Privacy Policy

Last updated on: [23.6.2021]

WEBSITE PRIVACY AND COOKIES POLICY

The present privacy policy (the « Privacy Policy ») describes the conditions under which Make it Native vGmbH, registered with the Luxembourg Trade and Companies Register under number B253022 and having its registered office at L-6975 Rameldange, 19, Am Bounert (“we” or “English Optixx”) collects and processes personal data pertaining to the visitors (the «Visitors » or « you») and registered users (« the Users » or « you ») of the website located at the following URL:  https://englishoptixx.eu  (the « Website »).

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible on the Website. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes on the Website or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your personal data.

What personal data does English Optixx process?

Personal data means any information relating to an identified or identifiable natural person.

With the exception of the data mentioned in the provision “Cookies” below, we do not collect personal data other than those you voluntarily provide us with when you register on the Website, express an interest in obtaining information about us or our services, when you participate in activities on the Website or otherwise when you contact us.

The personal data we collect may include your name, first name, email address, phone number and/or payment data, and any other personal data you may provide us with.

For what purposes are the personal data collected and processed by English Optixx?

Personal data collected by English Optixx (the « Personal Data ») will be processed by English Optixx for the following purposes:

    • communicate with you and provide you with the information requested;
    • validate your registration and give you access to the services offered on the Website;
    • fulfil and manage your orders;
    • request feedback on our services or about your use of the Website;
    • processing of access, rectification and opposition requests, and other rights with respect to Personal Data;
    • claims and litigation management;
    • keeping our Website safe and secure (fraud monitoring and prevention purposes);
    • production of statistics to enhance the Website performance;
    • deliver targeted advertising based on Visitors/Users’ interests and preferences.

The processing of the Personal Data is necessary for English Optixx to provide Visitors and Users with the services they requested, as well as to enable English Optixx to fulfil its legal obligations. This processing is also necessary for the legitimate interest of English Optixx as it enable it to protect its Website, promote its activities and improve the navigation experience on the Website.

These purposes constitute the legal basis for the data processing carried out by English Optixx.

Who are the data recipients?

Personal Data will be processed internally by duly authorized persons, within the limits of their respective responsibilities. They may also be communicated to the following third-parties:

    • administrative and judicial authorities, such as tax authorities, to enable English Optixx to fulfill its legal obligations in this regard;
    • English Optixx data processors (including IT service providers hosting the data) and external services providers (such as web designers, communication agencies, legal advisers, etc.), to the strictest extent necessary and subject to the existence of contractual guarantees to ensure the security and confidentiality of the data.

How does English Optixx ensure the security of Personal Data?

Personal Data collected by English Optixx will be processed by English Optixx as a data controller, in compliance with the applicable data protection legislation (i.e. EU General Data Protection Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (known as “GDPR”) and Luxembourg law dated 1st August 2018 on the organisation of the National Data Protection Commission and the general data protection framework, as well as any successor texts). English Optixx undertakes to implement technical and organizational security measures to ensure the protection of Personal Data against the risks associated with the use of information systems. English Optixx follows generally accepted security standards to help protect Visitors’ and Users’ Personal Data. However, no method of transmission over the Internet, or of electronic storage, is 100% secure. Therefore, English Optixx cannot guarantee the absolute security of the Personal Data.

English Optixx maintains any Users’ Personal Data on servers in a primary data centre located in the European Union.  For reasons of data redundancy and operational resilience, a copy of the data is maintained on servers in one or more secondary data centres, which can be located outside the European Union.

User’s Personal Data is kept until termination of his/her personal account, for whatever reason, as well as for the applicable statutory limitation period. Contact details are retained for the time necessary to process the request and to establish that we have responded to it. After a period of one year from the termination date of the User’s personal account or our response to your request, Personal Data will be archived on a separate computer medium and accessible only, if necessary, by a limited number of persons specifically authorized to do so. For more information on the retention period of your Personal Data, you can contact us at the contact address mentioned below.

What are Visitors’ and Users’ rights?

In accordance with the applicable data protection legislation, and subject to the limits provided by the applicable rules, Visitors and Users are entitled to obtain, free of charge:

    • access to the Personal Data pertaining to them;
    • confirmation that their Personal Data are or are not being processed;
    • information concerning at least the purposes of the processing, the categories of data to which the processing relates and the recipients or categories of recipients to whom the data are communicated; and
    • communication, in an intelligible form, of the data being processed.

Subject to the limits provided by the applicable rules, Visitors and Users may also have inaccurate or incomplete Personal Data rectified, object to the collection and processing of such data on grounds relating to their particular situation, request the erasure of all or part of the data or a restriction of the processing, and make use of their right to data portability. However, English Optixx can only respond favourably to the request for erasure within certain limits, in particular those related to its legal obligations as a data controller.

These rights may be exercised in writing, by email addressed to dpo@englishoptixx.eu. English Optixx reserves the right to request a scan / hard copy of your ID so that we can verify your identity before processing your request. Users can also rectify their Personal Data via their personal account.

You can withdraw your consent to the sending of newsletters at any time, either by following the instructions mentioned on the newsletter or by sending an email to the above-mentioned address.

For more information on how Personal Data are collected and processed by English Optixx or on how to exercise any of the aforementioned rights, you can contact us at the above-mentioned address.

In the event of a breach of the data protection rules, you may also lodge a complaint before a supervisory authority such as the National Commission for Data Protection (CNPD), 1 Avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette.

What are cookies?

The Website uses “cookies” and similar tools. “Cookies” are small text files left on the computer used to visit the Website. Cookies collect information about your operating system, such as your IP address (Internet Protocol), browser and operating system, the date and time of the visit, the registration information or the User’s navigational history and preferences.

Some cookies are necessary for you to benefit from the full functionality of the Website, others to prevent the fraudulent use of login information and to protect Users’ Personal Data against unauthorized third-parties. Other cookies are used to allow and facilitate navigation on the Website notably by memorising the Users’ navigation preferences or to help them avoiding having to re-enter personal information.

These cookies do not require your consent prior to their deposit. You may nevertheless refuse them by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of the Website.

Other cookies used by English Optixx on the Website require your prior consent, i.e.:

    • cookies used for statistical analysis and management purposes traffic in order to determine which are the most visited pages, the most used links, or how visitors navigate from one page to another (Google Analytics, Hotjar cookies). These cookies are used to improve the ergonomics of the Website and the interest of its services, and to allow us to develop new services or functionalities ; and
    • cookies allowing to share the content of the Website with other people via social media (i.e. Facebook and its partners – Facebook Pixel cookies) ; and
    • cookies used for targeted advertising purposes. These cookies enable us to offer you advertising tailored to your interests.

English Optixx may use the services of third-parties for analytics purposes, such as Google Analytics or Facebook Pixel. Google Analytics and Facebook Pixel use cookies. The use of these cookies is subject to Google Inc. and Facebook’s Privacy Policy. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google Inc. and Facebook. Their servers may be located outside of the European Union. Google Inc. will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity to our attention, and providing other services relating to Website activity and Internet usage. Google Inc. may also transfer this information to third-parties where required to do so by law, or where such third-parties process the information on Google Inc.’s behalf. Google Inc. will not associate your IP address with any other data held by Google Inc. Facebook will notably use the cookies to provide you with advertising related to us.

You can withdraw your consent to the use of cookies at any time by sending us an email to the following address: dpo@englishoptixx.eu or by configuring your browser setting to decline cookies.

Cookies are deleted after a period of 13 months from their date of deposit in the terminal equipment of the Visitor/User.

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