✅ Privacy Policy – PolyPro

Effective Date: 20/06/2025

Last Updated: 20/06/2025

This Privacy Policy explains how Master Learn Ltd ("we", "us", or "our") collects, uses, and protects your personal data when you use PolyPro, our English language learning platform.

1. Who We Are

PolyPro is a product of Master Learn Ltd, a company registered in England and Wales under company number 15613671.

We are the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Registered Office: 71-75 SHELTON STREET COVENT GARDEN LONDON UNITED KINGDOM WC2H 9JQ

Email: [email protected]

2. What Information We Collect

We may collect and process the following types of personal data:

a) Information You Provide:

• Name

• Email address

• Account credentials

• Payment details (processed securely via third-party providers)

b) Automatically Collected Data:

• IP address

• Browser type and version

• Device information

• Usage logs (e.g., lesson progress, login times)

Note: We do not use cookies or similar tracking technologies.

3. How We Use Your Information

We use your personal data to:

• Create and manage your user account

• Provide access to courses and progress tracking

• Process payments and send receipts

• Respond to support requests and inquiries

• Improve our services and platform performance

• Comply with legal obligations

4. Lawful Basis for Processing

Under UK GDPR, we process your personal data based on one or more of the following:

• Performance of a contract – To deliver the services you signed up for

• Consent – When you opt in to receive communications

• Legal obligation – To comply with applicable laws and regulations

• Legitimate interests – For platform maintenance and improvement

5. How We Store and Protect Your Data

We store your data securely on UK- or EU-based servers with strict access controls. All payment information is handled through secure, PCI-DSS-compliant payment gateways.

We retain your data for as long as your account is active, or as needed to comply with legal and contractual obligations.

6. Sharing Your Data

We do not sell or share your personal data with third parties for marketing.

We may share your data only with:

• Payment processors (e.g., Stripe)

• Cloud service providers (e.g., AWS, Google Cloud)

• Legal or regulatory authorities, where required

All third parties are contractually obligated to protect your data in accordance with UK data protection laws.

7. International Transfers

If any data is transferred outside the UK or EEA, it is protected using appropriate safeguards, such as Standard Contractual Clauses or an adequacy decision from the UK government.

8. Your Rights

You have the right to:

• Access your personal data

• Correct or update inaccurate data

• Request deletion of your data (“right to be forgotten”)

• Restrict or object to data processing

• Withdraw consent at any time

• Lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk

To exercise these rights, email us at [email protected]

9. Children’s Privacy

PolyPro is intended for adults aged 18 and above. We do not knowingly collect personal data from children.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised "Last Updated" date.