This Privacy policy concerns the principles of personal data processing within the internet website eTutor.eu (hereinafter referred to as website or platform) and services provided by LangMedia sp. z o.o.
The administrator of Users’ personal data (hereinafter referred to as Service Provider) is:
For more information, you can contact the Data Protection Officer we have designated at
. Correspondence address: Data Protection Officer LangMedia sp. z o.o.,
ul. Rapackiego 5, 53-021 Breslavia, POLONIA.
In this Privacy Policy GDPR refers to the Regulation (EU) 2016/679 of the European Parliament and of the Council 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, and repealing Directive 95/46/EC (General Data Protection Regulation).
Employees of the Service Provider are authorised to process personal data, participate in training in accordance with the internal Security Policy and sign statements on maintaining personal data confidentiality.
All servers on which personal data are stored are located within the European Union territory.
We use technical and cryptographic security solutions to protect the processed data against unauthorised access, modification, or removal. We regularly install security patches on our servers.
Due to the use of artificial intelligence (AI) algorithms based on external models such as GPT-4 by the Website to conduct conversations with the User during lessons (quests), the Service Provider ensures that any data provided by the User into the chat window and transmitted via the API is anonymized or pseudonymized whenever possible, in order to minimize the risk of identifying data subjects.
For security and privacy protection reasons, Users are strictly advised not to share any personal data or information that may lead to the identification of natural persons during the course of the conversation.
In the case of payment transactions, the data (such as the card number) are not processed on our servers, but only on the servers of the authorised companies handling payments, which make use of the security solutions compliant with the legal requirements and the regulations of the organisations that issue payment cards. These companies provide us with the information on the status of particular payment transactions.
By paying via PayPal, payment details are transferred to Paypal (Europa) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. The details are transferred pursuant to art. 6 sec. 1 letter b of GDPR and only to the extent necessary to process payments. You can find more information about data protection in the PayPal privacy policy at: www.paypal.com/pl/webapps/mpp/ua/privacy-full
By paying via PayU, payment details are transferred to PayU S.A. with its registered office in Poznań (60-166 Poznań, ul. Grunwaldzka 182), entered in the Register of Entrepreneurs kept by the District Court Poznań – Nowe Miasto and Wilda in Poznań, 8th Commercial Department of the National Court Register under KRS number 0000274399, NIP number: 779-23-08-495, Polish payment services provider monitored by the Polish Financial Supervision Authority, entered into the register of Polish payment services providers kept by the Polish Financial Supervision Authority under the number IP1/2012. The details are transferred pursuant to art. 6 sec. 1 letter b of GDPR and only to the extent necessary to process payments. You can find more information about data protection in the PayU privacy policy at: https://poland.payu.com/zasady-prywatnosci-w-payu/
We collect the data related to you whenever you use our websites and applications, create an account on one of our websites, subscribe to the newsletter, participate in our contests or contact us.
When an account is created, we ask you to provide the following information:
The provision of this data is voluntary, but necessary to conclude an agreement to maintain your account on the platform and provide access to paid courses.
When registering an account for identification purposes on the eTutor website, a login name, which is the User's individual name, is automatically assigned by the Service Provider or entered by the User. After registration, the login name may be changed once by the User (except for privileged users).
If you have a privileged account and access to the administrator panel in eTutor.eu, you must also give your phone number to which the Service Provider will send a text message with a code to verify the person using the account.
In some cases, with the User’s prior consent, an account is created on the basis of the data provided to us by the User’s employer or other entity paying for the course on behalf of the User.
When the account has been created, the User may add additional information to his or her profile:
We allow you to log in to the website via external services such as Facebook, Google and Apple. In this case, we will receive basic data from your account, such as your name and email address or email alias in the case of Apple. We do not obtain data such as passwords, photos or other data from external services.
When you log in to the website or create an account using an external website, such as Facebook, we collect your account’s ID, first name, surname, e-mail address and gender.
The Administrator allows you to log in to the website via:
When you use our services, we collect and process the following data:
Private messages exchanged between the Users are treated as confidential and they are not disclosed to third parties without the User’s consent, except for the situation where such disclosure is required under the relevant provisions of law.
The website offers the function of inviting other people, who have not created an account on our website yet, where the friends’ e-mail addresses can be provided in order to send invitations recommending our services to them. The provided addresses are used to send an invitation on your behalf.
When the websites are used, the following information may be recorded each time after sending a request to the Service Provider’s server:
In order for the eTutor.eu website to function properly, it uses cookies.
Cookies are files downloaded to your device (computer or mobile device) to store data, which can then be updated and downloaded by the entity responsible for their installation.
We classify the cookies used on our site into:
and others (optional), which we use only if you agree:
In addition, the above-mentioned cookies can be classified according to their storage time:
If you limit the application of the listed mechanisms, it may affect the functionalities available on the Website. Using the appropriate browser settings, you can also delete previously saved data.
During your visit to our website, a banner will be displayed with information about the use of cookies. If you select the “Enable all” option, it will mean that you accept all the cookies on our website and confirm that you have read the information about these cookies and the purposes of their use, as well as the cases in which the data collected with the help of these cookies is transferred to our partners.
In the case of essential cookies, your consent is not required, as cookies of this kind ensure the full and uninterrupted functioning of our website.
If you do not want our cookies to be stored on your device, you can select the “Reject all” option. By selecting this option, you will reject all but essential cookies that we use on our website.
We also use pixel tags, which are elements placed, for example, in an email message or in the code of a website, that allow us to monitor activity, such as opening an email or viewing a particular page. Pixel tags are often used in conjunction with cookies.
The providers of some Cookies are third parties that provide services to the website, which is clearly indicated above the name of the cookies.
The list of these entities and tools can change, but they include, among others:
Google Ads – a remarketing tool from Google LCC that allows to display personalized ads of the eTutor.eu service, more information:
https://policies.google.com/technologies/ads?hl=pl,
Google Analytics – a tool that collects information about the visits to the eTutor.eu website, the subpages viewed and the time the
User spent on the website, more information:
https://www.google.com/analytics/terms/
Facebook Pixel – a tool that allows to target personalized ads to Facebook Users, more information:
https://www.facebook.com/privacy/explanation,
Hotjar – a tool that allows the Administrator to conduct analysis of the User's activity on the website, including collecting data about
the behaviour and preferences of Users on our website, more information:
https://www.hotjar.com/privacy/
HubSpot - a marketing automation and contact management tool that monitors and reports on your online activity, more information:
https://legal.hubspot.com/privacy-policy
Pinterest Ads – a marketing automation and contact management tool that monitors and reports on your online activity, more information: https://policy.pinterest.com/pl/privacy-policy
TikTok Ads – the remarketing tool from TikTok Information Technologies UK Ltd, which allows to display personalized ads of eTutor.eu service, more information: https://ads.tiktok.com/i18n/official/policy/privacy.
Bing Ads (now known as Microsoft Advertising) - a remarketing tool from Microsoft, which allows to display personalized ads for the eTutor.eu service, more information: https://privacy.microsoft.com/pl-pl/privacystatement
We process your personal data only if we have legal basis to do so.
Data processing purposes on the basis of art. 6 sec. 1 point a of the GDPR (your consent):
The purposes of processing personal data on the basis of art. 6 sec. 1 point b of the GDPR (processing required to conclude an agreement that you are a party hereto or to take actions upon your request prior to conclusion of the agreement):
The purposes of processing personal data on the basis of art. 6 sec. 1 point c of the GDPR (fulfilling our legal obligations) are as follows:
The purposes of processing personal data on the basis of art. 6 sec. 1 point f of the GDPR (our legitimate interest) are as follows:
We use the collected data also for profiling the Users, i.e. processing it in an automated way to anticipate the behaviour and personal preferences of the Users. However, it does not cause any legal effects towards you and does not have any relevant impact on your situation.
We entrust the processing of your personal data to:
In case of the courses paid for through another company or an organization (for instance your employer) we transfer the personal data of the course Users for the purpose of billing (first name, surname, e-mail address), and in case of some of our customers, with your consent, also for the purpose of monitoring your learning progress. Expressing such consent may be a condition to cover the costs of your course by an external entity.
We enter into appropriate contracts with each entity to which we entrust the processing of your data to ensure data protection in accordance with the requirements of the GDPR.
We use services of the suppliers from different countries, including the suppliers with their registered offices located outside the European Union (for example in the USA). Legal regulations related to personal data protection in these countries are different from the regulations applied in the EU. In such cases, the Controller ensures an adequate level of data protection by applying the safeguards provided for in the GDPR. We may transfer your personal data to:
⎯ countries for which the European Commission has issued decisions on the adequacy of personal data protection without the need to meet additional requirements;
⎯ other countries on the basis of Standard Contractual Clauses with additional safeguards (technical and legal) or Binding Corporate Rules or on the basis of Article 49(1)(c) of the GDPR, if the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the Controller and a User outside the EEA. Examples of such service providers as of the date of this privacy policy are Amazon Web Services based in the USA, Google Inc. based in the USA, Facebook Inc. based in the USA, and Open AI based in the USA.
Such suppliers, as of the date of this privacy policy, include Amazon Web Services with its registered office in the USA, Google Inc. with its registered office in the USA, Facebook Inc. with its registered office in the USA, and Open AI based in the USA.
In relation to the processing of your personal data, you are entitled to request:
The ability to exercise the abovementioned rights may depend on the legal basis for processing your personal data by us and on the purpose for processing your personal data. Please send the applications related to the processing of personal data by e-mail or by post.
You can view or modify most of the personal data related to your account in Account settings. There is also a functionality which enables you to request removal of your account.
In order to authorise the submitted applications related to personal data our employee may also ask you to provide additional information to confirm the identity of the person submitting the application.
You have the right to withdraw your consent to processing personal data at any time. The withdrawal of consent does not affect the lawfulness of processing your personal data based on consent before its withdrawal.
You also have the right to withdraw your consent to a specific channel of communication related to direct marketing at any time, according to the provisions of the Electronic Communications Act. You can withdraw your consent to receive marketing communications from us at any time via the email preference page in Account Settings by clicking on the resignation link provided in an email message sent to you or by sending such information to the email address: ayuda@es.etutor.eu.
| Data Type | Storage period | Legal basis |
|---|---|---|
| User identification data | For the entire period of activity of the User's account on the Website, Mobile Application + 2 years after its cessation | Performance of the contract (Article 6(1)(b) GDPR) and the Administrator's legitimate interest in the form of handling complaints, pursuing or defending against claims (Article 6(1)(f) GDPR) |
| Activity history on the Website (course progress, test results) | For the entire period of activity of the User's account on the Mobile Application Service + 2 years after its cessation | Performance of the contract (Article 6(1)(b) GDPR) and the Administrator's legitimate interest in the form of handling complaints, pursuing or defending against claims (Article 6(1)(f) GDPR) |
| Data processed during the User’s conversation with the artificial intelligence algorithm in the course of lessons (quests) | For a period of 30 days | Performance of a contract (Article 6(1)(b) GDPR) |
| Data related to courses ordered by the Ordering Party | For the entire period of activity of the User's account on the Website, Mobile Application + 2 years after its cessation | Legal obligations (Article 6(1)(c) GDPR) arising from tax or accounting legislation, as well as the Administrator's legitimate interest - performance of the contract with the Ordering Party (Article 6(1)(f) GDPR) |
| Server logs | Up to 6 months | Legitimate interest of the Administrator - ensuring security (Art. 6(1)(f) GDPR) |
| Technical data (IP, device) | For the entire period of activity of the User's account on the Website, Mobile Application + 2 years after its cessation | Legitimate interest of the Administrator - ensuring security (Art. 6(1)(f) GDPR) |
| Improving the quality of the service and user experience | For the duration of the analysis of user activity or until you express an effective objection | Legitimate interest of the administrator (Article 6(1)(f) GDPR) consisting in conducting analyses of User activity on the Website, Mobile Application, as well as User preferences in order to improve the functionalities used |
| Development of new functionalities | For the period of active use or until you delete your account from the Website, Mobile Application or until you express an effective objection | Legitimate interest of the controller (Article 6(1)(f) GDPR) to develop and improve the services provided |
| Satisfaction survey | For the period of active use or until you delete your account from the Website, Mobile Application or until you express an effective objection | The legitimate interest of the controller (Article 6(1)(f) GDPR) to improve the quality of the services provided |
| Data processed on the basis of consent | Until consent is withdrawn | User consent (art. 6(1)(a) GDPR) |
| Sending direct marketing messages via email, push notifications | Until you withdraw your consent to receive communications or information (under the provisions of the Electronic Services Act or telecommunications law) | In relation to your consent to a particular marketing communication channel |
| To enable you to participate in a competition or promotional action (which are not in the nature of a public promise) | Until the end of the competition or promotional action | Necessity of the processing for the performance of the contract (Article 6(1)(b) GDPR) |
| To enable participation in a competition or promotional action (which are in the nature of a public promise) | Until the end of the competition or promotional action | Legitimate interest of the controller (Article 6(1)(f) GDPR) to fulfil obligations arising from making a public promise, organising competitions or similar actions |
| Fulfilment of tax, legal and accounting obligations | 6 years or for the period specified in mandatory legal provisions | Legal obligation (Art. 6(1)(c) GDPR) |
If you have any objections to the way we process your personal data, please contact us first. You are also entitled to make a complaint to the supervisory authority:
Urząd Ochrony Danych Osobowych (Personal Data Protection Office)
ul. Stawki 2
00-193 Warszawa
Website: https://www.uodo.gov.pl/
The Service Provider reserves a right to make changes to this Privacy Policy, in compliance with the relevant legal regulations. The valid version of the Privacy Policy will be available on the following web page: https://es.etutor.eu/regulamin/polityka-prywatnosci/.
Privacy Policy updated on: 9 July 2025.