Privacy Policy
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This Privacy Policy explains how Movoteka collects and uses personal data when you visit our website, book a consultation, take lessons with us or otherwise get in touch. We are committed to handling your data in accordance with the EU General Data Protection Regulation (GDPR), the Estonian Personal Data Protection Act and, for people in the United Kingdom, the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who is responsible for your data
1.1 The data controller is Movoteka Learn OÜ, trading as Movoteka, a private limited company registered in the Estonian Commercial Register under registry code 17579607, with its registered address at A. H. Tammsaare tee 119, Mustamäe linnaosa, 12917 Tallinn, Harju maakond, Estonia.
1.2 Questions about this policy or about your data should be sent to antoni.golab@movoteka.co.uk.
2. The data we collect
We collect the following categories of personal data:
| Category | Examples | Source |
|---|---|---|
| Identity and contact | Name, email address, phone number, WhatsApp or Telegram handle | You, when you book, message or purchase |
| Booking data | Consultation date and time, notes you add when booking | You, via Calendly |
| Learning data | Placement Test results, current level, lesson notes, homework, progress records, attendance | You, your Teacher and the Pearson Platform |
| Payment data | Package purchased, amount, date, payment status, the last four digits of your card | Stripe. We never receive your full card number |
| Communications | Messages you send us by email, WhatsApp or Telegram, and our replies | You |
| Referral data | The name of a person you refer, and who referred you | You or the person who referred you |
| Guide sign-ups | Name and email address left on the Free Guide page | You |
| Technical data | IP address, browser type, pages visited, language preference | Your device and our hosting provider |
| Advertising data | Pages you view and actions you take on the website (booking a free call, starting or completing a purchase, signing up for the guide, messaging us), linked to an identifier stored in the _fbp and _fbc cookies |
The Meta Pixel, only if you accept cookies in our banner |
We do not intentionally collect special category data (such as health data). If you tell us about a health condition so that we can adjust lessons, we process it only with your explicit consent and only for that purpose.
3. Why we use your data and our lawful basis
| Purpose | Lawful basis |
|---|---|
| Arranging and delivering your consultation, Placement Test and lessons; assigning a Teacher; tracking your progress | Performance of a contract with you, or steps taken at your request before entering into a contract |
| Taking payment and keeping accounting records | Performance of a contract; legal obligation (tax and accounting law) |
| Replying to your messages and providing support | Legitimate interests (running our school and responding to enquiries) |
| Running the referral programme | Performance of a contract; legitimate interests |
| Sending you the Free Guide and, where you have agreed, occasional emails about our services | Consent, which you can withdraw at any time |
| Measuring and improving our adverts on Facebook and Instagram with the Meta Pixel | Consent, which you can withdraw at any time using the Cookie settings link at the bottom of every page |
| Improving our website and services | Legitimate interests (aggregated, non-identifying statistics) |
| Keeping our website and systems secure, preventing fraud and misuse | Legitimate interests; legal obligation |
| Establishing, exercising or defending legal claims | Legitimate interests |
Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms and concluded that our processing is proportionate. You may object to processing based on legitimate interests at any time (see section 8).
4. Who we share your data with
We share personal data only where necessary with the following categories of recipient, each of which acts under a contract or terms that require them to protect your data:
- Teachers engaged by us, who receive the information they need to teach you (name, level, test results, lesson notes and contact details for scheduling).
- Pearson, which provides the learning platform and the Placement Test. Pearson processes your name, email address and learning data to provide the platform.
- Stripe, which processes payments. Stripe acts as an independent controller for the payment data it holds.
- Calendly, which hosts the booking calendar for consultations.
- Vercel, which hosts our website and processes technical data such as IP addresses in server logs.
- Meta Platforms Ireland Limited, if you accept cookies in our banner. Meta receives the data collected by the Meta Pixel. For the collection and transmission of that data, we and Meta act as joint controllers. Meta then processes it as an independent controller under its own privacy policy to provide advertising and measurement services, and may transfer it to Meta Platforms, Inc. in the United States.
- Messaging providers (WhatsApp, owned by Meta, and Telegram) when you choose to contact us through them. Those providers process your messages under their own privacy terms.
- Professional advisers, such as accountants, insurers and lawyers, where necessary.
- Authorities or regulators, where we are required by law to do so.
We do not sell your personal data and we do not share it with third parties for their own marketing.
5. International transfers
Some of the providers listed above process data outside the European Economic Area and the United Kingdom, in particular in the United States. Where that happens, we rely on one of the following safeguards: an adequacy decision for the destination country (for the United States, the provider's certification under the EU-US Data Privacy Framework and its UK Extension); or the European Commission's Standard Contractual Clauses, together with the UK Addendum or the International Data Transfer Agreement where data from the United Kingdom is involved. You may ask us for details of the safeguard that applies to a particular transfer.
6. How long we keep your data
| Data | Retention period |
|---|---|
| Learner records (contact details, level, progress, lesson notes) | For the duration of your relationship with us and for 6 years afterwards, which is the limitation period for contractual claims in England and Wales |
| Payment and accounting records | 7 years from the end of the financial year in which the transaction took place, as required by the Estonian Accounting Act |
| Messages and enquiries from people who do not become learners | 12 months from the last message |
| Free Guide sign-ups and marketing consent | Until you unsubscribe or ask us to delete your data, or after 24 months of no engagement |
| Website server logs | Up to 30 days |
When data is no longer needed we delete it or anonymise it so that it can no longer be linked to you.
7. Children
Our lessons and our Free Guide are available to children and teenagers as well as adults. Where a learner is under 18, we require a parent or guardian to book the consultation, purchase the package and provide contact details. We collect only the child's first name, level and learning data needed to teach them. We do not send marketing to children. If you believe we have collected data about a child without appropriate consent, please contact us and we will delete it.
8. Your rights
Under data protection law you have the right to:
- access the personal data we hold about you and receive a copy;
- rectification of data that is inaccurate or incomplete;
- erasure of your data in certain circumstances, for example where it is no longer needed;
- restriction of processing in certain circumstances;
- data portability, that is to receive data you provided to us in a structured, machine-readable format;
- object to processing based on legitimate interests, and to direct marketing at any time;
- withdraw consent at any time where we rely on consent, without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, email antoni.golab@movoteka.co.uk. We will respond within one month, and we will not normally charge a fee. We may ask you to confirm your identity before acting on a request.
You also have the right to lodge a complaint with a data protection supervisory authority. Our lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), www.aki.ee. If you live in the United Kingdom, you can also complain to the Information Commissioner's Office (ICO) at ico.org.uk or by telephone on 0303 123 1113. We would appreciate the opportunity to address your concerns before you approach a supervisory authority.
9. Security
We take appropriate technical and organisational measures to protect your data, including encrypted connections (HTTPS) across our website, access controls on our systems, and the selection of providers that meet recognised security standards. No method of transmission over the internet is completely secure, and we cannot guarantee absolute security, but we will notify you and the ICO where required by law if a breach affecting your data occurs.
10. Cookies and similar technologies
Our website uses a small number of cookies and browser storage items. Details, including how to manage your choices, are set out in our Cookie Policy.
11. Automated decision-making
We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects. Placement Test results are reviewed by a Teacher before a level is confirmed.
12. Changes to this policy
We may update this policy from time to time. The date of the latest version is shown at the top of this page. Where a change is significant, we will tell existing learners by email or message before it takes effect.
13. Contact
Movoteka Learn OÜ, A. H. Tammsaare tee 119, Mustamäe linnaosa, 12917 Tallinn, Harju maakond, Estonia. Email: antoni.golab@movoteka.co.uk.