Privacy Policy of www.missenglish.it

Owner and Data Controller

Learning English Trough F.U.N.

Owner contact email: letfunsrl@gmail.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Trackers; Usage Data; IP address.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy
policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this
Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may
make it impossible for this Application to provide its services. In cases where this Application specifically states
that some Data is not mandatory, Users are free not to communicate this Data without consequences to the
availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used
by this Application serves the purpose of providing the Service required by the User, in addition to any other
purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or
unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and
modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be
accessible to certain types of persons in charge, involved with the operation of this Application (administration,
sales, marketing, legal, system administration) or external parties (such as third-party technical service
providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data
Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the
processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than
their own. To find out more about the place of processing of such transferred Data, Users can check the section
containing details about the processing of Personal Data.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal
obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third
parties), detect any malicious or fraudulent activity, as well as the following:Displaying content from external
platforms and Analytics.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed
information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep
track of User behaviour.

Matomo (self-hosted) (this Application)

Matomo is an analytics software used by this Application to analyse data directly without the help of third parties.

Personal Data processed: anonymized IP address; Usage Data.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this
Application and interact with them. Such services are often referred to as widgets, which are small elements placed
on a website or app. They provide specific information or perform a particular function and often allow for user
interaction.
This type of service might still collect web traffic data for the pages where the service is installed, even when
Users do not use it.

Vimeo video (Vimeo, LLC)

Vimeo is a video content visualisation service provided by Vimeo, LLC that allows this Application to incorporate
content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Instagram widget (Meta Platforms Ireland Limited)

Instagram is an image visualisation service provided by Meta Platforms Ireland Limited that allows this Application
to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy.

Cookie Policy

This Application uses Trackers. To learn more, Users may consult the Cookie
Policy.

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes.
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual
  obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official
  authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in
particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract.

Further information about retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User
  shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed
  to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the
  Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such
processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data
for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to
erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the
retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have
  previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their
  Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if Data is being processed by the Owner,
  obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing
  processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and
  ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right to restrict the processing of their
  Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right to obtain the
  erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to
  receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to
  have it transmitted to another controller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection
  authority.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or
to any international organisation governed by public international law or set up by two or more countries, such as
the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or
enquire with the Owner using the information provided in the contact section.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in
the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such
processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they
can object to that processing at any time, free of charge and without providing any justification. Where the
User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such
purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer
to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this
document. Such requests are free of charge and will be answered by the Owner as early as possible and always within
one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or
restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has
been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner
will inform them about those recipients.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible
legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public
authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with
additional and contextual information concerning particular Services or the collection and processing of Personal
Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record
interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this
purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time.
Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page
and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users
via any contact information available to the Owner. It is strongly recommended to check this page often, referring
to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall
collect new consent from the User, where required.