints are retained until the matter is resolved and for a reasonable period afterwards in case of follow-up questions, complaints, or legal claims.

9.5 Security data

Security and access records are retained only for as long as reasonably necessary to investigate incidents, prevent misuse, protect the Platform, and maintain system security.
When personal data is no longer required, the Company will delete, anonymise, or securely dispose of it, unless the law requires continued retention.

10. Account closure and deletion

A User may request Account closure by contacting hello@lingnity.com.
Closing an Account does not always require the immediate deletion of all personal data.
The Company may retain information where necessary to:
maintain transaction records;
prevent fraud;
resolve complaints;
enforce legal rights;
respond to regulatory requests; or
establish, exercise, or defend legal claims.
Where retained data is no longer needed for active Platform use, access will be restricted where appropriate.
Closing an Account may remove access to purchased Learning Products, as explained in the Terms of Use.

11. Children

The Platform is intended for individuals who are at least eighteen years old or who have reached the age required to enter into a binding contract in their country.
The Company does not knowingly create Accounts for children who cannot lawfully agree to the Terms without the involvement of a parent or legal guardian.
If the Company becomes aware that personal data has been collected from a child contrary to the Platform’s eligibility requirements, the Company may close the Account and delete the information, subject to applicable legal-retention duties.

12. Special category data

The Company does not require Users to provide special category personal data.
Special category data includes information concerning matters such as health, racial or ethnic origin, religious beliefs, political opinions, trade-union membership, genetic data, biometric identification, sex life, or sexual orientation.
Users should not submit such information through support forms, emails, Account fields, or payment communications unless the Company has specifically requested it for a lawful and necessary purpose.

13. User rights

Subject to applicable law and any relevant exemptions, Users have the right to:
receive information about how their personal data is used;
request access to their personal data;
request correction of inaccurate or incomplete data;
request deletion of personal data;
request restriction of processing;
object to processing based on legitimate interests;
receive certain data in a portable format;
withdraw consent where processing is based on consent; and
complain to a data-protection authority.
These rights do not apply in every situation. For example, the Company may need to retain transaction information to comply with accounting or legal requirements.
Requests should be submitted to [privacy email].
The Company may ask for information needed to verify the requester’s identity before responding.
The Company will normally respond within the period required by applicable data-protection law. Additional time may be required where a request is complex or involves several requests, where permitted by law.

14. Complaints

Users should contact the Company first if they have a concern about the use of personal data.
Contact email: hello@lingnity.com

15. Changes to this Privacy Policy

The Company may update this Privacy Policy where necessary to reflect:
changes to the Platform;
changes to data-processing activities;
changes to payment providers;
legal or regulatory developments;
security requirements; or
corrections and clarifications.
The current version will be published on the Platform with the updated date.
Where a change materially affects how personal data is used, the Company may provide additional notice by email, through the Account, or through a notice on the Platform.

16. Contact details

Questions, requests, or complaints concerning this Privacy Policy or personal data should be sent to:
Company: [company name]
Company number: [company number]
Registered office: [registered address]
Website: lingnity.com
Email: hello@lingnity.com