GDPR

I. Introductory Provisions

1. These Terms and Conditions apply to the purchase and use of the Accent Artisan educational application license at www.accentartisan.com (hereinafter referred to as the "Application") operated by Accent Artisan s.r.o., ID: 03282601 (hereinafter referred to as the "Operator"), contact email: support@accentartisan.com.
2. A user of the Application is any individual or legal entity that creates a user account (hereinafter referred to as "User"). Creating a user account consists of entering an email address, username and password.
3. The Application is a web-based service primarily intended to facilitate foreign language learning through freely available publications.
4. The Operator develops and provides its customers with a web-based application for learning foreign languages online. The Application can be accessed via the web interface at www.accentartisan.com (hereinafter referred to as the “application”).
5. We may change or update this Privacy Policy on an ongoing basis. We will always inform you by email 30 days before these changes take effect. If you do not agree to a change, you have the right to terminate the Service agreement without penalty.
6. This Privacy Policy describes how we treat students' personal data, while complying with the Regulation (EU) 2016/679 of the European Parliament and of the Council, the General Data Protection Regulation, also known as the GDPR (hereinafter "GDPR").

II. Accentartisan.com is the Administrator of Personal Data

1. By granting approval in the application we begin to process your personal information. We are therefore a personal data controller. You may also collect personal information by browsing the site. We always process only personal information obtained from you only.
2. We process this type of personal data within the purview of Article 4 (1) of the GDPR:
   1. email address
   2. IP addresses from devices used to log into the application
   3. billing information if a subscription is paid
3. We process the aforementioned personal data for the purpose of the contract fulfilment under Article 6 (1) (a). b) GDPR, which stands for the provision of services by making the application accessible, informing about interruption of operation due to scheduled technical maintenance of software and hardware, answering your inquiries through customer support, sending support learning materials, sending vouchers for conversations with native speakers, and informing about changes in the application or its usage.
4. In order to protect servers from attacks and user accounts from being misused by third parties within the meaning of Article 6 (1) (a). f) GDPR
5. In order to keep you informed about what's new at accentartisan.com, what improvements and innovations we are plan, how we develop related products so that you always have an up-to-date and accurate overview of the application’s status.
6. We always store email communications with customer support for 12 months so that we can provide you with better service and help you more effectively in case of recurring problems with the application.
7. We process your personal data for the duration of the contract i.e. for the duration of the user account, but not longer than 10 years. Upon termination, in the event of a dispute between the company and a User that is related to the Terms of Use of the accentartisan.com application or this Privacy Policy for in the matter of compensation.
8. We use the following providers for the provision of services, which operate in accordance with European data protection standards. You agree that we may pass on your personal data to them for the purposes described above. Amazon Web Services, Amazon cloud environment (all data in the application), SendInBlue - for sending all emails, Google Analytics services, Smartsupp.com s.r.o. Tax ID: CZ03668681 for communication with accentartisan.com.

III. Processing Data Based on Your Consent

1. We may continue to process your data as stated above if you give us voluntary and informed consent within the meaning of Article 6, 1 let. a GDPR. Use of the app is never tied to providing consent. However, it is advisable to give consent at least to the processing of data directly related to the functioning of application.
2. The consent option is most commonly presented in the form of checkbox, e-mail or you give it to us by making an active step required in an e-mail (by clicking a button).
3. You may grant us your consent for various purposes individually.
4. We may process the personal data on the basis of consent for the duration of the provision of services i.e. for the duration of a user account’s existence. The processing period may be shorter if you withdraw your consent.

IV. Revocation of Consent

1. You may withdraw your consent to processing of your personal data under the previous paragraph at any time in your user account (profile section) or by sending a request to support@accentartisan.com.
2. If you do not want to receive emails from accentartisan.com, you can always unsubscribe from the subscription by clicking on the footer of each email. Unfortunately, this is not possible for e-mails that are necessary for running the application (e.g. cashback for italki). However, you can still opt out of this in your accentartisan.com profile.
3. We always regard a withdrawal of subscription as a withdrawal of consent under Article 7 (3) of the GDPR or a filing of an objection under Article 21 of the GDPR in the case of e-mails we use to inform you of related accentartisan.com services and products.
4. The consent given under the above provided paragraphs also applies to companies authorized by the Operator.

V. Processing Contract

1. Additionally, the User always enters into a free personal data processing agreement with the company, the content of which is determined by the following provisions under Article 28 (3) GDPR.
2. Users provide the application with the following personal information: email (login into the application), optionally also name or surname and in case of purchase billing information required to issue a tax document.
3. The Company undertakes to process personal data solely for the purpose of storing and ensuring the transmission of data to the repository and following the instructions of the User.
4. The Company is obliged to arrange a sub-processing relationship and to authorize Amazon, or other sub-processors, if necessary, for the functionality of the application to process.
5. The Company ensures the functionality and operation of the application, undertakes its regular maintenance and makes it available to the User.
6. The company's maintenance and service operations are purely incidental based on error correction need and system maintenance.
7. The User agrees to the involvement of other operators, Amazon in particular, whose involvement consists of storing data on cloud servers, and self-employed persons, if necessary, for ensuring the security of the application's functionality. No other operator shall be involved in the processing without the User's consent or without entering into a contract that obliges the sub-processor to substantially similar obligations with respect to the processing of personal data to which the company is bound.
8. In the event that the company intends to involve another operator in the processing, the company shall inform the User. All instructions for other operators will be in accordance with the personal data protection legislation. The company will always take care of the appropriate selection of operators.
9. The company undertakes to ensure that other operators or persons involved in the processing under the authority of the company always meet a high standard of trust by, in particular, entering into a confidentiality agreement.
10. The company undertakes to secure personal data in accordance with Article 32 of the GDPR. The parties declare that at the date of the Agreement taking effect the company has taken technical measures to ensure the security of personal data by encrypting data transmission using the HTTPS protocol.
11. The User acknowledges that he/she has full control and responsibility for the data he/she brings to the application. The requirement of accuracy, proportionality, time constraint and minimization of stored data must be fulfilled by the User. If the User deletes the data, they are deleted. The company does not make copies or otherwise backs up user data, nor does it interfere with the transfer of data between the User and Amazon.
12. The parties shall provide mutual assistance in the event of suspected misuse of personal data of data subjects. The parties shall do the maximum to take measures necessary to prevent the risk of misuse of personal data.
13. Upon the termination of this Agreement, i.e. the termination of the user account, all entered data are deleted within 7 days. The User always has the option to export the stored data and save it on his/her own storage to avoid an irrevocable loss of data. Neither the company nor the authorized operators are liable to the User for any damage resulting from the loss of data entered into the application after 7 days from the termination of the user account.
14. This Agreement also includes provisions of the Privacy Policy that follow.

Other Provisions on Personal Data Protection

1. We do not process personal data of minors nor special categories of personal data like the so-called sensitive personal data, within the meaning of Article 9 of the GDPR.
2. Operators entrusted with processing must comply with a high standard of protection and shall always handle the data within the limits of these policies.
3. We may collect and use technical data and relevant information through the website, including, but not limited to, technical information about the User’s device, system, application software and peripherals that are regularly collected with the aim to facilitate the provision of software updates, product support, and other related services. applications. We may use this information as long as it is in a form that does not identify the User personally, to improve our products or to provide services or technologies for the necessary time period.
4. Upon termination of service or termination of data processing grounds, we dispose of personal information.
5. We always make every effort to prevent the unauthorized processing of personal data by others, but we are not liable to the User or to other subjects for any harm caused by unauthorized processing of personal data by a third party.
6. All the web application’s data is stored on Amazon servers in Germany. Microsoft servers are located in Frankfurt am Main. No data sent by cloud applications leave the European Union. User-embedded data is not duplicated, checked, or modified.
7. You nor we consider emails sent to you by us as unsolicited commercial communications within the meaning of law 40/1995 on advertising and law 480/2004 on certain services of information society.
8. In the event that we become aware of any security risks associated with your personal data, we will notify you without undue delay.
9. We undertake to provide the User with synergies and legal assistance in the recovery of compensation from responsible Operators in the event of a loss related to personal data or other information leak. However, the company itself is not responsible for the faults of its authorized Operators.
10. Cookies in accordance with Cookies may be stored on your device through our website.
11. You acknowledge that the personal data you provided are true, accurate, and that it is solely related to your person or that you have provided information that has not infringed upon the rights of third parties. Always notify us at our request or without request of changes in your personal data so that only current and complete data can be processed. If we ask you to do so, always provide us with up-to-date and truthful information.
12. Personal data shall be processed electronically in a non-automated manner. Anonymized personal data can also be processed automatically. Data subjects shall not be subject to an individual automated decision within the meaning of Article 22 of the GDPR.

VII. Personal Data Management Support

1. If you believe that we are processing your personal data in violation of your private and personal life or in violation of the law, especially if the personal data are inaccurate with regard to the purpose of their processing, you can always ask us for an explanation, you can object to processing of the data for the purpose of a legitimate concern or request the provision of information on the extent or manner of processing of your personal data at support@accentartisan.com. We shall provide you with the data within a reasonable period (max. 30 days). You can also contact the Privacy Office directly.

VIII. Final Provisions

1. All legal relationships arising under or in connection with the processing of personal data are governed by the laws of the Czech Republic regardless of where they were accessed from. Czech courts, which apply Czech law, are competent to resolve any possible disputes arising in connection with the protection of privacy between the user and the company.
2. This Privacy Policy takes effect on August 1, 2019.