Effective Date: March 6, 2026

1. Introduction and Scope
This Privacy Policy describes how Grand English Courses (“Company”, “School”, “we”, “our”, “us”) collects, uses, discloses, and protects personal data of individuals who interact with our website and online education services. This policy applies to:

• Parents and legal guardians registering children for lessons
• Students participating in online lessons
• Individuals booking trial lessons
• Teacher applicants
• Visitors browsing our website
• Users contacting customer support

By accessing our website or purchasing our services, you confirm that you have read and understood this Privacy Policy.

2. Data Controller
The entity responsible for your personal data is:
IE Shahrom Azimov
Identification Number: 345825280
Address: Georgia, Batumi, Zhiuli Shartava Ave N7, Floor 7
Email: info@grandenglishcourses.com
Phone: +995 599 88 57 30
Website: grandenglishcourses.com

3. Definitions

• Personal Data: Any information relating to an identified or identifiable individual.
• Processing: Any operation performed on personal data (collection, recording, organisation, storage, adaptation, retrieval, consultation, use, disclosure, restriction, or deletion).
• User: Parent, guardian, student, visitor, or teacher applicant interacting with the School.
• Student: A child enrolled in the educational program.
• Teacher: An instructor providing online lessons.
• Platform: Digital systems used to conduct lessons, including ClassIn or other learning tools.
• Cookies: Small text files stored on a user's device when visiting a website.

4. Applicable Data Protection Laws
We process personal data in accordance with applicable international laws, including but not limited to:

• EU General Data Protection Regulation (GDPR)
• Brazilian General Data Protection Law (LGPD), Law No. 13,709/2018
• United States federal and state privacy laws (including COPPA and CCPA)
• Council of Europe guidelines on children's rights in the digital environment
• Other applicable laws in jurisdictions where our services are offered

4.1 Compliance with Georgian Law
As a company registered in Georgia, the School processes personal data in accordance with the Law of Georgia on Personal Data Protection (2023). This includes:

• Obtaining parental consent for minors under 16 years of age
• Responding to data subject requests within 10 working days
• Implementing appropriate technical and organizational security measures as required by Georgian law

5. Information We Collect
5.1 Information You Provide to Us
At Registration / Booking:

• Parent/guardian full name, email address, phone number, messaging app details (e.g., WhatsApp, WeChat), country of residence
• Student full name and age
• Preferred lesson schedule

During Lessons and Educational Activities:

• Attendance records, lesson participation data, homework submissions
• Pronunciation practice results, AI‑generated test results
• Lesson Recordings: Some lessons may be recorded for quality assurance, teacher training, or make-up lesson purposes. We will obtain explicit, verifiable parental consent before recording any lesson involving a child. Parents may withdraw consent at any time by contacting us. Recordings are stored securely and deleted after 3 months unless needed for dispute resolution.
• Teacher feedback and progress reports

When Communicating With Us:

• Email correspondence, chat messages, customer support requests, feedback forms, survey responses

When Applying as a Teacher:

• Full name, date of birth, contact details (email, phone, address)
• CV/résumé, educational background, professional experience, teaching certifications
• Interview notes, recorded sample lessons, demo tasks
• References and background verification results

When Booking a Trial Lesson:

• Full name of the person booking, contact details, preferred trial schedule, technical setup details (internet speed, device type)

Payment Information:

• Payment details are processed directly by secure third‑party providers. We do not store full credit card numbers but may retain transaction identifiers and invoice details.

5.2 Information Collected Automatically
When you interact with our website or learning platform, we may automatically collect:

• IP address, browser type, operating system, device type
• Pages visited, session duration, referral sources, login timestamps
• System diagnostic data

5.3 Cookies and Tracking Technologies
We use cookies and similar technologies to improve functionality and user experience. Types of cookies used include:

• Essential Cookies: Necessary for login authentication and secure platform operation.
• Functional Cookies: Remember user preferences (language, scheduling choices).
• Analytics Cookies: Provide aggregated information about website traffic and usage patterns.
• Performance Cookies: Help us understand system performance and detect errors.

You may disable cookies through your browser settings; however, some features may not function properly. For more details, please refer to our separate Cookie Policy (if available).
5.4 Testimonials and Marketing
With separate, explicit parental consent, we may use student first names, photos, or video clips for promotional materials on our website or social media. Consent may be withdrawn at any time by contacting us.

6. How We Use Your Information
We use your personal data for the following purposes:

• Providing online educational services (scheduling, conducting lessons, evaluating progress)
• Communicating with parents/guardians about lessons, schedules, and updates
• Processing payments and issuing invoices
• Recruiting and assessing teacher applicants
• Improving our educational content and platform functionality
• Ensuring technical compatibility and security
• Complying with legal obligations (e.g., tax records, regulatory requests)
• Marketing Communications: We may send promotional offers or newsletters with parental consent. Parents may opt-out at any time by clicking "unsubscribe" in emails or contacting us directly. We do not send marketing communications to children.

7. Legal Basis for Processing
We rely on the following legal bases:

• Consent of the parent/guardian (for children's data, lesson recordings, testimonials, etc.)
• Performance of a contract (to deliver the services you purchased)
• Legitimate interests (to improve our services, ensure security, and manage teacher applications)
• Compliance with legal obligations (e.g., retaining financial records)

8. Data Sharing
We may share your personal data with trusted third‑party service providers who assist us in operating our business, such as:

• Payment processors
• Educational platform providers (ClassIn)
• Cloud hosting and technical support providers
• Legal authorities when required by law

We do not sell, rent, or trade your personal information.

9. International Data Transfers
Because our services operate internationally, your personal data may be processed in countries outside your own. We implement appropriate safeguards (such as standard contractual clauses) to ensure your data is protected in accordance with applicable laws.

10. Data Security
We implement reasonable technical and organisational security measures, including:

• Encrypted connections (HTTPS)
• Restricted internal access to personal data
• Secure hosting infrastructure
• Regular internal privacy reviews

Data Breach Response:In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify affected individuals and relevant authorities within 72 hours as required by applicable law.
No method of transmission over the internet is 100% secure, but we strive to protect your information.

11. Data Retention
We retain personal data only as long as necessary to fulfil the purposes described in this policy:

• Student and parent accounts: Up to 3 years after the last completed lesson.
• Teacher applicants (not hired): Up to 12 months after application.
• Teachers (hired): For the duration of cooperation plus any legally required retention periods (e.g., tax records).
• Financial records: Retained according to applicable tax and accounting laws.
• Lesson recordings: Deleted after 3 months unless required for dispute resolution.

12. Children's Privacy
Our services are intended for children aged 6–12. We comply with the Children's Online Privacy Protection Act (COPPA) and other relevant child protection regulations.
In accordance with Georgian law, for students under 16 years of age, verifiable parental consent is required before collecting or processing personal data. Students aged 16 and above may provide their own consent.
Parents may review or delete their child's data at any time by contacting us.

13. Your Rights
Depending on your jurisdiction, you may have the following rights:

• Access your personal data
• Request correction of inaccurate data
• Request deletion of your data
• Restrict or object to processing
• Request data portability
• Withdraw consent at any time (without affecting the lawfulness of processing before withdrawal)

Response Time: We will respond to your data protection requests within 10 working days, as required by Georgian law.
For California Residents (CCPA):

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information (with exceptions)
• Right to opt-out of sale of personal information (we do not sell data)
• Right to non-discrimination for exercising CCPA rights
• California residents may make requests by emailing us, and we will verify identity before processing

If you are in the EU, you also have the right to lodge a complaint with your national data protection authority.

14. Third‑Party Links
Our website may contain links to external websites. We are not responsible for the privacy practices of those websites; we encourage you to read their privacy policies.

15. Policy Updates
We may update this Privacy Policy from time to time. The most current version will always be published on our website, with the effective date noted at the top.

16. Contact Us
For privacy‑related questions or to exercise your rights, please contact:
Grand English Courses
Email: info@grandenglishcourses.com
Website: grandenglishcourses.com