3. Privacy Policy

This Privacy Policy applies to the processing of personal data by [Insert legal name, e.g., KEENLYS EDUCATION INC.], operating the website keenlys.com and offering online English tutoring services (“Keenlys”, “we”, “our”, “us”). keenlys.com+2keenlys.com+2

If you have questions, see the Contact Us section below.

This Policy applies when you:

• Visit or use our Site;
• Create an account;
• Purchase a subscription or lessons;
• Participate in online lessons via our built-in classroom;
• Interact with us (e.g., via contact forms, email, or support).

It does not apply to third-party websites or services linked from our Site.

Depending on how you interact with us, we may collect the following categories of personal data:

3.1 Information You Provide to Us

• Account details – name, email address, password, profile photo, time zone.
• Student information – learner name, age range, language goals, CEFR level, and related learning preferences. keenlys.com+1
• Parent/guardian details – if you register a child, we collect the parent/guardian’s name, contact details, and relationship to the child.
• Payment & billing – billing address and transaction-related information. (Payment card details are handled by our payment processor; we do not store full card numbers.)
• Lesson data – scheduling information, attendance records, homework submissions, in-lesson chat messages, and progress notes.
• Communications – messages you send us via email, contact forms, or support, including feedback and survey responses.

3.2 Information Collected Automatically

• Device and usage data – IP address, browser type, operating system, approximate location, referring URLs, pages viewed, and time spent on the Site.
• Log data – information about your interactions with the Platform, such as login times, feature usage, and errors.
• Cookies and similar technologies – small data files placed on your device for purposes such as authentication, preferences, analytics, and advertising. See our Cookies Policy for more details.

3.3 Information from Third Parties

• Payment providers (e.g., confirmation of payment or subscription status);
• Sign-in providers (e.g., “Sign in with Google”); keenlys.com+1
• Marketing or analytics partners who help us understand how users discover and use Keenlys.

1. To provide and operate the Services
   • Creating and managing accounts;
   • Delivering one-on-one lessons;
   • Tracking progress and CEFR-aligned learning milestones. keenlys.com+1
2. To process payments and manage subscriptions
   • Handling purchases, renewals, and billing-related communications.
3. To communicate with you
   • Responding to your questions and support requests;
   • Sending important notices about your account, schedule, or changes to our terms and policies.
4. To personalize and improve the Services
   • Tailoring lessons to your goals and level;
   • Analyzing usage to improve content, scheduling, and user experience.
5. To send marketing communications (where permitted)
   • Providing information about new features, promotions, and programs.
   • You can opt out at any time (see marketing section below).
6. To maintain security and prevent misuse
   • Detecting and preventing fraud, abuse, or technical issues;
   • Enforcing our Terms and policies.
7. To comply with legal obligations
   • Keeping appropriate records;
   • Responding to lawful requests from authorities, where required.

• Contract – to provide the Services you request and perform our obligations under our agreement with you (e.g., delivering lessons, processing payments).
• Legitimate interests – to operate, secure, and improve our Services, communicate with you about non-intrusive updates, and prevent fraud.
• Consent – for certain optional activities, such as some marketing communications and non-essential cookies.
• Legal obligation – to comply with applicable laws, including tax and accounting requirements.

1. Tutors – so they can provide personalized lessons (e.g., your name, age range, level, learning goals, and relevant progress data).
2. Service providers – companies that help us operate the Platform (e.g., hosting, video conferencing, analytics, payment processing, customer support, email delivery).
3. Business partners – where we jointly offer services or promotions (if applicable and with appropriate safeguards).
4. Authorities and legal advisors – where required by law or necessary to protect our rights, users, or the public.
5. In corporate transactions – such as a merger, acquisition, financing, or sale of assets, where personal data may be transferred as part of the business.

We do not sell your personal data in the conventional sense of “selling” consumer data for money. If applicable laws define “sale” more broadly (e.g., some U.S. state laws), we will comply with any additional notice or opt-out requirements.

Your personal data may be transferred to and processed in countries other than the one in which you are located. Those countries may have data protection laws that differ from those in your jurisdiction.

Where required by law, we implement appropriate safeguards (such as standard contractual clauses) to protect your personal data when it is transferred internationally.

We retain personal data only for as long as necessary for the purposes described in this Policy, including to:

• Provide the Services;
• Comply with legal obligations;
• Resolve disputes;
• Enforce our agreements.

Retention periods depend on the type of data and the reasons we collected it. We may anonymize data so that it can no longer be associated with you, in which case we may use it indefinitely without further notice.

We use technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

However, no method of transmission or storage is completely secure. You are responsible for safeguarding your account credentials and informing us promptly if you suspect any unauthorized access.

Keenlys provides lessons for children and young learners, but accounts for minors must be created and managed by a parent, guardian, or authorized adult. keenlys.com+1

Where required by law (for example, in the United States under COPPA or in the EU/UK), we obtain consent from a parent or legal guardian before collecting personal data from children.

If we learn that we have collected personal data from a child without appropriate consent, we will take steps to delete that information.

• Access – to know whether we process your personal data and, if so, obtain a copy.
• Rectification – to correct inaccurate or incomplete personal data.
• Erasure – to request deletion of your personal data in certain circumstances.
• Restriction – to request that we restrict processing of your personal data in certain cases.
• Portability – to request a copy of your personal data in a structured, commonly used, machine-readable format.
• Objection – to object to certain processing, including direct marketing or processing based on legitimate interests.
• Withdraw consent – where processing is based on consent, you may withdraw it at any time (this will not affect processing prior to withdrawal).

To exercise these rights, please contact us using the details in the Contact Us section. We may need to verify your identity before responding.

If you are in the EEA, UK, or other regions with data protection authorities, you may also lodge a complaint with your local supervisory authority.

If you opt in (or where permitted by law), we may send you marketing emails about Keenlys, new features, or promotions.

You can opt out at any time by:

• Clicking the “unsubscribe” link in any marketing email; or
• Contacting us via the details below.

Please note: we may still send service-related messages (e.g., billing, security, lesson reminders) even if you opt out of marketing.

We use cookies and similar technologies to operate the Site, enhance your experience, and understand usage, including analytics and, where enabled, advertising tools such as pixels. keenlys.com+1

For detailed information about how we use cookies and how you can manage your preferences, please see our Cookies Policy.

The Site may link to third-party websites or services that are not controlled by Keenlys. We are not responsible for their privacy practices or content. We encourage you to review their privacy policies.

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this page. If changes are material, we may provide additional notice (e.g., via email or in-app).

Your continued use of the Site or Services after the effective date of the updated Policy constitutes your acceptance of the changes.

If you have any questions or requests about this Privacy Policy or our data practices, please contact us:

Email: [Insert privacy contact email]
Address: [Insert registered address]

If you are in the EEA/UK and require the contact details of our representative or Data Protection Officer (if applicable), we will provide them upon request or in an updated version of this Policy.