1. Who we are and what this policy covers.Speak Ukrainian Ltd, trading as Speak Ukrainian (“we”, “us”, or “our”), is the data controller responsible for the personal information described in this policy.Company number: 17051860Place of registration: England, UK.Email: moc.aukaeps%40ofniWebsite: https://www.speakua.com
This policy explains how we collect, use, share, retain, and protect personal information when you visit our website, use our mobile application or learning platforms, book lessons, join courses or learning communities, buy learning materials, subscribe to communications, or contact us. It also explains your privacy rights.
We process personal information in accordance with applicable data protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018, as amended. Additional protections may apply under the laws of other countries where we offer services. This policy provides information about our processing. It does not replace any separate consent we must obtain for particular activities.
2 Personal information we collect.The information we collect depends on how you use our services. We collect only information relevant to the purposes described in this policy. Identity and contact information: your name, email address, telephone number if provided, country, time zone, and parent or guardian contact details where relevant.
Account and learning information: account identifiers and authentication information, language level, learning goals and preferences, bookings, attendance, assignments, assessments, teacher feedback, and course progress.Purchase and delivery information: products or services ordered, billing details, payment status, transaction references, refunds, and delivery addresses for physical products. Payments are handled by Revolut and PayPal.
Communications: enquiries, support messages, feedback, and messages you submit through our learning or community services. Technical information: IP address, browser and device type, operating system, language settings, access logs, and information about use of our website and app. Cookies and similar technologies are explained in section 5.Preferences: your marketing choices, cookie choices, and records of consent or objections.Lesson recordings and transcripts: recordings of relevant sessions and transcripts generated through the features we use, as explained in section 4.
We obtain information directly from you, automatically through your use of our services, and where relevant from parents or guardians, teachers, payment providers, and learning platforms.Where information is necessary to fulfil a booking, deliver an order, or create an account, we indicate this when collecting it. Without that information, we may be unable to provide the requested service. Optional information is identified separately.
3. How and why we use personal information.We use different lawful bases for different activities. These bases do not mean that all uses of your information are mandatory.Providing purchased services: we use the information necessary to manage your account, bookings, payments, lessons, course access, learning feedback, and orders to perform our contract with you or take steps you request before entering a contract. This includes essential service messages and support relating to your purchase.
Answering other enquiries and administering our services: where this is not necessary for a contract, we rely on our legitimate interests in responding to requests and running our school effectively, provided these interests are not overridden by your rights and interests.
Security and service improvement: we rely on legitimate interests to protect accounts, prevent misuse, troubleshoot problems, and improve teaching and service quality where proportionate. We assess the necessity and impact of this processing. Separate consent requirements for device tracking still apply.
Legal obligations: we retain and use information where necessary to comply with applicable tax, accounting, and other legal obligations. Where necessary, we also process information for our legitimate interests in establishing, exercising, or defending legal claims.
Marketing: we rely on consent for subscription-based promotional communications. Where the applicable electronic marketing rules permit the products and services soft opt-in, we may rely on legitimate interests to promote our own similar products and services, subject to your right to opt out. See section 6.
Cookies and advertising: we obtain consent for advertising tracking and other technologies requiring consent. Where a statutory exception applies, we comply with its conditions and identify the relevant processing and controls in our Cookie Notice.Children’s services: the purposes and lawful bases for processing information through SpeakUA Kids are explained in its separate Privacy Policy, linked in section 12.
If we want to use information for a materially different purpose, we will explain the new use and the relevant lawful basis before doing so, and obtain consent where required.
4. Online lesson recordings and communities.Our live lessons take place through Zoom and Google Meet. We record speaking clubs, group lessons, and speaking sessions to help students review learning or catch up. We use Grain to record trial lessons. Recordings may include participants’ names, images, voices, shared screens, and chat messages.
Course and group recordings. Recordings stored on Google Drive are retained for two years from the session date. Student access is limited to the relevant course, club, or session. Authorised teachers and administrators may access recordings where needed for their work. Student downloads are not permitted.
Trial-lesson recordings through Grain. We record trial lessons for teaching feedback and quality review. These recordings are stored in Google Drive. Transcription and automated notes. We use Zoom’s transcription feature to convert spoken lesson content into text.
Consent and participation. We obtain participants’ consent before recording and sharing their identifiable contributions. Students who decline can participate with recording paused during their contributions. Consent may be withdrawn by contacting .moc.aukaeps%40ofni
We obtain separate consent for promotional use of identifiable student images, voices, or testimonials.In group lessons and communities, other participants may see your name and messages. In WhatsApp groups, your phone number and profile details may also be visible. Please respect other participants’ privacy.
5. Cookies and similar technologies.Our website and app may use cookies, pixels, local storage, and similar technologies. Some are essential to provide functions you request, such as signing in or maintaining a shopping basket. Others support optional analytics, preferences, or advertising.
We request consent before using technologies that require it. You can reject optional technologies and withdraw consent through actual cookie settings. Refusing optional tracking does not prevent access to the core services, although some optional features may be unavailable.
Where we rely on a permitted statistical or preference-related exception, we provide the required information and a simple, free way to object. We do not treat advertising tracking as essential or assume that all analytics qualify for an exception.
Our Cookie Notice at https://www.speakua.com identifies the technologies and providers used, their purposes and duration, and how to change your choices. Browser settings offer additional controls, although blocking essential technologies may affect functionality.
6. Marketing communications.We may send newsletters, learning content, offers, and product updates where you have opted in or where another lawful marketing permission applies.
For the products and services soft opt-in, we only use contact details obtained directly during a sale or negotiations for a sale, promote our own similar products or services, and offer a clear opt-out both when collecting your details and in each marketing message. We apply any additional requirements of the laws relevant to the recipient.
You can stop promotional communications at any time using the unsubscribe link or by emailing .moc.aukaeps%40ofni We retain the minimum information needed to respect your opt-out. You have the right to object to use of your personal information for direct marketing at any time, including related profiling.
We may still send necessary service communications, such as booking confirmations, lesson changes, payment information, and security notices. These do not depend on your agreement to receive marketing.
7. Who receives personal information.We do not sell your personal information.
We share relevant information with people and organisations that help deliver our services, including authorised teachers and support staff; website, app, and course-hosting providers; video-conferencing and booking providers; payment processors; email and customer-support platforms; and delivery providers for physical products. Accounting, legal, analytics, advertising, and AI providers receive information only where relevant to the activities described in this policy and subject to applicable permissions.
Providers processing information on our behalf must act under appropriate contractual instructions and safeguards. Some organisations, including certain payment providers, may act as independent controllers for their own processing; their privacy notices explain those activities.
We may disclose information where required by law or where necessary and lawful to prevent fraud, protect legal rights, or respond to legitimate requests from authorities. Student-to-student visibility in learning activities is described in section 4.
8. International transfers.Our teachers and administrative team work in the United Kingdom, Ukraine, and other European countries. Authorised team members may access the student information needed to deliver lessons and administer our services from these locations.We also use Google Drive, Google Meet, and Zoom. These services may process personal information outside the UK.
9. How long we keep information.We retain information only for as long as necessary for the relevant purpose, including applicable legal requirements. Our retention arrangements are:- Course and group recordings on Google Drive: two years from the session date, as described in section 4.- Trial-lesson recordings in Grain.- Saved transcripts and automated summaries, if generated.- Account and learning records.- Purchase and accounting records.- Support correspondence.- Marketing contact records.- Consent and opt-out records.- Technical logs and backups.We may retain relevant information longer where necessary for a legal obligation or unresolved claim. When information is no longer required, we securely delete or anonymise it.
10. How we protect information.We use appropriate technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, or loss. Access is limited to people who need the information for their work and who are subject to appropriate confidentiality obligations.
No electronic system is completely secure. If a personal data breach occurs, we assess it and notify the relevant regulator and affected individuals where required by law. Please contact us promptly if you suspect misuse of your account or personal information.
11. Your privacy rights.Subject to the applicable law and circumstances, you may ask us to provide access to your personal information, correct inaccurate information, delete information, restrict processing, or provide a portable copy of certain information. You may object to processing based on legitimate interests. We will assess the objection and stop the processing unless a lawful reason permits it to continue. Your right to object to direct marketing is absolute.
Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. We explain any effect on an optional service when you withdraw. To exercise your rights, email .moc.aukaeps%40ofni We may request proportionate information to confirm your identity. We normally respond within one month; where the law permits additional time, we explain the reason and expected timescale. Requests are normally free, subject to legally permitted exceptions.
Some rights are limited in particular circumstances. For example, we may need to retain certain accounting records despite a deletion request. If we cannot fully comply, we explain why and how you can challenge the decision.You may raise a privacy concern with us using the same email address. You also have the right to complain to the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/ without first obtaining our permission. Depending on your location and applicable law, you may also complain to your local data protection authority.
12. Children’s services.Our dedicated children’s lessons are provided through SpeakUA Kids. Information about how we collect and use children’s and parents’ personal information for these services is available in the SpeakUA Kids Privacy Policy: https://speakuakids.com/privacy-policy
13. Changes to this policy.We may update this policy to reflect changes in our services, practices, or legal obligations. The latest version will appear on our website with an updated date. We provide appropriate notice of material changes and explain new purposes before using information for them. Where consent is required, we obtain it separately.
14. Contact us.For privacy questions, concerns, or requests, contact Speak Ukrainian Ltd at moc.aukaeps%40ofniWebsite: https://www.speakua.com