Parlo (London) Limited (collectively referred to herein as “Parlo”, “we”, “our”, or “us) recognises the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users”, “you”, or “your”) who visit our websites. This Privacy Policy applies to data collection by Parlo and shall apply to your use of the website, www.parlo.london and other Parlo-related sites, applications, software, communications, capabilities and services (“Services”) accessible on or by any top-level Parlo domain owned by us (each, a “App” and collectively the “Sites”), but excluding services that state that they are offered under a different privacy policy.

When this Privacy Policy Applies

Our Privacy Policy applies to all of the services offered by Parlo, and services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Terms of Use

By accessing or using the App in any manner, you also agree to be bound by Parlo’s Terms of Use (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.

Information We Collect

We collect information, including personal information, to provide better services to all our Users. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.

The personal information which we collect includes, but is not limited to, the following circumstances and data elements:[GU2] 

1. 1. If you express an interest in obtaining additional information about our services, request customer support, use our “Contact Us” or similar features, register to use our Sites or Services, or download certain content, we may require that you provide to us your contact information, such as your name, organization , phone number, or email address, and in some instances, you may elect to provide us with location and address information;

1. 1. If you report a problem or have a question about our Services, you may provide us with contact information, such as a phone number or email address;

1. 1. If you desire to pay for bills via our websites, we may require that you provide to us your financial and billing information, such as billing name and address, credit card number or bank account information; That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn’t ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the United Kingdom, to detect fraudulent credit card transactions, and to print on your invoices.

1. 1. If you use and interact with our app or emails, we automatically collect information about your device and your usage of our app or emails through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Information (please see the “What device and usage data we process” section, below);

1. 1. If you use and interact with our services, we automatically collect information about your device and your usage of our services, through log files and other technologies, some of which may qualify as Personal Information;

1. 1. If you voluntarily submit certain information to our services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request; and

If you believe that your Personal Information has been provided to us improperly or to exercise otherwise your rights relating to your Personal Information, please contact us by using the information set out in the “How to Contact Us” section below.[GU3] 

Brazil LGPD

This Privacy Policy is in compliance with the Brazilian General Data Protection Law (LGPD) and other applicable data protection laws. If you are a resident of Brazil, you have additional rights under the LGPD, including the right to request access, correction, or deletion of your personal information. To exercise these rights, please contact us at privacy@parlo.london .

How We Use Information We Collect

We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

• • To present, operate or improve the App[GU4]  and Services, including analysis of App activity;
    • To inform you about Services and products available from Parlo;
    • To authorise access to our Apps and Services;
    • To customize or tailor your experience of the Services;
    • To administer content, promotion, surveys, or other App features;
    • To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, and other offers or promotions, and to deliver pertinent emails;
    • To improve our customer service.
    • To respond to and support users regarding their use of the Sites and Services.
    • To comply with all applicable legal requirements.
    • • To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users.

We use the information we collect from our App to provide, maintain, and improve them, to develop new services, and to protect our company and our Users.

We use information collected from cookies and other technologies, to improve your User experience and the overall quality of our services. We may use your Personal Information to see which web pages you visit at our App, which web App you visited before coming to our App, and where you go after you leave our App. We can then develop statistics that help us understand how our visitors use our App and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Your Rights With Respect to Your Information

You may have heard about the General Data Protection Regulation (“GDPR”) in Europe. GDPR gives people under its protection certain rights with respect to their personal information collected by us on the App. Accordingly, Parlo recognises and will comply with GDPR and those rights, except as limited by applicable law. The rights under GDPR include:

• • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.

• • Right to Correction. This is your right to request correction of your personal information.

• • Right to Erasure. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession (also known as the “Right to be forgotten”). However, if applicable law requires us to comply with your request to delete your information, fulfillment of your request may prevent you from using Parlo services and may result in closing your account.

• • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.

• • Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed.

• • Right to Object. This is your right, in certain situations, to object to how or why your personal information is processed.

• • Right to Portability. This is your right to receive the personal information we have about you and the right to transmit it to another party.

• • Right to not be subject to Automated Decision-Making. This is your right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable European law, or is based on your explicit consent.

Many of these rights can be exercised by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at privacy@parlo.london

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

Processors we use

As part of the services we provide, and only to the extent necessary, we may use certain third party processors to process some or all of your personal information. For identification of these processors, and where they are located, We have signed appropriate data processing contracts that comply with GDPR with each processor.

How We Protect Personal Information

Parlo maintains administrative, technical and physical safeguards designed to protect the user’s Personal Information and other information against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. For example, we use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.

Cookies and Other Technologies

We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party analytics partners include Google and similar partners.

The technologies we use for this automatic data collection may include:

1. 1. Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services. For more information about our use of cookies, including details on how to opt-out of certain cookies.
   2. Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
   3. Clickstream data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.

Third Parties

You understand that Parlo uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to provide you with our services. A current list of vendors is available upon request.

Data Deletion

When you cancel your account, you can request to get your data deleted on privacy@parlo.london. Parlo furthermore reserves the right to delete your data 60 days after you have canceledcancelled your account. This information can not be recovered once it has been permanently deleted.

When transferring personal data from the EU

The GDPR requires that any data transferred out of the EU must be treated with the same level of protection that the EU privacy laws grant. The privacy laws of the United Kingdom generally do not meet that requirement. That is why since GDPR went into effect, Parlo has offered a data processing addendum and voluntarily participated in the EU-US Privacy Shield Framework as well as the Swiss-US Privacy Shield Framework.

We have incorporated a Data Processing Addendum to our Terms of Service that is in effect when the GDPR applies to your use of Parlo Services to process Customer Data as defined in the DPA. You can find the DPA linked within clause 5 of the Security and Privacy section in the Terms. The DPA includes the European Commission’s Standard Contractual Clauses to extend GDPR privacy principles, rights, and obligations everywhere personal data is processed. Furthermore to aid our customers, we have provided summary of GDPR in our Privacy Regulation Reference.

To get an executed copy of the Data Processing Addendum, you should sign a copy following the instructions listed in our Terms of Service and Privacy Regulation Reference. Regardless of whether you execute or not, we protect and secure your data to the high standards set out in the addendum.

There are also a few ad-hoc cases where EU personal data may be transferred to the US related to Parlo, Inc. operations. For instance, if someone in the US comments on our company blog or a customer participates in one of our infrequent surveys or someone applies to one of our open positions or buys swag on our company shop. Such transfers are only occasional and transferred under the Article 49(1)(b) derogation under GDPR.

EU-US and Swiss-US Privacy Shield Framework

The EU-US Privacy Shield is an agreement between certain European jurisdictions and the United Kingdom that up until July 16, 2020, allowed for the transfer of personal data from the EU to the US. Participation in the Privacy Shield program is voluntary. The Swiss-US Privacy Shield is a similar program for data transferred to the US from Switzerland that was in effect until September 8, 2020.

Parlo complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United Kingdom, respectively. Parlo has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Parlo is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regard to the Privacy Shield Frameworks.

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United Kingdom. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United Kingdom under Privacy Shield, should direct their query to privacy@Parlo.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@Parlo.com.

Law Enforcement

While we may be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, Parlo won’t otherwise hand your data over to law enforcement unless a court order says we have to. We flat-out reject such other requests from local and federal law enforcement when they seek data without a court order. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. We will provide delayed notice if the legal prohibition is lifted.

Parlo’s accountability for personal data that it receives in the United Kingdom under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Parlo remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Parlo proves that it is not responsible for the event giving rise to the damage.

EU-US and Swiss-US Privacy Complaints

In compliance with the Privacy Shield Principles, Parlo commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United Kingdom pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact Parlo by email at privacy@parlo.london or via post at:

Parlo (London) Limited , C/O The Education Group (London) Level 18,
40 Bank Street
London, E14 5NR

Parlo has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints for more information and to file a complaint.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Location of App and Data

This App is operated in the United Kingdom. If you are located in the European Union or elsewhere outside of the United Kingdom, please be aware that any information you provide to us will be transferred to the United Kingdom. By using our App, participating in any of our services and/or providing us with your information, you consent to this transfer.

Changes & Questions

Parlo may update this policy once in a blue moon — we’ll notify you about significant changes by emailing the account owner or by placing a prominent notice on our App.

You can access, change or delete your personal information at any time by contacting us at privacy@parlo.london, or by mail at Parlo (London) Limited , C/O The Education Group (London) Level 18, 40 Bank Street, London, E14 5NR