TalkEngO: Talk English Online - Policies

TalkEngO Ltd Policies

  1. GDPR-compliant policy
  2. Cookies Policy
  3. Security policy
  4. TalkEngO’s Privacy 
  5. TalkEngo Codes for all Independent Contractors
  6. Equal Opportunities and Diversity
  7. Dispute Resolution Process
  8. Payment, Recredit and Withdrawal Policy




1- TalkEngO GDPR-compliant policy

Thank you for choosing to be part of our community at Talkengo Ltd. (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at talkengo.com.

TalkEngO has implemented a series of changes to bring our policies and procedures into GDPR compliance. We’ve updated our Terms of Use, Privacy Policies, and Cookies Policy to be more transparent about how we use your data.

When you visit our website talkengo.com (the "Website"), and more generally, use any of our services (the "Services", which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as any related services, sales, marketing or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.


1.1 What is General Data Protection Regulation (GDPR)?

The GDPR is a European regulation designed to:

  • Unify privacy rights across the countries of the European Economic Area (EEA)
  • Strengthen individual data subjects’ rights for EEA residents

This includes your ability to correct, delete, and transport personal data on TalkEngO. 

At TalkEngO, our goal is to help our customers meet both the letter and the spirit of GDPR in a simple and straightforward way. We believe GDPR is not just a regulation; respecting the privacy rights of all customers and their users (regardless of origin) is the right thing to do.

TalkEngO has updated its platform to meet GDPR standards worldwide, and we will continue to invest in industry-leading data privacy initiatives.


1.2 WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.

In Short: We collect information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; job titles; passwords; usernames; contact preferences; educational background; photo; interest topics; timezone; english level; free time; paypal email; professional certificates; and other similar information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Linkedin Google account. If you choose to register in this way, we will collect the information described in the section called"HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.


1.3 HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Website offers you the ability to register and login using your third-party social media account details (like your Facebook or Linkedin logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Website. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.


1.4 Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.

We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie policy.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system configuration information.
  • Location Data. We collect information data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type of settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Locations settings on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
  • Webcam and Microphone

Information collected from other sources:

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g. Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings.


1.5 HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.
  • To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact us at support@talkengo.com and be sure to include your name, testimonial location, and contact information.
  • Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
  • To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.
  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.
  • Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
  • To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
  • To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).
  • Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information, see our Cookie policy.
  • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

1.6 WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

1.7 DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie policy.


1.8 HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


1.9 HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.


1.10 WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. 

If you have questions or comments about your privacy rights, you may email us at support@talkengo.com.


1.11 Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.
  • Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

  • Access your account settings and update your preferences.
  • Contact us using the contact information provided.

1.12 Age Restrictions

In accordance with GDPR, we have changed the age of consent for EEA residents' use of our services. If you are an EEA learner, please check the Terms and Conditions about age restrictions to learn more.

The privacy of children is one of our concerns. TalkEngO Services are not intended for use by children under the age of 18 without the express permission of their parents or legal guardian. If you are under the age of 18 you will need to get your parent’s/legal guardian’s permission before submitting any personal data to TalkEngO. We may process the personal data of children under the age of 18, provided that data has been consensually provided by parents/legal guardians for the express purpose of using TalkEngO Services.


1.13 Third-Party Vendors

We have worked to build product features that give learners more control over their data. We have also contracted with third-party vendors to perform certain specialized tasks, including processing personal data.

These vendors fall into the following categories:

  • Social account (Facebook, Google, Linkedin). If you access our websites or Service through a social account connection or log-in, that third party may pass certain information about your use of its service to TalkEngO such as your name, picture and Email address.
  • Hosting. Our platform is hosted on third-party servers.
  • Analytics/Marketing. To improve TalkEngO and the content we offer, we use various third-party analytics and marketing tools to refine our offerings, understand learner habits, optimize the platform, and tailor our marketing efforts.
  • Customer Support/Communication. To provide customer support, we use third-party tools and services to communicate and respond to questions promptly.
  • Video communications. To provide video chat tools for peer to peer video sessions.
  • Video hosting and playing. To provide facilities for users to play all video in the website with fast speed and maximum compatibility.

To learn more about the GDPR, click here
This page is provided as a source of general information. It is not and should not be treated as legal advice.

2 - Cookies policy


2.1 What are cookies

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Site or a third-party to recognize you and make your next visit easier and the Site more useful to you. Essentially, cookies are a user’s identification card for the TalkEngO servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our Site and related functionalities. Cookies and web beacons allow TalkEngO to serve you better and more efficiently, and to personalize your experience on our Site.


2.2 How TalkEngO uses cookies

When you use and access the Site, we may place a number of cookies files in your web browser.

TalkEngO uses or may use cookies and/or web beacons to help us determine and identify repeat visitors, the type of content and sites to which a user of our Site links, the length of time each user spends at any particular area of our Site, and the specific functionalities that users choose to use. To the extent that cookies data constitutes personally identifiable information, we process such data on the basis of your consent.

We use both session and persistent cookies on the Site and we use different types of cookies to run the Site:

Essential cookies. Necessary for the operation of the Site. We may use essential cookies to authenticate users, prevent fraudulent use of user accounts, or offer Site features. Analytical/performance cookies. Allow us to recognize and count the number of visitors and see how visitors move around the Site when using it. This helps us improve the way the Site works.

Functionality cookies. Used to recognise you when you return to the Site. This enables us to personalise our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

Targeting cookies. Record your visit to the Site, the pages you have visited, and the links you have followed. We will use this information to make the Site more relevant to your interests. We may also share this information with third parties for this purpose.


2.3 Third-party cookies

In addition to our own cookies, we may also use various third-party cookies to report usage statistics of the Site and refine marketing efforts. Tracking cookies. Follow on-site behavior and tie it to other metrics allowing better understanding of usage habits. Optimization cookies. Allow real-time tracking of user conversion from different marketing channels to evaluate their effectiveness. Partner cookies. Provide marketing conversion metrics to our partners so they can optimize their paid marketing efforts.


2.4 What are your choices regarding cookies

If you'd like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use some or all of the features we offer. You may not be able to log in, store your preferences, and some of our pages might not display properly.




3 - Security policy

TalkEngO is dedicated to protecting your Personal Information and taking reasonable security measures to ensure that your information is treated securely and in accordance with this Privacy Policy. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.

After a transaction, your private information (credit cards, social security numbers, financials, etc.) will not be stored on our servers. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional access, use or disclosure of your information.

As a user of our Site or Service, please remember to sign out of your TalkEngO Account, and close your browser window whenever you leave your computer. This is to ensure that others cannot access your account or Personal Information. To help protect your TalkEngO Account information, please keep your password secure and do not divulge your password to anyone. We suggest that you pick a non-obvious password that mixes numbers and letters. Ultimately, you are responsible for maintaining the secrecy of your passwords and any TalkEngO Account information, and we are not responsible for the unauthorized use by third parties of information you post or otherwise make available publicly.

Security Breach Procedures

  1. Service Provider shall:
    1. Provide Conversation Partner (CP) and Language Learner (LL) with the name and contact information for an employee of Service Provider who shall serve as CP’s and LL’s primary security contact and shall be available to assist CP & LL twenty-four (24) hours per day, seven (7) days per week as a contact in resolving obligations associated with a Security Breach;
    2. Notify CP and LL of a Security Breach as soon as practicable, but no later than twenty-four (24 hours after Service Provider becomes aware of it;
    3. Notify CP & LL of any Security Breaches by Email with a read receipt at info@talkEngo.com and with a copy by e-mail to Service Provider’s primary business contact at hsh@talkengo.com
  2. Immediately following the Service Provider’s notification to CP & LL of a Security Breach, the parties shall coordinate with each other to investigate the Security Breach. Service Provider agrees to fully cooperate with CP & LL in the handling of the matter and assisting with any investigation.
    1. Facilitating interviews with Service Provider’s employees and others involved in the matter.
    2. Making available all relevant records, logs, files, data reporting and other materials required to comply with the laws of England and Wales, industry standards or as otherwise reasonably required by CP & LL



4 - TalkEngO’s Privacy


4.1 PRIVACY

The content of this Agreement shall be treated confidentially. Each party to the Agreement shall treat highly sensitive personal information confidentially all documents, information and data (hereinafter collectively referred to as “information” made accessible to it or which otherwise come into its possession as if these were its own commercial secrets and shall only use them for the purposes of this Agreement.

The obligation shall not apply to information which is or becomes public knowledge and where there is an ongoing right of use, or where the party to the Agreement has given written consent to its disclosure, nor does it apply to information which has been verifiably acquired independently or otherwise legitimately obtained.

All informationhanded over by a party to the Agreement shall be deleted on first request, together with any duplicates made, on expiry or termination of the Agreement, provided no ongoing right of use exists.

Service provider shall, in particular:

  • only make such information and documents available to those who require such information and documents to fulfil their tasks.
  • ensure that parties are committed to treating the information and documents confidentially.

“Highly-Sensitive Personal Information” means an

  1. individual’s government-issued identification number (including social security number, driver’s license number or state-issued identified number);
  2. financial account number, credit card number, debit card number, credit report information, with or
  3. without any required security code, access code, personal identification number or password, that would permit access to an individual’s financial account; or biometric or health data.

“Personal Information” means information provided to Service Provider by or at the direction of Customer, or to which access was provided to Service Provider by or at the direction of Customer, in the course of Service Provider’s performance under this Agreement that:

  1. identifies or can be used to identify an individual (including, without limitation, names, signatures,
  2. addresses, telephone numbers, e-mail addresses and other unique identifiers; or
  3. can be used to authenticate an individual (including without limitation, employee identification numbers, government-issued identification numbers, passwords or PINs, financial account numbers, credit report information, biometric or health data, answers to security questions and other personal identifiers; in case of both subclauses (i) and (ii), including, without limitation, all Highly Sensitive Personal Information. Parties to this Agreement business contact information is not by itself deemed to be Personal Information

4.2 HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, you have specific rights regarding access to your personal information.


4.2.1 What categories of personal information do we collect?

We have collected the following categories of personal information:

Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name

NO

B. Personal information categories listed in the California Customer Records statute

Name, contact information, education, employment, employment history and financial information

YES

C. Protected classification characteristics under California or federal law

Gender and date of birth

NO

D. Commercial information

Transaction information, purchase history, financial details and payment information

NO

E. Biometric information

Fingerprints and voiceprints

NO

F. Internet or another similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements

NO

G. Geolocation data

Device location

YES

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video or call recordings created in connection with our business activities

YES

I. Professional or employment-related information

Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us

YES

J. Education Information

Student records and directory information

YES

K. Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

NO

We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries

4.2.2 How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice and our Cookie policy .

Youmay contact us by email at info@talkengo.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.


4.2.3 Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to awritten contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as forundertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

Talkengo Ltd. has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Talkengo Ltd. will not sell personal information in the future belonging to website visitors, users and other consumers.


4.2.4 Your rights with respect to your personal data

Rightto request deletion of the data - Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.


4.2.5 Right to be informed - Request to know

Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell your personal information to third parties;
  • the categories of personal information that we sold or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.


4.2.6 Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

We will not discriminate against you if you exercise your privacy rights.


4.2.7 Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

To exercise these rights, you can contact us by email at info@talkengo.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.




5 - TalkEngo Codes for all independent Contractors


5.1 Standards of Work

All Independent Contractors who are approved to work on TalkEngO (TEO) agree to our Conversation Partner (CP) Terms of Service. In addition to our CP Terms of Service, we ask that all CPs adhere to our CP Code of Conduct. The purpose of our Code of Conduct is to:

  1. Encourage the highest standards of behaviour for all CPs in their relationships with TalkEngO Language Learners (LL) by setting out clear statements of expectation.
  2. Provide a set of principles to guide CPs in their daily conduct and assist them when interacting with TalkEngO LL’s
  3. As our CPs come from all over the world and may adhere to different cultural norms, our CP Code of Conduct has been created based on universally accepted standards of respect and tolerance. It does not cover every specific situation but provides guidelines for ethical and professional behaviour

5.2 Code of Practice
  1. Behave with honor, integrity, and impartiality
  2. Communicate openly, honestly, and consistently
  3. Be Culturally Sensitive: Respect the values and traditions of your Learners. Accept diversity with tolerance and understanding
  4. Strongly commit to the values of the organisation and empower others
  5. Open minded, adaptive to change and adopt an attitude of continuous improvement.
  6. Inspire participation and commitment through a shared vision
  7. Inspire confidence through ethical and fair treatment of others
  8. Maintain high personal standards, taking pride in our appearance and conduct 
  9. Listen with patience, value opinions, and provide feedback
  10. Are transparent in our delivery and strive for service excellence
  11. Be polite and professional when interacting with Conversation Partners and Language Learners
  12. Avoid asking the following questions (unless specifically requested by the Learners) during your sessions:
  13. Personal life Avoid asking learners if they are married and or single (i.e. Do you have a girlfriend/boyfriend?)
  14. Politics Avoid asking learners about their political affiliations
  15. Religion Avoid asking learners about their religious views

5.3 Code of Conduct
  1. TalkEngo’s conversation sessions must be taught on TalkEngO’s website. Please contact our team at info@talkengo.com with any issues or concern
  2. Conversation Partners are to refrain from promoting or directing Language Learners to competing apps and services.
  3. Communication Off-platform is strictly forbidden. It is a prerequisite all communication between Conversation Partners and Language Learners must occur through TalkEngO.
  4. Do not send funds to or receive funds from TalkEngO Conversation Partners and Language Learners off-platform.

5.4 Violations of TalkEngO Conversation Partner Code of Conduct

As anonline Conversation Partner at TalkEngO, Language Learners around the world are trusting you. Be punctual, professional, and responsible in your communications with LL’s both on TalkEngO and during conversation sessions. 


5.5 Prohibited Actions

The following actions are prohibited at TalkEngO. Failure to comply will lead to being banned or blocked from TalkEngO’s website.

  1. Exchanging contact information or bypassing TalkEngO 
  2. Using TalkEngO platform for personal use without explicit written permission from TalkEngo
  3. Use of abusive, offensive, derogatory language, threats, intimidation or bullying towards TalkEngO Conversation Partners, Language Learners and Third Party’s
  4. All forms of discrimination are prohibited. For example, age, sex, race, gender, transgender et al
  5. Monetary fraud from TalkEngO Conversation Partners or Language Learners off platform
  6. Any attempt to recruit TalkEngo Conversation Partners or Language Learners to work or learn on other platforms
  7. Identity fraud
  8. Money laundering or theft
  9. Fraudulent use of credit cards or other payment methods
  10. To engage in sexual activities online
  11. To exploit, abuse or misuse TalkEngO’s website and services
  12. Spam messaging



6 - Equal Opportunity Policy and Diversity Policy


6.1 Introduction

TalkEngO Ltd aims to provide a welcoming, supportive, and emotionally and physically secure learning and working environment for every member of the school community.

TalkEngO recognises and promotes human rights, and values the diversity of culture, beliefs, practices, customs, physical and intellectual abilities and life experience of the whole school community.


6.2 Our commitment

TalkEngO Ltd aims to create an inclusive English Language culture that fosters acceptance and respect for diversity. In doing so, we seek to deepen understanding and knowledge, promote registered users' wellbeing and help everyone achieve their full potential. That is why discrimination, harassment, vilification, bullying and victimisation will not be tolerated at TalkEngO under any circumstances.

TalkEngO Ltd is committed to ensuring that the working environment is free from discrimination, harassment, bullying, vilification and victimisation.

This company acknowledges that in society some people are treated unfairly or unfavourably because of irrelevant personal characteristics such as their sex or race. TalkEngO supports the Charter of Human Rights and the Equal Opportunity Act 2010 (Vic), which says that it is against the law to discriminate against anyone, including learners, conversation partners and staff at TalkEngO, because of their actual or assumed:

  • age
  • career status
  • disability/impairment
  • gender identity
  • industrial activity
  • marital status
  • parental status
  • physical features
  • political belief or activity
  • pregnancy
  • race
  • religious belief or activity
  • sexual orientation
  • personal association with someone who has, or is assumed to have, one of these personal characteristics.

No member of the TalkEngO community will be treated less favourably because they possess any of these personal characteristics nor will such characteristics affect access to benefits and services TalkEngO provides. Discrimination is unacceptable at TalkEngO. Discrimination may be direct or indirect – both are against the law.


6.3 Direct discrimination

Means treating someone unfairly or less favourably because of one of the personal characteristics listed above or because of their association with someone identified with one of those characteristics.


6.4 Direct discrimination

Happens when a rule, policy or requirement unnecessarily or unreasonably disadvantages a person or group of people because of a protected personal characteristic they share.


6.5 Direct discrimination

Is unacceptable at TalkEngO Ltd. Harassment is behaviour (through words or actions) based on the personal characteristics listed above that are unwanted, unasked for, unreturned and likely to make school an unfriendly or uncomfortable place by:

  • humiliating (putting someone down)
  • seriously embarrassing
  • offending (hurting someone’s feelings) or
  • intimidating (threatening someone so they behave in a certain way).

6.6 Sexual harassment

Is an unwelcome sexual advance; request for sex or any other sexual behaviour that a reasonable person would know or expect would offend, humiliate, seriously embarrass or humiliate another.


6.7 Racial and religious vilification is unacceptable at TalkEngO

Vilification is behaviour (through words or actions) that incites hatred, serious contempt or ridicule of another person or group of people because of their race or religious belief.


6.8 Bullying is unacceptable at TalkEngO

Bullying is unreasonable behaviour that is intimidating, threatening or humiliating and repeated over time or occurring as part of a pattern of behaviour. Bullying can be physical, verbal or indirect, and creates an unfriendly, threatening or offensive environment.


6.9 Victimising someone who makes an Equal Opportunity complaint is unacceptable at TalkEngO

Victimisation means treating someone unfairly or otherwise disadvantaging them because they have made an EO complaint or might do so in the future.

TalkEngO will take action to prevent discrimination, harassment, vilification, bullying and victimisation and to promote a safe and inclusive school.

TalkEngo will take immediate and appropriate action to address and resolve EO issues and complaints.

TalkEngO will take action to promote human rights both in terms of school policy and practice and within its educational activities and culture.

A human rights based approach means taking steps to assess the school’s decisions and actions within the framework of the Charter and also taking proactive steps to encourage and promote wider school discussion and learner learning on the key Charter themes of Freedom, Respect, Equality and Dignity.


6.10 Who and what this policy covers

This policy covers the whole TalkEngO Ltd community, including staff, Learners, Conversation Partners, parents, contractors and volunteers.

This policy applies to all stakeholders engaged with TalkEngO ltd - Learners, Conversation Partners, Parents and Public.


6.11 Rights and Responsibilities

Under this policy, every member of the TalkEngO has the right to learn and work in a safe and inclusive environment free of discrimination, harassment, bullying, vilification and victimisation. Along with this right comes the responsibility to respect and promote human rights and responsibilities by behaving according to this policy.


6.12 The principal of TalkEngO is accountable for implementation of this policy.

The principal of TalkEngO may appoint an Equal Opportunity and Anti-Harassment Coordinator to support implementation of this policy.




7 - TalkEngO Policy for Dispute Resolution Process


7.1 Disputes between Language Learner (LL) and Conversation Partner (CP)
  1. Any disputes in connection with Services provided by CPs or payments made by Ls remain between such LLs and CPs. By using the Payment Account Service, you agree to follow the Dispute Resolution Process.
  2. alkEngO Ltd (TEO) will not be a party to any such dispute.
  3. TalkEngO will attempt to take the actions set forth in the Dispute Resolution Process, but TalkEngO will not be obligated to take any other action or refrain from taking any other action toward resolving any such dispute
  4. TalkEngO may, at its sole discretion, withhold or delay payment or continue to hold amounts or make payment or release amounts in the event of dispute between a LL and a CPS
  5. ARBITRATION: In case of a dispute between the Parties relating to or arising out of this Agreement, the Parties shall first attempt to resolve the dispute personally and in good faith. The arbitration shall be conducted via a qualified Mediator from TalkEngO and the outcome of the arbitration is final

7.2 Dispute between a member and TalkEngO

If a dispute arises between members and TalkEngO – T&C are governed in all aspects by law of the UK. Members to contact Customer Service first. 




8 - Payment, Recredit and Withdrawal Policy

Glossary of terms

  • CP – Conversation Partner
  • LL – Language Learner
  • Payment Gateways – PayPal; Braintree; etc
  • Payment by LL - Fee paid for a session by the learner
  • Re-credit - money paid back into the learner’s TalkEngO wallet account
  • Wallet account - This is a digital wallet which allows for an electronic transaction. This account holds the value of the credit you may have with TalkEngO - Wallet is used for purchasing sessions or withdrawal. 
  • Withdrawal - To take away a sum or total value of credit and transfer to a personal bank account. Withdrawal is subject to the cost of transaction and admin fee - please see terms & conditions below. 

8.1 General rules
  1. Your purchase of and payment for sessions shall be regulated by this Payment, Recredit and Withdrawal Policy. So, please read it carefully before making a payment as it determines your rights regarding your purchases, including essential restrictions. 
  2. This policy applies to all services and features made available through the TalkEngO Website and any related TalkEngO mobile device application.
    1. TalkEngO Ltd facilitates contracts between users (Learners/their parents and Conversation partners) by supplying a platform to request, deliver and pay for such Services. 
    2. TalkEngO is a platform which will be a party to any contracts made by CPs and learners, or any other service or materials
    3. TalkEngO will be responsible for monitoring any transactions between learners/parents, and CPs.
  3. Payment Services
    1. We use third party payment services to bill you through an online account payment in lieu of directly processing your credit/debit card information. Your paid balance for one or more sessions is safe in your wallet account as we use an integrated iframe for checkouts from our partners payment providers (PayPal and others…) and CPs get payment for delivering/assessing a session/s. 
    2. Data provided by you - You agree and understand that billing information, which you provide to make payment for conversation session(s) through TalkEngO, namely your credit card information and/or a third party Payment gateway’s information (e.g. PayPal account), is processed by our partners-payment providers (PayPal, ….) only. TalkEngO does not collect, store or otherwise process your billing information. Correspondingly all transactions are secured as our partners-payment providers use SSL encryption protection. We do not store your payment information on our servers.
    3. You agree that TalkEngO will not be responsible for any failure of the third party to adequately protect such information. The processing of payments will be subject to the terms, conditions, and privacy policies of our partners-payment providers in addition to this policy.
    4. You acknowledge that we may change our partners-payment providers and require them to transfer your information to other service providers that encrypt your information using secure socket layer technology (SSL) or other comparable security technology.
    5. All payments shall be made through the Payment Gateway Services. Upon receiving payment from a learner (or a parent on a learner’s behalf), TalkEngO will hold such payment and disburse it to the applicable CP on a pro-rata basis on a per session basis.
  4. All Users agree that they will not sell or buy CP services or materials from another User other than through our Services.
  5. CPs, Learners and parents will be liable for all transaction fees on the services related to the delivery and consumption of services through our Website.
  6. We charge CPs a commission for our Services. 

8.2 Re-Credit
  1. There will be no refund facilities. Once the fund is transferred to the wallet, it cannot be refunded.
  2. No refund will be issued in case the user has lost and/or forgot his/her login credentials (username and passwords), which has resulted in loss of data, temporary loss of access to the user's account or any other inconveniences for the user.
  3. No refund will be issued in case the user (learner) has lost connection due to the absence of Internet access, factory reset or updates. In this case, the learner must report in full any technical problems.
  4. Fees, incurred as a result of chargebacks or other payment disputes brought by you, your bank, or a payment provider, and disputes that require accounting or legal services shall be covered by you
  5. Recredit entitlement
    1. The session was not rated by CP - the fee will be re-credited into the LL’s wallet minus the TalkEngO’s Commission.
    2. The request for refund based on justifiable reasons and accepted as judged by the admit - for example CP does not show in the session or LLs has submitted a complaint. 

8.3 Withdrawal from wallet
  1. By Withdrawal it means transferring money from the Wallet to your personal bank account
  2. Withdrawal is only applicable for the fund available in your wallet
  3. There will be a total cost of £35 involved with such request which consist of:
    • £25 for processing the request; and 
    • £10 for cost of transaction. 
  4. Withdrawal can be requested at any time – provided there is enough funds in the wallet
  5. It will take up to 90 days for the process to take place
  6. To request Withdrawal, you need to complete the Withdrawal Proforma via contact us page