goFLUENT Services Privacy Policy
Date Updated: 19 September 2023
goFLUENT is committed to protecting individuals from possible misuse of their Personal Data, protecting their right to data protection and privacy in compliance with the General Data Protection Regulation 2016/679 (“GDPR”), and other Data Protection Legislations, where goFLUENT operates.
goFLUENT Group SA及其子公司（“goFLUENT”、“本公司”、“我”或“我們”）訂定了本隱私權政策，以表明我們對使用者（“您”、“您的”）數據保護和隱私權的堅定承諾。 本隱私權政策載明我們如何處理您的個人資料以及您在本網站上提供的所有可用於直接或間接識別您身份的資訊。
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Section 1. General Information -
Section 2. Corporate Language Academy -
Section 3. Assessment Portal -
Section 4. How To Contact Us -
Section 5. Effectivity And Changes On This Privacy Policy
Section 1. General Information
1.1. Who We Are
goFLUENT Group SA (Route de Pré-Bois 20, 1215 Geneva, Switzerland) is the entity that primarily controls the goFLUENT Corporate Language Academy Portal and goFLUENT Assessment Portal.
By using our services, goFLUENT processes your personal data as a Data Processor under the General Data Protection Regulation 2016/679 (hereinafter “GDPR”). goFLUENT respects your privacy and is committed to processing your personal data as defined by the principles and responsibilities of the GDPR.
If you have any concerns or questions about this Privacy Policy, including any requests to exercise your rights in connection with data protection as mentioned below, please feel free to contact our appointed Data Protection Officer (“DPO”): privacy@gofluent.com
goFLUENT is committed to follow the Principles of Article 5 of the GDPR for the processing of your Personal Data.
1.2. When Does This Privacy Policy Apply?
This Privacy Policy applies to Personal Data that you provide to goFLUENT or that is provided under a contract to deliver access to the Corporate Language Academy, Live Training and Language Assessment Services.
Our Corporate Language Academy is the learning Portal you use for your language training.
Our Assessment Portal is the Portal you use for taking your language Placement test.
To learn more about the purposes for which your Personal Data is used, please visit Section
2 Corporate Language Academy and Section 3 Assessment Portal below.
1.3. What Data do We process?
a. General Data
From our Services, we collect and process the following information:
- Training path data: Including the information about your test results, lesson reports, session tracking, performance surveys, quizzes and activities performed on the Portal.
- Assessing language data: Including your test results.
- Technical data and usage data: Including your password, browser and device information, and any other information that you may have provided and/or we have collected through our Services.
b. Personal Data
Personal Data means any information that, directly or indirectly, identifies you or another individual and which may include:
- Identity and contact details: Name, title, company name, job function, image, voice.
- Profile and usage data: Including your email or user ID to access our Services, your communication preferences and information about your usage of our Services to track your progress in order to make this information available to you.
It is your responsibility not to submit any Personal Data related to third parties. Particularly, when using our services, you must ensure that no Personal Data of other persons is being collected by your device camera and/or microphone.
c. Sensitive Personal Data
goFLUENT does not intend to collect, use or process any Sensitive Personal Data for the delivering of our services through our Portal. To comply with our internal commitment, we ask you not to send us or disclose any Sensitive Personal Data (e.g., information related to racial or ethnic origin, sexual orientation, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background, or trade union membership).
d. Children’s Personal Data
We do not intend for our services to be used by anyone under the age of 16. If you are younger than 16, you may not register with or use our Services. If you are a parent or guardian and believe we may have collected information about a child, please contact at privacy@gofluent.com
e. Personal Data of Deceased Persons
根據GDPR，當地數據保護條例可能會規定有關處理已故人員個人資料的規則，我們將回應繼承人可能已認可代表已故人員行使的權利。
1.4. Where Do We Process and Transfer Your Personal Data?
a. Where goFLUENT Stores Your Data
goFLUENT’s servers that are processing and storing your Personal Data are located in the European Economic Area (the “EEA”).
b. How Do We Handle Your Personal Data Globally?
As part of a global group of companies, goFLUENT has affiliates within as well as outside of the European Economic Area (the “EEA”). Therefore, whenever goFLUENT is using or otherwise processing your Personal Data for the purposes set forth in Section 2) Corporate Academy and Section 3) Assessment Portal of this Privacy Policy, goFLUENT may transfer your Personal Data to countries outside of the EEA, including to such countries in which a statutory level of data protection applies that is not comparable to the level of data protection within the EEA. Whenever such transfer occurs, it is based on the Standard Contractual Clauses (according to article 46.2 c) GDPR and EU Commission Decision 2021/914 or any future replacement) in order to contractually provide that your Personal Data is subject to a level of data protection that applies within the EEA.
To know the list of the goFLUENT entities which will have access to your Personal Data you can reach us out at privacy@admin
We do not sell and share your Personal Data with third parties.
1.5. How Do We Secure And Store Your Personal Data?
a. Data Security
goFLUENT has implemented appropriate organizational, technical and administrative measures aligned with ISO 27001 Certification to protect Personal Data within our organization. These measures include information security tools to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Data from loss, misuse, interference, and unauthorized access, modification and disclosure, you should be aware that no security procedures or protocols are ever guaranteed to be 100% secure from intrusion or hacking. Therefore, there is always some risk related to Personal Data management
b. Handling Data Incidents
goFLUENT has established an internal framework which includes audit and procedures on how we handle and address your concerns regarding data incidents.
If you think there are any data incidents that have occurred with regards to your Personal Data that is connected with our services, please do contact us immediately and send us the details at privacy@gofluent.com
c. Data Retention Policy
Where goFLUENT processes and uses your Personal Data as permitted by the GDPR, goFLUENT will store your Personal Data for the specified time frames stated for each processing activities, as set in Sections 2) Corporate Language Academy and 3) Assessment Portal below.
但是，如果強制性法律要求goFLUENT更長時間地保留您的個人資料，或者goFLUENT需要您的個人資料來主張或抗辯法律索賠，則goFLUENT將保留您的個人資料，直到相關保留期結束或相關索賠得到解決。
1.6. Your Individual Data Protection Rights
If you have any requests to exercise your rights in connection with data protection as mentioned below, please feel free to contact us at: privacy@gofluent.com
我們承諾在三十 （30） 天內回復您的要求。
a. Right Of Access: 您可以隨時向goFLUENT索取有關goFLUENT處理您的哪些個人資料的資訊。
b. Right To Rectification: If the Personal Data that we process is incomplete or incorrect, you have the right to request their completion or correction at any time. However, we encourage you to review and update your Personal Data by accessing your individual online account.
c. Right To Erasure: You have the right to request the deletion at any time, if you consider that we should stop processing them. However, in case goFLUENT is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law.
As goFLUENT is not the Data Controller of your Personal Data, in order to process your Erasure Request we will need to notify your Organization about your request, in order to give you an answer aligned with your Organization’s Data Retention Policy.
d. Right To Restriction Of Processing: You can request that goFLUENT restricts your Personal Data from any further processing in any of the following events:
- you state that the Personal Data goFLUENT has about you is incorrect, (but only for as long as goFLUENT requires to check the accuracy of the relevant Personal Data),
- there is no legal basis for goFLUENT processing your Personal Data and you demand that goFLUENT restrict your Personal Data from further processing,
- goFLUENT no longer requires your Personal Data but you claim that you require goFLUENT to retain such data in order to claim or exercise legal rights or to defend against third-party claims, or
- in case you object to the processing of your Personal Data by goFLUENT (based on goFLUENT’s legitimate interest) for as long as it is required to review whether goFLUENT has a prevailing interest or legal obligation in processing your Personal Data.
If you request to restrict the processing of your Personal Data, it will result in the suspension of your access to our Solutions and also to the delivery of our services, during the process we solve your request.
e. Right To Object: You may object to goFLUENT using Personal Data when goFLUENT is processing your data for its own Legitimate Interest, in the terms set forth in this Privacy Policy. If you do so, goFLUENT will cease using your Personal Data for the purposes lawfully based on the legal obligation and remove it from its systems, unless goFLUENT is permitted to use such Personal Data for another purpose set forth in this Privacy Policy or goFLUENT determines and demonstrates a compelling legitimate interest to continue processing your Personal Data.
f. Right To Withdraw Your Consent: 如果您的個人資料是在您同意的基礎上處理的，您有權隨時撤回。 取消同意將不影響撤回前處理您的資料的合法性。
As goFLUENT is not the Data Controller of your Personal Data, in order to process your Consent Withdrawal Request we will need to notify your Organization about your request, in order to give you an answer aligned with your Organization’s Data Retention Policy.
g. Rights In Relation To Automated Decision And Profiling: We respect your legal rights not to be subject to decisions that are based solely on automated processing of your Personal Data, including profiling activities.
In delivering services to you, goFLUENT does not perform processing activities, based on automated decision making, including profiling.
h. Right To Lodge A Complaint: 如果您認為goFLUENT沒有按照此處規定的要求或適用的EEA數據保護法處理您的個人資料，您可以隨時向您居住的EEA國家/地區的數據保護機構或goFLUENT註冊所在國家或州的數據保護機構提出投訴。
Section 2. Corporate Language Academy
2.1. Your Personal Data in the goFLUENT Corporate Language Academy.
This section of the Privacy Policy applies exclusively to the users (“Learners”) of the goFLUENT Corporate Language Academy.
Definition of Learners: Learners are the employees of the organizations which have contracts to use our training services delivered via the goFLUENT Corporate Language Academy.
2.2. How Do We Collect Your Personal Data?
我們以各種方式收集您的個人資料，包括：
a. Through your employer or an organization you are related to: When your employer registers you to receive services from goFLUENT by providing your Personal Data directly to goFLUENT;
b. Through the goFLUENT Corporate Language Academy (Portal): When you access or log-in in our Portal to receive our services, goFLUENT may collect information as you edit and update your Personal Data in the User Information section, and other information that you will share and provide to personalize your training and/or while taking your lessons through comments, chats, Writing exercises, participation in live lessons and virtuals classes, questionnaires, etc.;
c. Through our app: When you download and use the goFLUENT app or other apps developed by goFLUENT, we and our service providers track and collect app usage data, e.g., data such as the date and time, when the app accesses our servers and what information has been downloaded to the app based on your mobile device number.
d. Directly from you: When you contact us to update your personal data or contact details.
2.3. How Do We Use And Process Your Personal Data?
a. Registration and provision of access to the Corporate Language Academy
In order to give you access to goFLUENT Corporate Language Academy, we will use your Personal Data to register you and to create your user profile.
The relevant Personal Data is required for goFLUENT to create the user profile and offer access to our Corporate Language Academy.
b. Personalizing Your Learner Profile
In the process of using the Corporate Language Academy goFLUENT offers you the option to add additional information such as your professional job title and industry.
Providing this information is completely voluntary. If you decide not to provide this information, you can still use our services
c. Lesson Reporting
goFLUENT collects processes and stores the information resulting from the Placement Test you take when first accessing our Portal.
goFLUENT will process the Personal Data based on statutory permission set out in the GDPR, for the purposes delineate in this Privacy Policy.
Where goFLUENT uses your Personal Data based on the provision of our Services:
According to article 6.1 b) of the GDPR, goFLUENT uses and processes your Personal Data for the following processing operations:
a. Registration and provision of access to the Corporate Language Academy
In order to give you access to goFLUENT Corporate Language Academy, we will use your Personal Data to register you and to create your user profile.
The relevant Personal Data is required for goFLUENT to create the user profile and offer access to our Corporate Language Academy.
b. Personalizing Your Learner Profile
In the process of using the Corporate Language Academy goFLUENT offers you the option to add additional information such as your professional job title and industry.
Providing this information is completely voluntary. If you decide not to provide this information, you can still use our services
c. Lesson Reporting
goFLUENT collects processes and stores the information resulting from the Placement Test you take when first accessing our Portal.
- Placement Test Results
We process the data to make available the Placement Test results available to you. We may also use the results to offer you customized content and activities based on your level of language comprehension.
- Lesson Reports
After taking individual lessons with goFLUENT, your trainer will send you a Lesson Report, which includes relevant information and resources for your training.
d. In-Lesson Interactive Tools
Depending on the service you get from goFLUENT, you can use chat, interactive whiteboard or a tool to send your files to a trainer for the purpose of your training.
e. Services Support
To handle your queries and requests, we may communicate with you by phone, chat or email.
f. Reminders And Notifications
We send notifications about your lessons to your email address.
g. Learner Engagement Activities
We may send you messages, questionnaires, surveys or invitations to training-related activities hosted by goFLUENT. The purpose of these communications is to help you use the Portal, to invite you to events and webinars, and to help you stay motivated as you follow your training path.
Questionnaires and Surveys are designed in a way that they can be answered without any Personal Data. We use these questionnaires and surveys to know your general satisfaction with our Portal.
h. Usage and Progress Reporting
We will provide you with reporting on your Portal usage and your Live Training progress within the Portal, the quizzes and activities you have taken, the satisfaction surveys you have completed and also the reporting of the time you have spent on the Portal.
This information is also collected, consolidated and provided to your Organization, as a part of our reporting services.
2.4. Data Retention Policy
goFLUENT will retain your Personal Data as long as we provide you with our services through the Portal. After your access to our Portal and Live Training services expires, goFLUENT will store your Personal Data for the necessary time period to comply with applicable regulation, and for audit and reporting purposes.
Section 3. Assessment Portal
3.1. Your Personal Data On The Assessment Portal.
This section of the Privacy Policy applies exclusively to the users (hereinafter “Candidates”) of the Assessment Portal, who take the Proficiency Test and the Speaking Test.
Definition of candidates: Candidates are the users of the Assessment Portal who requested to assess their language skills by the organizations they are related to or during the job application process.
3.2. Where Does Your Personal Data Come From?
a. Through the organization with whom you are in a recruitment process: When the organization with whom you are in a recruitment process registers you to perform the grading language test by providing your Personal Data directly to goFLUENT;
b. Through your employer or the organization you are related to: When your employer registers you to receive services from goFLUENT by providing your Personal Data directly to goFLUENT;
c. Through automated technologies: As you interact with our Assessment Portal, we may automatically collect certain information through your browser or through your device, e.g., your IP address;
d. Through our Assessment Portal: When you access or log-in to our Assessment portal to receive our services, goFLUENT may collect information as a consequence of your performance on the tests;
3.3. What Are The Purposes Of Processing Your Personal Data?
According to article 6.1 b) GDPR, we will process your Personal Data for the provision of our services:
a. Registration To Our Assessment Portal
There will be relevant and essential Personal Data which will be required for the creation of the Candidate profile to provide you with access to our Assessment Portal Solution. Those data are necessary to create your Candidate Profile and to give you access to our Assessment Portal.
b. Execution Of The Assessment Test
For the purpose of your language assessment you will be required to take the Proficiency Test and the Speaking Test. During the Proficiency Test we will be taking pictures at random intervals using your device camera. This is a necessary requirement as a part of anti-cheating measures. While answering the questions during the Speaking Test you will be required to record a video of yourself, which will be used to evaluate your language fluency and to verify your identity. Without those Personal Data, we will not be able to evaluate your assessment results.
c. Email Communications
We will send you emails related to our Assessment services, including the following purposes:
- To confirm your registration to our Assessment Portal
- To send you the instructions about how to use our Portal, perform the tests and the timeframe you have to do so
- To communicate to you your Test results when they are ready.
These communications are not marketing-related, but merely required for the relevant performance of the services.
d. Communication of your Personal Data
As mentioned above, we will take pictures and videos of you during the Proficiency Test and the Speaking Test. These Personal Data will be communicated to the Organization that contracted our Assessment services (Assessment Portal) for the sole purpose of validating your identity. Your Organization will not be able to download the pictures and videos of you. Your Personal Data will not be shared with third parties.
3.4. Data retention
goFLUENT will store recorded pictures and videos of you for 45 (forty-five) days as a part of our Services through the Assessment Portal. After 45 days recorded pictures and videos will be automatically deleted from our systems.
Section 4. How To Contact Us
goFLUENT尊重您的隱私。 如果您對本隱私政策有任何疑慮，包括行使上述與數據保護有關的權利的任何請求，請隨時聯繫我們指定的數據保護官（DPO）
You may send us your concerns and questions in the details provided below:
| Information | Details |
|---|---|
| 資安長 | Evgeny Boychuk |
| Email address | privacy@gofluent.com |
Section 5. Effectivity And Changes On This Privacy Policy
為確保我們的隱私權政策不斷更新，以履行我們對您的數據保護和隱私權以及最佳實踐的承諾，goFLUENT可能會不時修訂本隱私政策。 如上所述，更新日期是本隱私政策的生效修訂日期。