Privacy Policy
GENERAL

At Engram, we care about your personal data, so we have prepared this Privacy Policy to explain how we collect, use and share it.

This Privacy Policy ("Privacy Policy") details the personal data Engram, Inc. ("Engram", "we", "us" or "our") receives about you, how we process it and your rights and obligations in relation to your personal data. Engram, Inc., a company registered at 5/4 Leninskaya str, 12 , Mogilev, Belarus is the data controller for the purposes of the General Data Protection Regulation ("GDPR") and any relevant local legislation ("Data Protection Laws").

By using or accessing the Service, you agree to the terms of this Privacy Policy. We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy on the Website for at least 7 days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that 7 day period.
  1. INFORMATION WE COLLECT

    This Privacy Policy explains how we collect, use and share your personal data.

    Information you provide Through the registration process, you will provide us with your phone number. You will also provide us with your payment transaction information if you choose to pay for Engram services.

    Live Speaking Practice When you take a Live Speaking Lesson, we will use your computer's microphone throughout the lesson to speak to your tutor. You also have the option of using your camera to share your video with your tutor.

    Engram does not share any of your personal data with your tutor. You are completely anonymous to them by default, and you can freely choose whether you show them your video or tell them any personal details such as your name during the conversation. Engram only shares some basic skill level information with the tutor, prior to your lesson, so they understand how best to speak to you.

    Test Data If you register for the Engram English Test, you will also provide us with your name and e-mail.

    When you use the Service to take an examination in the Engram English Test you must provide access to your computer's webcam and microphone. We will use them to record you and your screen during the entire examination period ("Testing Video"). While using the Engram English Test, you will submit answers to questions and other information as part of the testing and evaluation process.


    Product Research and Development We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We will record the video, audio and text transcriptions of these sessions and will retain this data for two years.

    You may opt out of being contacted for research activities at any time by emailing us atengramby@gmail.com.
  2. INFORMATION OBTAINED BY THIRD PARTIES

    To support and enhance the Service, we work with a variety of third party advertising networks, marketing analytics service providers and website analysis firms, such as Google, Facebook (collectively, "Third Party Advertising Service Providers"). These Third Party Advertising Service Providers collect and use non-personally identifiable information, such as your mobile device ID, about your visits to and use of the Website, as well as other websites in order to serve you with advertisements and content tailored to meet your preferences and likely interests or better understand ad effectiveness. Aggregate demographic and interest data will also be used for market research purposes.

    We use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page:https://tools.google.com/dlpage/gaoptout.

    You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative ("NAI") or who follow the DAA Self-Regulatory Principles for Online Behavioral Advertising using their respective opt-out tools. The NAI's opt-out tool can be found herehttp://www.networkadvertising.org/choices/ and the DAA's opt out tool can be found herehttp://www.aboutads.info/choices/.

    In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS' Advertising ID and Google Android's Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.

  3. USE OF INFORMATION OBTAINED BY ENGRAM

    Engram may occasionally send you service related and product change announcements through the general operation of the Service. We will send you reminder notifications to support the Engram teaching methodology by reinforcing the learning cadence and help maintain your learning streak. We process your data to help provide you with the Service and offer personalized features, to understand and improve our Service and to keep our Service safe and secure.

    Engram may use or share anonymous data collected through the Service, including Activity Data without limitation. As a business, it is critical that we perform our contract with you with the best service possible, and it is in our legitimate interests to perform these processing functions and to enable service e-mails by default to keep your data secure and provide our Service. You may opt out of any non-essential service e-mails at any time.

    We may also use your contact information to send you notifications regarding new services, offers and promotions offered by Engram if you affirmatively consent to receive such communications.

    When you register with Engram, some of your information is made public and available at engram.by/pl/your-username. This will include the data from your Engram Profile and Account (Name, Location, Bio, Username, User ID, Profile picture); your followers and the people you follow; and your learning progress (XP, Streak, Lingots, Daily Progress, Languages being learned, progress level, Crowns, Skills, Lessons undertaken, Lexemes and Strength). Tinycards decks you create are also public by default, but can be made visible to only you or to people you have shared a link with.


    Engram English Test When you take a test in the Engram English Test, we will use your computer's camera and microphone throughout the test to collect a Testing Video.

    We can process information in connection with the Engram English Test comprising given name(s), surname(s), date of birth, gender, native language, country, secondary school, self-reported test scores for other exams, application IDs, a picture or scan of a current, your Testing ID, Testing Video, and answers to questions as part of the testing and evaluation process in order:

    • To provide accurate testing results to Score Recipient(s) (as defined below)
    • To store and review the Testing Video recording to validate that you took the examination without improper assistance
    • To evaluate your performance on the Engram English Test, to report results and to evaluate the usefulness, accuracy and other aspects of the Engram English Test
    • For our research team to validate and improve the examination, in an anonymized format
    • To analyze audio recordings of verbal responses to improve our ability to understand the spoken languag

  4. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES

    Engram shares your personal data only when it is necessary to offer the Service, legally required, or permitted by you.

    We will provide personal data to hosting providers such as Amazon Web Services, search engine providers such as Google, analytics providers such as Crashlytics, and support providers such as ZenDesk.

    We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the Engram name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies.

    Engram will share the complete and accurate results of Engram English Tests with such institutions, including universities, potential employers, or other third parties, (collectively, "Score Recipients") as specified when you send your results after finishing a test or when you apply a coupon sponsored by the Score Recipient before starting a test. These results will include your test score, a video of the interview section of your test, and your written responses to certain parts of the test. We will also share your full name, date of birth, e-mail address, and the photo you take of yourself. We will never share examination results with any party without your approval, except that anonymized examination results will be used by Engram and its partners to improve the examination and for research and analysis. We will not share your Testing ID with any Score Recipients, except with your consent upon initiation of a dispute by a Score Recipient.

    If the ownership of all or substantially all of the Engram business, or individual business units or assets owned by Engram that are related to the Service, were to change, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain subject to this section.

    Engram will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service.

  5. DATA SUBJECT RIGHTS AND DATA RETENTION



    You have the following rights in relation to the personal data we hold about you, unless provided otherwise by local law:

    • To request access to, or erasure of, the personal data we hold about you.
    • To request us to restrict the processing of the personal data we hold about you.
    • To object to us processing personal data relating to you.
    • Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.
    • To export the personal data you have provided to Engram in a format that can be transferred electronically to a third party.
    • To delete your account with Engram by following the instructions available through the Service.
    Engram will retain your data until your account is deleted, after which point we will retain anonymous data collected through the Service, including Activity Data, which may be used by Engram and shared with third parties in any manner. Information associated with the Engram English Test, including examination results and your Testing Video, will be collectively deleted from your Engram account after five years have passed from the date you upload your test, but anonymized examination data, including your examination results and Testing Video, will be kept indefinitely by Engram to improve the examination and for research and analysis.

    Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.

  6. THIRD PARTY WEBSITES AND LINKS

    Please note that you may have cookies placed on your computer by third party websites that refer you to our Service. Although we do not share your personal data with these third party websites unless it is reasonably necessary to offer the Service, they may be able to link certain non-personally identifiable information we transfer to them with personal data they previously collected from you. Please review the privacy policies of each website you visit to better understand their privacy practices. In addition, Engram would like to inform you that anytime you click on links (including advertising banners), which take you to third party websites, you will be subject to the third parties' privacy policies.

    Our Services contain links to other sites operated by third parties. Engram does not control such other sites and is not responsible for their content, their privacy policies, or their use of personal data, including any personal or financial information collected by our third party payment processor to process payments for in-app purchases. Engram's inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.
  7. CHILDREN UNDER AGE OF DIGITAL CONSENT Engram do not provides features and services intended for use by children. To send us your request, you confirm that your age is over 16. If you believe we have collected personal information from a child, please contact us at engramby@gmail.com.
  8. LINKS

    The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave the Service to read the privacy statements of other websites that collect personally identifiable information. This Privacy Policy applies only to information collected by Engram via the Service.

  9. INFORMATION SECURITY

    Engram has implemented administrative and technical safeguards it believes are appropriate to protect the confidentiality, integrity and availability of your personal data, Testing ID, User Photo, access credentials, and Engram English Test results. However, given sufficient resources, a determined attacker could defeat those safeguards and may, as a result, gain access to the data we seek to protect.

  10. DO NOT TRACK

    The Service is not designed to respond to "do not track" signals sent by some browsers.

  11. CONTACT US

    Engram's headquarters are located at:
    OOO Engramby.
    Leninskaya str. 5/4, 12
    Mogilev, 212000
    Belarus
    e-mail: engramby@gmail. com


    Last revised on 30th August, 2018
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