Privacy Policy

 

Last Updated: October 4th, 2024

 

1. Introduction

 

I am Craig Brown, an American English-language tutor. I run this website and my business is classified as a "micro-enterprise" under French law and is registered in France (Siren #: 933560054), where I live and have my "auto-entrepreneur" status. For the remainder of this article I will refer to my business using "we," "our," or "us". We provide online professional conversation practice services ("Services"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Services.

 

2. Information We Collect

 

2.1 Information You Provide

To provide our professional conversation practice services and maintain your account, we collect the following information that you voluntarily provide to us during use of our services:

- Name and contact information

- Professional background information

- Payment information (processed through Stripe)

- Content of practice conversations

- Account credentials

- Communication preferences

 

2.2 Information Automatically Collected

When you visit our website and use our services, our systems automatically collect certain technical and usage information to ensure proper functionality and improve your experience:

- Device information

- IP address

- Browser type

- Operating system

- Usage data

- Cookies and similar technologies

 

3. How We Use Your Information

 We use your information to:

- Provide and maintain our Services

- Process payments through Stripe

- Schedule and conduct practice sessions

- Communicate with you about our Services

- Improve our Services

- Comply with legal obligations

 

4. Payment Information

 All payment processing is handled through Stripe. We do not store your complete credit card information. When you make a payment:

- You provide your payment information directly to Stripe

- We receive only limited information about your transaction

- All payment data is encrypted and processed securely by Stripe

- Stripe's own Privacy Policy and Terms of Service apply to payment processing

 

5. Information Sharing

 We may share your information with:

- Stripe (for payment processing)

- Calendly (for scheduling sessions)

- Service providers who assist in operating our business

- Legal authorities when required by law

- Professional advisors (e.g., lawyers, accountants)

 

We do not sell your personal information to third parties.

 

6. Data Security

 We implement appropriate security measures to protect your information, including:

- Encryption of data in transit and at rest

- Regular security assessments

- Limited access to personal information

- Secure payment processing through Stripe

 

7. Your Rights

 You have the right to:

- Access your personal information

- Correct inaccurate information

- Request deletion of your information

- Opt-out of certain data collection

- Withdraw consent for data processing

 

8. Changes to This Policy

 We may update this Privacy Policy periodically. We will notify you of any material changes by posting the updated policy on our website.

 

9. Contact Us

 

For questions about this Privacy Policy or our privacy practices, contact Craig Brown at:

SmallConvBusiness@outlook.com

 

10. Additional Information for Specific Jurisdictions

10.1 European Union Residents

If you are a resident of the European Union (EU) or European Economic Area (EEA), you have specific rights under the General Data Protection Regulation (GDPR):

Legal Basis for Processing

We process your personal data under the following legal bases:

  • Contract Performance: Processing necessary to provide our Services as contracted
  • Legal Obligation: Processing required to comply with our legal obligations
  • Legitimate Interests: Processing that serves our legitimate business interests
  • Consent: Processing based on your explicit consent

Additional Rights Under GDPR

In addition to the rights mentioned in Section 7, EU/EEA residents have the right to:

  • Data Portability: Receive your personal data in a structured, commonly used format and transmit it to another controller
  • Restriction of Processing: Limit how we use your personal data in certain circumstances
  • Object to Processing: Object to processing based on legitimate interests or direct marketing
  • Withdraw Consent: Withdraw previously given consent for data processing
  • Lodge a Complaint: File a complaint with your local data protection authority

International Data Transfers

Your data may be transferred to and processed in countries outside the EU/EEA. We ensure such transfers comply with GDPR requirements through:

  • Standard Contractual Clauses approved by the European Commission
  • Adequacy decisions issued by the European Commission
  • Other appropriate safeguards as required by GDPR

Data Retention

We retain your personal data only for as long as necessary to:

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

Typical retention periods are:

  • Account information: Duration of your account plus 2 years
  • Practice session records: 1 year after completion
  • Payment information: 7 years (as required by tax laws)
  • Communication records: 2 years from last interaction

Automated Decision-Making

We do not engage in automated decision-making or profiling that produces legal effects or similarly significant effects on individuals.

Special Categories of Personal Data

We generally do not collect or process special categories of personal data (sensitive data). If such data is accidentally disclosed during practice sessions, it will be treated with additional security measures and deleted as soon as possible.

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

  • Notify the relevant supervisory authority within 72 hours
  • Inform affected individuals without undue delay
  • Provide information about the breach and steps taken to mitigate risks

Cookie Policy Compliance

Our cookie usage complies with EU ePrivacy Directive requirements. This website does not collect cookies, but cookies may be collected by Stripe or Calendly.

Please contact me directly if you have any questions or want to know more.
My email address is craigfbrown@gmail.com
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