This privacy notice for Energetic English Ltd. (doing business as Energetic English) (“Company,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:

Visit our website at www.energeticenglish.com, or any website of ours that links to this privacy notice.

Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns?

Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services.

If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Energetic English Ltd. and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information?

We do not process sensitive personal information.

Do you receive any information from third parties?

We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

How do you process my information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information?

We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe?

We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do I exercise my rights?

The easiest way to exercise your rights is by contacting us at [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

9. HOW LONG DO WE KEEP YOUR INFORMATION?

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

11. DO WE COLLECT INFORMATION FROM MINORS?

12. WHAT ARE YOUR PRIVACY RIGHTS?

13. CONTROLS FOR DO-NOT-TRACK FEATURES

14. DO WE MAKE UPDATES TO THIS NOTICE?

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect includes:

- Basic contact info (e.g., name, email, phone number).

- Payment information (processed via third-party providers; we do not store credit card details).

- Session recordings, notes, or progress reports from coaching sessions.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

- To facilitate account creation and authentication and otherwise manage user accounts.

- To deliver and facilitate delivery of services to the user (e.g., scheduling sessions, providing access to materials).

- To respond to user inquiries/offer support to users.

- To send administrative information to you.

- To fulfill and manage your orders or payments.

- To request feedback and to contact you about your use of our Services.

- To protect our Services (e.g., fraud monitoring).

- To comply with our legal obligations.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

Under the UK General Data Protection Regulation (UK GDPR) and the EU GDPR, the legal bases we rely on include:

Consent: Where you have given us consent.

Performance of a contract: To fulfill our contract with you.

Legitimate interests: For our legitimate business interests, provided they do not override your rights.

Legal obligations: To comply with the law.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include:

- Payment processors (e.g., Stripe, PayPal).

- Video platforms (e.g., Zoom).

- Scheduling and other tools (e.g., Calendly).

- We may also share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

The Services may link to third-party websites, online services, or mobile applications. We are not responsible for the safety of any information that you share with these third parties or their privacy practices.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Yes, we may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

If you choose to register or log in to our Services using a social media account, we may have access to certain information about you. Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in the United Kingdom. If you are accessing our Services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States and other countries.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organisational and technical security measures. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.

11. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the EEA, UK, and Canada), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

You have the right to request access to, correction of, or deletion of your personal data; to object to processing; or to withdraw consent. To make such a request, contact us at [email protected].

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized.

14. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected].

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at [email protected].