Transparent may collect the following personal information directly or through our order processing agents:
- First and last name
- Email address
- Phone number
- Address information
- Country of origin
- Organization name, if applicable
- Age range (15 and younger or 16 and older), as required to comply with regulations
- IP address
- Category of user (personal learner, educator, librarian, company representative, etc.), if you provide such information
- Any answers you provide if you voluntarily choose to participate in customer surveys
- Any additional contact information (such as Skype name, cell phone, fax, etc.) that you voluntarily choose to provide if you interact with Transparent employees, including tutors, instructors, and technical support
The Application also collects the following information related to your usage of the program:
- Native language(s) selected
- Language(s) being learned
- Learning history and other lesson and course interaction
In addition, the following technical information may be collected in an anonymized format, not linked directly to your account:
- Browser type and version used to access the Application
- Operating system used to access the Application
- Referrer URL / Previously visited page
Transparent requires the information we gather to generally understand your needs and to provide you with better service, and in particular for the following reasons:
- To customize your experience with the Application according to your interests
- To enable internal record keeping and reporting
- To improve our products and services
- To periodically send promotional emails about new products, special offers, or other information which we think you may find interesting
- To contact you from time to time for market research purposes
Transparent is committed to ensuring that your information is secure. To prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
We also adhere to the principles of purpose limitation and data minimization. Therefore, we only store your personal data for as long as it is necessary to achieve the purposes mentioned here or as long as the storage periods required by law. After discontinuation of the respective purpose or expiry of these deadlines, the corresponding data will be blocked or deleted in accordance with the statutory provisions. Our legal basis for the deletion or blocking of personal data is Art. 5 (1) b) GDPR and Art. 5 (1) c) GDPR.
You have the right to complain about any improper processing of your personal data (such as collection, storage, modification, transfer, deletion, etc.) by us to the proper authorities.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), and to request the deletion or restriction of your information. Transparent will respond to requests about these matters within a reasonable timeframe.
- Accessing, updating, and downloading your information: The User Profile section of the Application gives you the ability to access and update certain information about yourself from within the Application. It also allows you to download a copy of your information in an electronic file.
- Opting out of communications: You may opt out of receiving communications from us by using the unsubscribe link within each email, by updating your email preferences within the Application, or by contacting Transparent at firstname.lastname@example.org.
- Accepting or declining cookies: Cookies are small files which can be placed on your computer’s hard drive to allow web applications to respond to you as an individual. With cookies, web applications can tailor their operations to your needs, likes, and dislikes by gathering and remembering information about your preferences. Within the Application, we use traffic log cookies to identify which pages are being used. We only use this information for statistical analysis purposes, then remove the data from our system. The cookies in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Most web browsers automatically accept cookies, but you can change your browser setting to decline cookies if you prefer. Please be aware that if you choose to decline cookies, some or all of the Application may be inaccessible or non-functional.
- Requesting that we forget you: If you no longer wish to use the Application and do not want Transparent to continue storing information about you, you may have your account forgotten by clicking the “Forget Me” link in the User Profile section of the Application and following the instructions on the screen. When we receive such a request, we will retain your user data for 30 days. If you change your mind during this period, you can stop the process of being forgotten by logging into your account. If you haven’t logged in within 30 days, your account and all your learning progress will be permanently forgotten. At that point, the action cannot be undone.
Transparent will not sell, distribute, or lease your personal information to third parties unless we have your permission or are required by law to do so. However, we may use the following sales and marketing products for web analytics and social media marketing:
- Google Analytics: We use Google Analytics, a web analytics service provided by Google Inc. (“Google”), on our websites, including the Application. Google Analytics uses its own cookies to evaluate site usage, compile site activity reports, and provide other services related to website activity and internet usage on behalf of Transparent. Google is a U.S. company that uses servers in the United States.
- Google AdWords: If you reach our website via an advertisement sent by Google, Google AdWords sets a cookie on your computer. These cookies lose their validity after 30 days and are not used for personal identification. If you visit certain pages on our website and the cookie has not expired, we and Google may recognize that you clicked on the ad and were redirected to this page. Google is a U.S. company that uses servers in the United States.
- HubSpot LiveChat: HubSpot LiveChat is built into our websites to let our users communicate with Transparent employees. HubSpot LiveChat collects access data such as IP address, browser, and operating system type as well as the dial-in location from users of the live chat. In addition, cookies are used to collect further data about user behavior. HubSpot has represented to us that it processes this information solely to improve its own services. HubSpot stores and processes all collected data on servers located in the United States.
- SurveyMonkey: SurveyMonkey lets Transparent create surveys that users of the Application may choose to participate in. We use these surveys to collect user opinions and feedback that helps us improve our products and websites. Surveys are anonymous but may allow users to submit questions along with their email address. SurveyMonkey attempts to distinguish users by using their IP addresses as identifiers. SurveyMonkey is a U.S. company.
- TypeForm: We uses TypeForm to create data input forms that allow users to submit technical support cases and other customer service requests. TypeForm is a Barcelona-based online Software as a Service (SaaS) company that specializes in online form building and online surveys.
- GrooveHQ: We use GrooveHQ for technical support case management, knowledge base, and LiveChat. GrooveHQ is a U.S. company.
- CloudAMQP: We use CloudAMQP to host an instance of RabbitMQ, which is used to send data to Transparent servers for processing. Information is not stored by CloudAMQP and is encrypted in transit.
- Amazon Web Services (AWS): We use AWS to host content, send emails and notifications, maintain access logs, and provide support within Transparent authoring tools. AWS encrypts data at rest and uses secret keys to control who can access various data points.
- BlueSnap: BlueSnap processes Transparent’s payment transactions. Transparent also uses a cart hosted by BlueSnap servers to gather customer payment info at purchase time, which means Transparent never has access to that info. After a transaction has taken place between BlueSnap and a Transparent customer, Transparent may view transaction information such as date, customer email, customer name, customer address, amount, payment method, and product purchased, but not payment info. BlueSnap is a U.S. company.
- FeedBlitz: We use FeedBlitz to send emails to voluntary subscribers to our blogs and Word of the Day service. FeedBlitz is a U.S. company.
- WordPress: We use WordPress to power our blogs, which may be accessible through the Application. WordPress may collect the name, email address, and IP address of users who voluntarily choose to comment on our blog articles. WordPress is a U.S. company.
Our legal basis for the use of these third-party products is provisions 6 (1) b) and 6 (1) f) of GDPR.