1 – Legal bases and purposes of processing

7Speaking implements various processing operations whose legal bases are as follows: contractual execution, your consent, its legal and regulatory obligations, its legitimate interest.

The purposes associated with each legal basis are listed below:

Based on the execution of the contract you subscribed to by accepting the General Terms of Use, we implement processing for the following purposes:

• give access to personalized language training, individually, or to a group of employees of a company, or to a group of agents of an administration, educational institution or community, or to a group of students of a higher education establishment;
• map the level and language needs to build the personalized program;
• allow training professionals (training manager, partners, and teachers) to monitor and adapt the service to the learner's needs;
• generate learner adherence, achieve optimal engagement rates.

Based on your consent, we implement processing for the following purposes:

• management of adherence to the 7Speaking user community;
• management of cookies subject to consent.

Based on compliance with our legal and regulatory obligations, we implement processing for the following purposes:

• management of our general accounting;
• management of responses to official requests from public or judicial authorities authorized for this purpose.

Based on our legitimate interests, we implement processing whose purposes are as follows:

• establishment of proof of completed transactions;
• fraud prevention;
• analysis of your data, particularly to personalize the products and services we offer based on your profile, send you messages, personalized or non-personalized communications, regarding our products or services;
• management of cookies not subject to consent.

The purposes pursued on the basis of our legitimate interests are done so in respect of your rights and freedoms.

If 7Speaking is required to process your data for purposes other than those listed in the paragraph below, we will inform you and take any further steps that may be necessary.

2 – Processed data

7Speaking commits to its clients to collect and process only the data necessary for its activities, relating in particular to the provision of the services we offer you, as well as products and services personalized according to your profile. Consequently, 7Speaking collects various personal data concerning you.

Certain data processed by 7Speaking is collected indirectly from:

• publications or databases made available to it,
• third parties, such as data providers, namely employers and/or teachers.

3 – Data subjects

The persons concerned by the processing are:

• prospects who contact 7Speaking to obtain information on the products and services offered;
• 7Speaking clients;
• any person with an account allowing them to access the sites www.7speaking.com and user.7speaking.com, and more specifically any learner, trainer, and teacher.

4 – Data recipients

To achieve the purposes described above and within the limits necessary to pursue these purposes, the data collected by 7Speaking may be transmitted to all or part of the following recipients:

• the internal departments of 7Speaking or LEARNATION Group companies, the latter acting as subcontractors of 7Speaking, authorized to manage our commercial relationship (all persons in charge of the awarding, management, and execution of contracts);
• LEARNATION Group companies, as data controllers, it being specified that the exercise of the right of opposition can be exercised directly with 7Speaking.
• the internal training departments of our clients, who, as joint data controllers, must have access to data relating to the progress of the training followed by their employees.
• persons in charge of the marketing department, the commercial department, departments responsible for handling customer relations, complaints, prospecting, administrative departments, IT departments, as well as their line managers;
• our partners, service providers, and subcontractors, if applicable;
• lawyers, court auxiliaries, and public officers, administrative or judicial authorities seized of a dispute if applicable, as part of compliance with the legal obligations incumbent on 7Speaking or to enable 7Speaking to ensure the defense of its rights and interests;
• mediators, supervisory and control authorities authorized to receive such data;
• departments responsible for control such as statutory auditors and auditors as well as departments responsible for internal control.

5 – Data retention period

Respectful of the right to be forgotten, 7Speaking retains the personal data it collects only for the time necessary for the purposes of the processing and in accordance with applicable legislation.

The data collected by 7Speaking will thus be kept for the duration necessary for the fulfillment of the purposes described above, plus the legal prescription period.

More specifically, we organize our data retention policy as follows:

6 – Data security

7Speaking attaches particular importance to the security of personal data.

It has implemented technical and organizational measures adapted to the degree of sensitivity of personal data, in order to ensure the integrity and confidentiality of data and to protect it against any malicious intrusion, loss, alteration, or disclosure to unauthorized third parties.

7Speaking regularly conducts audits to verify the proper operational application of rules relating to data security.

Thus, it commits to taking the necessary physical, technical, and organizational security measures to:

• protect its activities;
• preserve the security of personal data of its prospects, clients, and internet users;
• against any unauthorized access, modification, distortion, disclosure, destruction, or access to the personal data it holds.

Nevertheless, the security and confidentiality of personal data rely on the good practices of everyone, so you are invited to remain vigilant on the matter.

7Speaking chooses its subcontractors and service providers with care and requires them to have:

• a level of personal data protection equivalent to its own;
• use of personal data or information only to ensure the management of the services they must provide;
• strict compliance with the legislation and regulations applicable to confidentiality and personal data;
• the implementation of all adequate measures to ensure the protection of personal data they may have to process;
• the definition of technical and organizational measures necessary to ensure security.

7Speaking concludes contracts with its subcontractors, in accordance with legal obligations, precisely defining the conditions and modalities of personal data processing.

7 – Data transfer outside the European Union

7Speaking stores personal data within the European Union.

8 – Focus on ancillary services

As part of your subscription to 7Speaking products and services, you may benefit from ancillary services. You can freely subscribe to these various services with the provider of said services. Only the provider of the subscribed ancillary service(s) is the data controller within the meaning of the regulations on personal data, for the personal data concerning you that they process. It is your responsibility to inquire with said provider about the terms under which they process your personal data.

We inform you that we may have to transmit data concerning you to said providers that are necessary for them to provide you with their services.

9 – Your rights and how to exercise them

9.1- The content of your rights

Any data subject has the following rights related to the data concerning them:

• right to information;
• right of access;
• right to rectification;
• right to erasure (unless they are necessary for the execution of the services, or they are necessary for 7Speaking to comply with its legal obligations or to establish or exercise its rights);
• right to define directives relating to the fate of data after the death of the data subject.

Under the right of access, 7Speaking may ask you for the payment of reasonable fees based on administrative costs for any additional copy of the data to the one that will be communicated.

You also have:

• a right to obtain the restriction of a processing;
• a right to data portability of the provided data;
• a right to object.

You can request to exercise your right to object to the processing of personal data concerning you for reasons relating to your particular situation when the processing is based on 7Speaking's legitimate interest. This right to object also applies to profiling.

In the event of exercising such a right to object, 7Speaking will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

You can also object to any processing related to prospecting without it being necessary to invoke reasons relating to your particular situation.

9.2 – The exercise of rights

The exercise of rights is carried out by sending an email to the address dataprotection@7speaking.com or by postal mail to the Personal Data Protection Officer, accompanied by any means to establish your identity, at the address:

The communication of specific post-mortem directives and the exercise of rights are carried out by postal mail, accompanied by any means to establish your identity, to the Personal Data Protection Officer, at the address:

9.3 – The withdrawal of consent

You can also withdraw your consent at any time, in cases where it has been requested from you (the withdrawal of your consent will not affect the lawfulness of the processing carried out before the withdrawal of consent).

9.4 – Lodging a complaint

If you consider, after contacting us, that your rights to your data are not respected, you can submit a complaint to the National Commission on Informatics and Liberty (CNIL).

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