Last Updated: May 18th, 2018
Version 3.5
1. INTRODUCTION
Welcome to Open EnglishTM, and Open English JuniorTM a web-based service (“the Service” or “Website”) provided by Open Education LLC (“Open English” or the “Company”). We offer you the ability via our courses to learn English online through our online services and website functionality and offline through downloads that may be available via the website (collectively, the “Service”). We respect your privacy and want you to know what information about you we collect and what we do with that information. In order to help you understand how the information you provide Open English will be used, we have created the following Privacy Policy. This Privacy Policy applies to all information we collect or receive from you.
Please note that Open English may contain links to other websites and occasionally other websites may be co-branded with the Open English or an affiliate’s trade name. Websites that are linked to the Service or carry the Open English brand may have privacy policies which differ from that of Open English
2. HOW TO REACH US
If you have any questions regarding this Privacy Policy, or if you would like to contact Open English for any other reason, please call the number that appears on our website www.openenglish.com. If you are a student, please use any of the contact options in your learning platform’s “Contact Us” link.
3. INFORMATION WE COLLECT
3.1 Registration Information. You are not required to register or give us any personal information about yourself in order to visit the Website and or to view certain features made generally available on our Website. However, we may offer you the opportunity to register with us or to sign up for our mailing list. Although registration is not required to visit our Website, in order to access our premium features available on our Website, and in order to use certain other services that may be offered on our Website, you will be required to register and create an account with Open English (“Open English Account”). When you create your Open English Account, you will be required to provide certain personal information from you, including your first and last name, a user name (which will be your email address), the country in which you reside, your phone number and a password. At other times, you may also be asked to provide us with additional information, such as your age, gender, and other personal information about yourself in order to receive additional information about our services.
In addition, prior to using the Service, you may also be required to provide information of your credit card or other payment instrument and your billing address. If you authorize us to do so, we will retain your credit card information in our database to facilitate your checkout process for future transactions, all in accordance with regulations issued by credit cards networks.
As part of the process to create an Open English Account or to participate in certain promotions offered by Open English such as entering sweepstakes, contests, surveys, newsletters, etc., in addition to name, email and address, you may be asked to provide certain information which, by itself, does not personally identify you. For example, you may be asked to provide information concerning your education or preferences, purchasing habits, and the like. Open English may request this information in order to enhance your online experience by understanding you better and to also make you aware of new services, programs or offers in which you may be interested.
3.2 Automatic Collection of Data. You may be able to visit our Website and use certain of our services while remaining anonymous. However, whether you have registered with us or not, Open English may still collect certain non-personally identifiable information about your use of our services. For example, Open English might collect information concerning the type of Internet browser you are using, the type of computer operating system you are using, your IP address, your connection speed, the domain name of your Internet service provider, the geographic location from which you are accessing our service and/or the Website or advertisement from which you linked to the Website. When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. Once you have registered with us, we also track and collect information about you, including your transactions with us, our affiliates, or others, and your site usage patterns, such as the pages on the Website you have visited, searches you have conducted and the amount of time you have spent on our Website. If you contact us, we may keep a record of your correspondence.
3.3 Cookies. When you visit our Website or click through hyperlinks appearing thereon, or use one or more of our services, we may use an industry-wide technology called “cookies” which stores certain information on your computer and which will allow us to customize your experience to better match your interests and preferences or simply facilitate your signing-in to use the services. Most browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. Please note, however, that if you set your browser to block acceptance of cookies, you may not be able to use the Service or enter our Website or it may otherwise adversely impact the functionality of the site. By allowing your browser settings to accept cookies from this Website or Service, you consent to our placement of cookies on your personal computer and/or technology device. However, Users of our Website and Service can set their browsers to accept or reject all, or certain, cookies. Please note that if you set your browser to disable cookies or other technologies, you may not be able to access certain parts of our Website or Service and other parts of our Service may not work properly. For more information about cookies, click this link: www.aboutcookies.org.
3.4 Testimonials. Open English may post customers’ testimonials on our websites, platforms and social media (“Website”) as well as advertising on television (“TV”), which may contain personal information from our customers. Once you accept the Terms of Service applicable to the Service, you give your consent to Open English to publish on our Website and TV any testimonial, post, comments, name and any other representations that you may send us via the applicable communication channels.
3.5 IInformation We Receive From Our Affiliates. You may also separately provide information about yourself to third party or co-branded sites through which we provide access to our service (“Affiliate Sites”). When you register with us, the Affiliate Site that you came from may provide us with your user/member name and password from such site. Some of those Affiliate Sites or other sites may share other information that you provide to them with us. By using our services, you agree to allow us to receive and use any information, except for credit card information that you may provide to such Affiliate Sites or other sites, under the same terms as if you provided it to us directly. Whether or not that Affiliate Site or other site actually shares your information and to what extent they do share with us will depend on their agreement with us and their individual privacy policy.
4. WHAT WE DO WITH YOUR INFORMATION
4.1 In general, Open English may use information about you to provide and improve its Service. Open English may share this information with the suppliers of content on the service, affiliates and other entities in non-personal form to show general demographic and preference information among users of the Service or for other purposes. This information may include usage and demographic data, but it will not include personal information (such as your email address).
4.2 As part of the Service, Open English may provide you feedback regarding your progress in the form of video messages hosted on third party websites, which messages can be viewed by other users of such third party websites. Although these video messages will not identify you by name or photograph, if you do not wish to receive such feedback, you will have the ability to opt-out of receiving and having such messages hosted on the third party websites.
4.3 If you provide Open English with personally identifiable information, we will take reasonable and appropriate steps to protect this information. Except as otherwise described in this Privacy Policy, Open English will not disclose, share, sell or rent personally identifiable information collected on our Website to third-party organizations for their marketing or promotional use without your consent or except as part of a specific program or feature for which you will have the ability to opt-out. If you ask to receive information from our affiliates by selecting this option in the future, we may share your registration information and information regarding your transactions on our Service with the studios and/or our affiliates. If you access our Service using a co-branded version of our Website that contains messaging that information will be shared with that affiliate whose company name is displayed on the co-branded site, any personal or non-personal information collected may be shared with that affiliate. Any use of such information by Open English will be subject to this Privacy Policy and any use of such information by the affiliate will be subject to this Privacy Policy and the affiliate’s privacy policy. If we sell or otherwise transfer part or the whole of Open English business and/or our assets to another organization like in a course of a merger and acquisition transaction, or in the case of a bankruptcy, dissolution or liquidation, your information such as name and email address and any other information collected through our Website or Service may be among the items sold or transferred. The resulting buyer, surviving company or transferee will honor the commitments we have made in this Privacy Policy. We do not share your credit card account information with Affiliate Sites or any other third parties, other than order processing and credit card clearance service providers as described below.
4.4 In order to keep you informed about our services, we may send e-mails and announcements that are needed for the administration of our Website and Service. We also may provide our users with the option of joining our mailing list to receive additional information about our Website, services and offers, including the services and offers of Open Education LLC or its affiliates. Additionally, we may, from time-to-time, allow you to choose whether you would like to receive mailings from third parties with whom we have affiliate relationships. You will always have the ability to change your options by accessing your Open English Account. Each marketing e-mail from Open English will include instructions for how to unsubscribe from our mailing list.
4.5 We work with third parties who provide services, which may include website hosting, promotion fulfillment, order processing, credit card clearance, data analysis and other services of an administrative nature. Personal information, including financial information, may be shared with such third parties for the purpose of providing such services to you. We seek to impose confidentiality obligations on such service providers. Also, Open Education LLC, which owns Open English, will be able to use your personal information under the terms of this Privacy Policy. We also reserve the right to disclose personal information to third parties when we believe in good faith that the law requires it, to enforce our Terms of Service, to protect the rights, property, safety, or security of Open English or the public, to respond to an emergency, or as otherwise stated in this Privacy Policy.
4.6 Following termination or deactivation of your account, Open English, its Affiliates, or its Service Providers may retain information associated with your profile information for a commercially reasonable time for backup, archival, and/or audit purposes.
5. SECURITY
5.1 We use reasonable security methods to protect the data that resides on our servers. However, because no security system is impenetrable, we cannot guarantee the security of our servers. It is also possible that information you supply to us will be intercepted during transmission.
5.2 Whenever you give Open English sensitive information (e.g., credit card numbers), Open English will take commercially reasonable steps to protect such information by establishing a secure connection with your Web browser. Open English employs an industry standard technology known as a secure-socket-layer (“SSL”) to protect the transmission of payment information to the Website. You can check the security of your connection by looking at the address in your browser window. After you have accessed a secure server protected by SSL, the first characters of the address will change from “http” to “https.”
5.3 Please do your part to help us. To help protect your Open English Account information, please keep your password secure. Your password will be maintained on our system in encrypted form because Open English understands that privacy is important to you. Open English will generate a link to create a new password in case you forget it and send it to the email account you provided. This will not affect your settings in any way. We suggest that you pick a non-obvious password that mixes numbers and letters. In addition, we recommend that you do not divulge your password to anyone. Ultimately, you are responsible for maintaining the secrecy of your passwords and any Open English Account information.
5.4 Remember to sign out of your Open English Account, and close your browser window whenever you leave your computer. This is to ensure that others cannot access your personal information, because your computer may be accessible to others or used in a shared setting.
5.5 Open English’s Privacy Policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond Open English’s control, and is not to be applied in any manner contrary to applicable law or governmental regulation.
6. CHAT WITH OUR TEACHERS
During the term of the Course, adults and children will have the opportunity to interact with academic advisors (the “Teachers”) during the online live classes (no image, only voice) available in the Course participating in session, games and activities through a virtual classroom and a chat system. We may employ live moderation and/or encourage users to flag inappropriate communications. We strongly encourage children who use these interactive features on our sites and applications never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent the filters or moderation we may have in place. We also recommend that you as a parent or legal guardian carefully supervise your children while his/her participation in online activities associated with the Course.
7. CHILDREN
7.1 EConsistent with the federal Children’s Online Privacy Protection Act of 1998 (COPPA) as amended from time to time, we will never knowingly request personally identifiable information from anyone under the age of thirteen (13) without requiring parental consent. Any person who provides their personal information to us through the Service represents that they are 13 years of age or older. Open English does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service.
7.2 The Course activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. However, in connection with certain activities or services of the Course, we may collect a child’s online contact information, such as an email address, in order to communicate with the child more than once. On some occasions a child may be engaged in more than one ongoing communication, and a parent may be required to “opt-out” of each communication individually.
7.3 In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.
7.4 For more information please review our Privacy Policy that explains our information collection, disclosure, and practices with respect to information we collect. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding children’s personal information.
8. COPPA
8.1 Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at [We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
8.2 At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account or service administered by the Company, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, license of use, or other service administered by the Company.
8.3 In any correspondence to the Company such as e-mail or mail, please include the child’s username and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.
9. THIRD-PARTY ADVERTISERS
9.1 Open English may allow other companies, called third-party ad servers or ad networks, to serve advertisements within the Service. These third-party ad servers or ad networks use technology to send, directly to your browser, the advertisements and links that appear on the Service. They automatically receive your IP Address when this happens. They may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize their advertising content.
9.2 Open English does not provide any personally identifiable information to these third-party ad servers or ad networks without your consent or except as part of a specific program or feature for which you will have the ability to opt-in. However, please note that if an advertiser asks Open English to show an advertisement to a certain audience or audience segment and you respond to that advertisement, the advertiser or ad-server may conclude that you fit the description of the audience they were trying to reach.
9.3 You should consult the respective privacy policies of these third-party ad servers or ad networks. Open English’s Privacy Policy does not apply to, and we cannot control the activities of, such advertisers or other websites.
10. LINKS TO OTHER SITES
10.1 Linking to other sites is an integral part of the functionality of the Internet, including our Website. Any link to a page which displays a URL other than a domain name that ends in Open English.com in the address window of your browser is a link to a site outside of our service and thus outside the control of Open English. This includes links to our suppliers of content on the service, affiliates, and links to any other third parties that may be linked to Open English. These other sites may send their own cookies to you, collect data or solicit personal information. Open English cannot guarantee and is not responsible for the content of outside sites.
10.2 Please keep in mind that whenever you give out personal information on other sites (for example via message boards or chat), that information can be collected and used by people you don’t know. While Open English strives to protect our visitors’ personal information and privacy, we cannot guarantee the security and privacy of any information you disclose at other sites, and you do so at your own risk. Please learn about the privacy and security practices and policies of external websites before providing them with personal information.
11. SPECIAL NOTE TO INTERNATIONAL USERS
The Service is hosted in the United States and is aimed primarily at users domiciled in the Americas. If you are accessing the Service from the European Union (EU), Asia, or any other region with laws governing personal data collection, which use, and disclosure may differ from United States laws, please note that you are transferring your personal data to the United States which does not have the same data protection laws as the EU and other regions, and by providing your personal data you expressly consent to:
Special Note for EU users
This section applies if you are in the EU, and regardless of our disclaimers, you decide to provide us with your personal information. In accordance with the applicable EU General Data Protection Regulation (hereinafter “EU privacy law”), you have the following rights in respect of your personal information that we may hold:
Regardless of your location, any questions, comments and requests regarding our Privacy Policy is welcome and should be addressed through our Customer Service team by calling the phone number that may apply to you.
12. HOW TO REVIEW, UPDATE OR DELETE YOUR REGISTRATION INFORMATION
12.1 As part of your use of our Service, you are responsible for updating your submitted registration information so that it is both current and complete. In order to update your registration information, please contact an advisor by calling the number that appears on our website, or from your learning platform, choose the Contact Us link.
12.2 Please note that by using our Website, you signify your agreement to this Privacy Policy, as it may be amended from time to time. If you do not agree to this Privacy Policy, please do not use our Website or the services provided thereon. We reserve the right to make changes to this Privacy Policy. We will provide notice to you of any material changes by any reasonable means including sending an email to the most recently updated address in your Open English Account and/or posting such notice and the amended policy on the Open English Website. Your continued use of our Website following changes to this Privacy Policy will mean that you accept and agree to the changes and that any information collected or provided after such change will be governed by the updated Privacy Policy.
12.3 Open English is dedicated to protecting your personal information and welcomes comments and questions on this Privacy Policy. You may reach out to our team by calling the number on our website. If you are a student, choose from the contact options displayed in the “Contact Us” link in your learning platform.
13. INVITATIONS – REFER A FRIEND
If you decide to refer a friend to our site, contests or promotions, we ask you for the friend’s name, email address and country. Open English will then send an automatically generated email message inviting your friend to visit our site and/or experience our contests or promotions. Your friend will be subject to this Privacy Policies and the terms of service of Open English.