Privacy Policy

1. Information We Collect

The information we collect depends on how you interact with Chatly.

Information you provide to us

We may collect information that you provide when you:

• purchase or enquire about lessons;
• book, cancel or reschedule lessons;
• participate in lessons;
• complete forms or questionnaires;
• communicate with us by email, WeChat, WeCom or other communication channels;
• contact customer support;
• provide feedback or reviews;
• participate in promotions or surveys; or
• otherwise communicate with Chatly, our tutors or our service providers.

This information may include:

• your name;
• email address;
• telephone number;
• WeChat or other messaging identifier;
• country or region;
• time zone;
• age or age range;
• preferred language;
• English proficiency level;
• learning goals;
• lesson preferences;
• availability;
• tutor preferences;
• examination or academic goals;
• employment or professional information where relevant to Business English lessons;
• information provided by a parent or guardian about a student;
• communications with Chatly or our tutors; and
• other information you choose to provide.

Student information

To provide appropriate English lessons, we may collect information about a student's:

• age;
• English level;
• educational level;
• learning objectives;
• areas of strength or difficulty;
• lesson history;
• progress;
• attendance;
• tutor feedback;
• homework or learning activities; and
• examination preparation or results voluntarily shared with us.

Tutors may also make lesson notes to help provide continuity and improve future lessons.

2. Payment Information

When you purchase lessons or subscriptions, payments may be processed by third-party payment providers.

Depending on the payment method used, these providers may collect:

• card details;
• billing details;
• payment account information;
• transaction identifiers;
• payment method;
• billing country; and
• fraud-prevention information.

Chatly does not generally receive or store your complete payment card number or card security code where payments are processed directly by a third-party payment provider.

We may receive information about a transaction including:

• amount paid;
• currency;
• payment status;
• payment method;
• refunds;
• disputes;
• transaction reference; and
• the lesson plan or subscription purchased.

Payment providers may process information in accordance with their own privacy policies and legal obligations.

3. Lesson Recordings, Audio, Video and Transcripts

Some Chatly lessons may be recorded.

Depending on the lesson platform and features being used, this may include:

• video;
• audio;
• text chat;
• lesson transcripts;
• screen sharing;
• classroom activity;
• teaching materials; and
• information voluntarily discussed during a lesson.

Recordings and transcripts may be used to:

• allow students to review lessons;
• provide learning feedback;
• improve teaching quality;
• review tutor performance;
• investigate technical or customer-support issues;
• resolve complaints or disputes;
• maintain safety and integrity; and
• improve Chatly's educational services.

Students and parents should avoid voluntarily disclosing unnecessary sensitive personal information during lessons.

4. Information Collected Automatically

When you visit our website or use our Services, certain technical information may be collected automatically.

This may include:

• IP address;
• browser type;
• operating system;
• device type;
• approximate location derived from IP address;
• referring website;
• pages visited;
• date and time of access;
• interactions with our website;
• session information;
• device identifiers; and
• technical diagnostic information.

We may use cookies and similar technologies to collect some of this information.

5. Cookies and Similar Technologies

Chatly may use cookies, pixels, local storage and similar technologies to:

• operate our website;
• remember preferences;
• maintain website security;
• understand how visitors use our website;
• measure website performance;
• identify and fix technical problems;
• understand marketing performance; and
• provide relevant advertising where permitted.

Some cookies are necessary for our website to function.

Where required by law, non-essential cookies will only be used after obtaining appropriate consent.

You may also control cookies through your browser settings. Disabling certain cookies may affect the functionality of our Services.

6. How We Use Personal Information

We may use personal information to:

• provide English lessons and tutoring services;
• process purchases and subscriptions;
• schedule and manage lessons;
• match students with appropriate tutors;
• communicate with students and parents;
• administer our relationship with you;
• provide customer support;
• manage cancellations, rescheduling and refunds;
• track student progress;
• personalise learning experiences;
• provide lesson feedback;
• maintain lesson histories;
• send service-related communications;
• send marketing communications where permitted;
• improve our curriculum, website and Services;
• analyse how our Services are used;
• train and support tutors;
• maintain security;
• detect and prevent fraud or misuse;
• enforce our Terms and Conditions;
• comply with legal, tax, accounting and regulatory requirements;
• establish, exercise or defend legal claims.

We may also use aggregated or de-identified information for analytics, research and improvement of our Services where the information no longer reasonably identifies an individual.

7. Legal Bases for Processing

Where laws such as the UK GDPR or European GDPR apply, we rely on one or more lawful bases for processing personal information.

Performance of a contract

We process information where necessary to provide Services you have purchased or requested, including providing lessons, arranging tutors and processing transactions.

Legitimate interests

We may process information where reasonably necessary for our legitimate business interests, including:

• operating and improving Chatly;
• providing customer service;
• maintaining security;
• preventing fraud;
• analysing our Services;
• improving teaching quality; and
• managing our business.

We consider the impact on your rights when relying on legitimate interests.

Consent

We may rely on consent for certain activities including some marketing, cookies, lesson recordings or processing involving children where required by law.

Where processing is based on consent, you may withdraw that consent subject to applicable law.

Legal obligations

We may process information where necessary to comply with legal, regulatory, tax, accounting or law-enforcement obligations.

8. How We Share Personal Information

We do not sell personal information in the ordinary meaning of selling customer information for money.

We may disclose information to the following categories of recipients where reasonably necessary.

Tutors

Information necessary to provide lessons may be made available to the tutor teaching the student.

This may include the student's name, age or age range, English level, learning objectives, previous lesson information and other relevant educational information.

Service providers

We use third-party companies to help operate Chatly.

These may include providers of:

• online classroom technology;
• video communications;
• website hosting;
• cloud infrastructure;
• payment processing;
• communications;
• WeChat or WeCom services;
• email;
• analytics;
• customer support;
• scheduling;
• fraud prevention;
• cybersecurity; and
• professional services.

For example, lessons may currently be delivered using Neukol, and communications with some students may take place using WeChat or WeCom.

These providers may process personal information in accordance with their own terms and privacy obligations.

Professional advisers

We may disclose information where reasonably necessary to lawyers, accountants, auditors, insurers, banks and other professional advisers.

Legal and safety reasons

We may disclose information where we reasonably believe disclosure is required to:

• comply with applicable law;
• respond to lawful requests from authorities;
• comply with court orders or legal proceedings;
• investigate fraud;
• protect Chatly, our students, tutors or others;
• enforce our agreements; or
• protect legal rights or safety.

Business transactions

If Chatly or AJK Online LLC is involved in a merger, financing, acquisition, restructuring, sale of assets or similar transaction, personal information may be disclosed as part of that transaction, subject to appropriate safeguards.

9. Children's Privacy

Chatly provides educational services to both adults and children.

Where a student is a minor, we may require a parent or legal guardian to:

• purchase the Services;
• provide information about the student;
• communicate with Chatly;
• consent to certain processing activities; and
• manage the student's participation in the Services.

We may collect information about children where necessary to provide their lessons, such as their name, age, English level, learning progress, lesson recordings and communications.

We seek to collect only information reasonably necessary to provide and improve the educational service.

10. Parents and Guardians

If you provide information about a child, you confirm that you are authorised to provide that information to us.

Parents and guardians may contact Chatly regarding the information we hold about their child.

Depending on applicable law, you may have rights to:

• access the child's personal information;
• correct inaccurate information;
• request deletion;
• withdraw consent;
• request that certain processing stop; or
• obtain further information about how the child's information is used.

We may need to verify your identity and relationship to the child before fulfilling such a request.

11. Communications

We may communicate with you through:

• email;
• WeChat;
• WeCom;
• telephone;
• website communications; or
• other communication services agreed with you.

Service communications may include:

• lesson confirmations;
• scheduling information;
• tutor information;
• payment information;
• subscription notices;
• changes to the Services;
• security notices; and
• customer-support communications.

These communications may be necessary to provide the Services and therefore may not always be optional.

12. Marketing Communications

Where permitted by law, we may send information about Chatly lessons, offers, products or services.

You may opt out of promotional email communications using the unsubscribe mechanism included in the message or by contacting us.

Opting out of marketing does not prevent us from sending necessary service-related communications.

13. International Data Transfers

Chatly operates internationally.

AJK Online LLC is a United States company, while our students, tutors and service providers may be located in other countries, including the United Kingdom, China and other jurisdictions.

As a result, personal information may be transferred to, stored in or processed in countries outside the country where you live.

Privacy and data protection laws in those countries may differ from those in your jurisdiction.

Where applicable law requires safeguards for international transfers, we will take appropriate measures designed to protect personal information. These measures may include contractual safeguards, approved transfer mechanisms, consent where legally appropriate, or other mechanisms permitted by applicable law.

14. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Retention periods may depend on:

• the duration of our relationship with you;
• whether you continue to use Chatly;
• legal and regulatory requirements;
• payment and accounting requirements;
• dispute-resolution requirements;
• fraud prevention;
• security requirements; and
• the nature of the information.

Some records may need to be retained after you stop using Chatly for tax, accounting, legal or regulatory reasons.

When information is no longer required, we may delete or anonymise it.

15. Data Security

We use reasonable administrative, technical and organisational measures designed to protect personal information against:

• unauthorised access;
• loss;
• misuse;
• alteration;
• destruction; and
• unauthorised disclosure.

However, no system or method of transmitting information over the internet is completely secure, and we cannot guarantee absolute security.

16. Your Privacy Rights

Depending on where you live and applicable law, you may have rights relating to your personal information.

These may include the right to:

• know whether we process your information;
• request access to your information;
• receive a copy of your information;
• correct inaccurate information;
• request deletion;
• restrict certain processing;
• object to certain processing;
• withdraw consent;
• opt out of certain marketing;
• request data portability;
• opt out of certain forms of targeted advertising or data sharing where applicable; and
• lodge a complaint with an applicable privacy or data-protection authority.

These rights are not absolute and may be subject to legal exceptions.

To exercise a privacy right, contact us using the details in Section 22.

We may need to verify your identity before processing your request.

17. UK and European Users

If the UK GDPR, EU GDPR or similar legislation applies to you, you may have additional rights including rights of:

• access;
• rectification;
• erasure;
• restriction;
• objection;
• data portability; and
• withdrawal of consent.

You may also have the right to complain to the relevant supervisory authority.

For individuals in the United Kingdom, this may include the Information Commissioner's Office (ICO).

18. Users in Mainland China

Where China's Personal Information Protection Law (“PIPL”) or other applicable Chinese privacy laws apply, individuals may have rights relating to their personal information, including rights to:

• know about and make decisions regarding processing;
• restrict or refuse certain processing;
• access and copy personal information;
• correct or supplement inaccurate information;
• request deletion in circumstances provided by law; and
• withdraw consent where processing relies upon consent.

Where required by applicable law, we will seek separate consent for processing sensitive personal information or transferring personal information internationally.

19. United States Privacy Rights

Residents of certain US states may have additional rights under state privacy laws.

Depending on the applicable law and whether Chatly falls within its scope, these may include rights to:

• access personal information;
• correct personal information;
• delete personal information;
• obtain a portable copy;
• opt out of certain sales or sharing;
• opt out of targeted advertising; and
• appeal certain decisions relating to privacy requests.

We will honour applicable privacy rights where required by law.

20. Third-Party Websites and Services

Our Services may contain links to or integrations with third-party services.

Those third parties may have separate privacy policies and practices.

Chatly is not responsible for the privacy practices of independent third parties, and we encourage you to review their privacy notices.

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we make changes, we will update the effective date at the top of this page.

Where required by law, we may provide additional notice of material changes or request renewed consent.

Your continued use of the Services after an updated policy becomes effective will be subject to the updated Privacy Policy to the extent permitted by applicable law.

22. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or would like to exercise a privacy right, please contact us.