PolyglotWorks Language Academy (PolyglotWorks, IP)
Privacy Policy - Explicit Consent Policy
Effective: 2024
Contact: polyglotworks@polyglotworks.net

Introduction

PolyglotWorks Academy (PolyglotWorks, IP), a Kazakhstan-based institution, respects your privacy. This Policy explains what data we collect, why we collect it, how we use it, with whom we share it, how long we keep it, and your rights.

By submitting your personal data, creating an account, accessing the website or platform, or purchasing any service, you:

• explicitly and fully consent to all processing of your personal data described in this Policy and in all other PolyglotWorks agreements,
   

• acknowledge that PolyglotWorks may process all collected data for all educational, administrative, analytical, AI-based, marketing and operational purposes set out in this Policy,
   

• accept all PolyglotWorks policies in full, including the Terms of Use, Refund Policy, Digital Item Policy, Platform & User Content Policy, and Performance & Exam Disclaimer,
   

• acknowledge that PolyglotWorks provides no guarantee of learning progress, level improvement, or exam scores, and that all educational outcomes are your own responsibility.
   

All data processing is performed in accordance with the laws of the Republic of Kazakhstan and to the maximum scope permitted by Kazakh law.

PolyglotWorks is not responsible for user actions, disclosures, device security, or risks created by third-party platforms, networks or user behaviour. The responsibility for all personal information shared through the system lies entirely with the user.

 

Data we collect

We may collect:

• Identity data: first and last name
   

• Contact data: phone number (including WhatsApp), email address, postal address (if provided)
   

• Education data: English level, goals, preferences
   

• Interaction data: communication logs, attendance, homework, progress, trial lesson performance, testimonials, recordings where applicable
   

• Technical data: device identifiers, IP address, cookies, usage analytics
   

• Payment data: confirmations and invoice details (card data not stored)
   

By creating an account or sending data voluntarily, you consent to the processing of all these categories.

 

Purposes of processing and legal basis

Your data may be processed for the following purposes:

• contacting you, scheduling, enrollment, and delivering lessons
   

• providing educational services and maintaining student records
   

• marketing, advertising, retargeting, and lookalike audiences
   

• using testimonials and video/audio excerpts for promotion if provided with consent at registration or later
   

• sending newsletters, educational material, and updates
   

• fraud prevention, accounting, compliance, dispute management
   

• training and improving PolyglotWorks AI models, including analysis of interaction data, voice/text samples, and recordings
   

Legal basis:
For all processing activities, the primary legal basis is your explicit, informed, broad consent, given when you submit data, create an account, or purchase a service.

Where applicable, PolyglotWorks may also rely on legal obligations, legitimate interest, or contractual necessity, but your explicit consent is intended to cover all purposes described here to the maximum extent permitted by Kazakh law.

PolyglotWorks bears no liability for any educational performance, exam results, or outcomes.

 

Sharing within our group and third parties

Your data may be shared with:

• PolyglotWorks Academy (PolyglotWorks, IP) internal teams
   

• Payment processors, CRM systems, hosting providers, marketing and analytics services, advertising platforms (e.g., Meta, Google)
   

• Legal authorities where required under Kazakhstan law
   

Third parties must protect your data and may only use it for authorized purposes.

The user is fully responsible for any personal information voluntarily provided to tutors, third-party apps, or communication channels.

 

Use of student content

By accepting this Policy, you grant PolyglotWorks permission to:

• record lessons for training, quality control, and AI processing
   

• use anonymized progress data for reporting
   

• use testimonials and voluntary video/audio material for advertising if consent is given
   

You may withdraw future promotional use by emailing polyglotworks@polyglotworks.net.

 

Marketing communications

You consent to being contacted via:

• Email
   

• SMS/MMS
   

• WhatsApp
   

• Social media messages
   

• Phone calls
   

You may withdraw marketing consent at any time.

 

Retention

Data is retained as long as necessary for the stated purposes and in line with legal requirements. Default retention is up to 5 years after last activity unless law requires otherwise.

 

Security

We implement reasonable security measures; however, no internet-based system can be fully secure.
Users are solely responsible for protecting their devices, passwords, networks, and data they choose to share.

PolyglotWorks cannot be held liable for breaches caused by third parties, user error, device insecurity, or external factors beyond reasonable control.

 

Your rights

You may request access, correction, deletion, withdrawal of consent, or limitation of processing. Requests must be made by email.

 

Automated decision-making

PolyglotWorks does not perform legally binding profiling. Automated analytics may be used for recommendations; you may opt out on relevant platforms.

 

Updates

This Policy may be updated. The latest version will be published with its new effective date.

 

Applicable law

This Policy is governed by the laws of the Republic of Kazakhstan.