Privacy Policy – Glite Tech Ltd

This Privacy Policy serves as our Privacy Notice under UK GDPR and EU GDPR. It explains what to expect when Glite Tech Ltd collects and uses your personal information. We are committed to protecting your privacy and handling your data in an open and transparent manner.

Who We Are and How to Contact Us

Data Controller:
Glite Tech Ltd
128 City Road, London, United Kingdom, EC1V 2NX
Email for privacy questions: privacy@glite.ai

Data Protection Officer (DPO):
TechGDPR DPC GmbH
Willy-Brandt-Platz 2, 12529 Berlin-Schönefeld, Germany
Email: glite.dpo@techgdpr.com

EU Representative:
Pursuant to Article 27 of the GDPR, we have appointed the European Data Protection Office (EDPO) as our representative in the EU. You can contact them regarding data protection matters.
European Data Protection Office (EDPO)
Avenue Huart Hamoir 71, 1030 Brussels, Belgium

What Information We Collect and Why

We collect information to provide and improve our language learning services.

• Account and Profile Information: When you create an account, we collect your name, email, year of birth, native language, country, and education level. This helps us set up and personalise your learning experience.
• Learning and Performance Data: We collect your test results, answers, vocabulary assessments, and progress data to deliver our learning features and track your development.
• Behavioural and Usage Data: We automatically log your interactions with our apps and website, such as features used and time spent, to understand usage patterns and improve our service.
• Voice and User-Generated Content: For certain features, like the "Describe Image" test, we process your voice recordings. We also store content you provide, such as through text import features.
• Technical Information: We collect your IP address, device details, and browser information for security, analytics, and to ensure our services function correctly.

Our Lawful Bases for Processing

We only use your data when the law allows us to. Our main legal bases are:

• Performance of a Contract: Much of our processing is necessary to provide the service you signed up for, such as running tests and managing your account.
• Legitimate Interests: We use data to improve our platform, train our AI models, and ensure security. We balance our interests with your rights. You can object to this processing at any time.
• Consent: For optional activities, like non-essential cookies or certain data collection features, we will ask for your explicit consent.

Who We Share Your Information With

We use trusted third-party providers to help us deliver our services. These include:

• Cloud hosting and storage providers (e.g., Amazon Web Services).
• Authentication services (e.g., Firebase).
• AI and speech processing partners (e.g., OpenAI, Deepgram).
• Website analytics and A/B testing services (e.g., Google Analytics, VWO).
• Error monitoring services (e.g., Sentry).

We have contracts with these providers to ensure they protect your data.

International Data Transfers

Some of our service providers are based outside the UK and EU. When we transfer your data internationally, we use legal safeguards like Standard Contractual Clauses to ensure it remains protected to the same high standards.

How Long We Keep Information

We keep your personal data for no longer than is necessary for the purposes for which it was collected. Account data is kept while your account is active. Other data, like analytics records, is kept for a fixed period (e.g., 14 months) before being deleted or anonymised.

Your Data Protection Rights

Under data protection law, you have rights including:

• Your right of access - You have the right to ask us for copies of your personal information.
• Your right to rectification - You have the right to ask us to rectify information you think is inaccurate.
• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing - You have the right to ask us to restrict the processing of your information.
• Your right to object to processing - You have the right to object to processing where we rely on legitimate interests.
• Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation.

You do not need to pay a fee to exercise your rights. If you make a request, we have one month to respond. Please contact us at privacy@glite.ai to make a request.

How to Complain

If you have concerns about our use of your personal information, please contact us first at privacy@glite.ai.

You can also complain to the UK's Information Commissioner's Office (ICO) if you are unhappy with how we have used your data.

The ICO's address:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk