Privacy Policy

We are committed to protecting the privacy of our website users and other individuals who provide personal data to us. We therefore ask you to read our Privacy Policy before providing us with any information about you or any other person. This Privacy Policy (together with our website terms of use at and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the purposes of this Privacy Policy, "we" or "us" means Ltd of 5 Godalming Business Centre, Woolsack Way, Godalming, Surrey GU7 1XW, UK and "you" means the user of the website. We are the controller for the purpose of the Data Protection Act 2018.

By 'personal data' we mean identifiable information about you, such as your name, email address, geographical address, telephone number and IP address.

Personal Data we may collect

We may collect and process the following data about you:

  1. If you complete a form or navigate on our website at, we will collect and process the information you provide. This may include information that you have to provide to us in order to register to use our site including for a Getting Started account, subscribing to our paid for service, posting material, requesting additional services, or in the event that you report a problem with our site;
  2. If you contact us at any time, including through our social media accounts, we may receive personal data that you provide. Please note that we may keep a record of that correspondence and/or record any telephone call we have with you;
  3. We will retain details of any transactions you carry out through our site, including records relating to the fulfilment of any orders you place with us;
  4. We will also record details of your visits to our site and the resources that you access during those visits. This may include, but is not limited to, traffic and location data, web logs and any other communication data;
  5. From time to time we may also ask you to complete surveys that we use for research purposes. (Please note that you do not have to respond to our surveys if you do not wish to do so).
The Data Protection Act 2018 refers to certain 'special categories' of personal data; we do not collect any data in these special categories.

If you are being granted access to a subscription registered to another party (such as your employer or the educational establishment where you study), then we may receive personal data about you from that party, such as your name, role and email address in order for you to use the subscription. We may also share some or all of the site, activity, learning records and/or related learning materials with that party at our discretion.

For certain account types, we may from time to time grant access to some or all of the learning records and/or related learning materials to a teacher of English at our discretion. Where such access is granted, you must provide us with the teacher's name and email address and you agree that the teacher has consented to share such information with us. You agree that we may receive personal data about you from your teacher. We shall process the personal data of the teacher in accordance with this Privacy Policy.

IP addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate or traffic information to our advertisers.


Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site, and also allows us to make improvements to our site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy at

Storing your personal data

The data that we collect from you may be transferred and stored outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, for example in processing your payment details, fulfilling your order, providing services, and providing administration and support services. By submitting your personal data, you agree to this transfer, storing or processing taking place. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Please note that where you have a password which enables you to access certain parts of our site, you are solely responsible for keeping this password confidential and you must not disclose it to anyone.


We will do our best to protect your personal data, however the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of any data you transmit to our site and any transmission is at your own risk. You supply your data to us at your own risk. Once we have received it, we shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

How we will use your information

We will only use your personal data where we have a lawful basis to do so. The lawful purposes that we rely on under this Privacy Policy are:

  • consent (where you choose to provide it),
  • performance of our contract with you;
  • legal compliance; and
  • legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.
The information we hold about you will be used to:

  1. provide you with the information, products or services that you require from us in accordance with our contractual obligations to you;
  2. carry out our obligations arising from any other contracts we have entered into with you or under which you are receiving services from us;
  3. for our legitimate interests notify you about changes to our service and deal with any customer service enquiries;
  4. provide you with information, products or services that we feel may interest you, where you have consented to be contacted for such purposes;
  5. for our legitimate interests ensure that content from our site is presented in the most effective manner for you and your computer;
  6. allow you to participate in interactive features of our service, when you choose to do so in accordance with our contractual obligations to you;
  7. comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party's rights, property, or safety; and
  8. for our legitimate interests, as part of any audit or review we may carry out in relation to our business.
We shall also use the information we hold about you on an anonymous basis to:

  1. help us to develop and improve our services, for example in training automated scoring and evaluation systems, including using machine learning; and
  2. to prepare and publish analysis based on aggregated site user data.

Disclosing your information

For our legitimate interests, we may disclose your personal information to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006).

Again, for our legitimate interests, we may share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers, IT service providers, accountants, auditors and lawyers. We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.

In certain circumstances we may disclose your personal information to other third parties:

  1. If we are required to do so by the courts or to comply with other legal, statutory and/or regulatory obligations, including accounting and taxation requirements;
  2. Where it is necessary for the provision of information or services to you (for example to disclose information to your employer, teacher or student for the purposes of providing services to you);
  3. In order to enforce or apply our terms of use and any other agreements;
  4. In order to protect the rights, property, or safety of Ltd, our customers, or others. This may include sharing information with other organisations for the purposes of fraud protection or prevention and credit risk management;
  5. In the event that we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer;

Your rights

You have a number of rights under applicable law. You can also exercise your rights at any time by contacting us at the email address at

You have the right to obtain from us a copy of the personal data that we hold for you or request that we transfer your personal data to another service provider.

You can also require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date. Therefore, if the information you have provided us with changes, please let us know promptly, and we will correct, update or remove any information that we hold about you. We may however need to retain archive copies of that information for legal or audit purposes.

You also have the right at any time to require that we delete your personal data that we hold for you, but please note if you do this, we shall not longer be able to access your subscription or any Getting Started account. We may however need to retain archive copies of that information for legal, tax or accounting purposes.

At any time, you can withdraw your consent to receive our marketing emails.

Please note, we reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You can also contact the Information Commissioner, see or if you are based outside of the United Kingdom, please contact your local regulatory authority

Retention of personal data

We retain your personal data in accordance with applicable laws. The length of time we keep your personal data depends on what it is and whether we have an on-going business need to retain it (for example, to provide you with access to the service or to comply with applicable legal, tax or accounting requirements).

We shall retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an on-going business need to retain it, in accordance with our data retention policies and practices. Following that period, we shall make sure it is deleted or made anonymous within our systems.

Changes to our Privacy Policy

Any changes to our Privacy Policy will be posted on this page and, where appropriate, notified to you by e-mail.


Where a translation of this Privacy Policy is provided by us, the English version shall prevail in case of any discrepancy between the English version and the translated version.

Contact us

Should you have any questions or comments about our Privacy Policy please do not hesitate to contact us at the email address at

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