Privacy Policy

Preamble

7Speaking is committed to a policy of respecting and maintaining high standards of ethical conduct, including the protection of personal data.

On the www.7speaking.com and www.7speaking.com websites, 7Speaking is responsible for processing its users’ personal data. The identity and contact details of 7Speaking are listed in the “Legal Mentions” section.

The purpose of this external privacy policy is to inform you about how 7Speaking processes your personal data and the extent of your rights.

This policy may change according to the applicable legal and regulatory environment.

 

1 – Legal framework and purposes of data processing

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

The purposes associated with each legal basis are listed below:

  • Based on the performance of the contract you have agreed to by accepting the General Terms of Use, we implement processing for the following purposes: 
    • Providing access to personalized language training for individuals, or for a group of employees of a company, or for a group of employees of an administration, educational institution or community, or for a group of students of a higher education institution;
    • Mapping the learner’s level and needs in order to build a personalized program;
    • Enabling training professionals (training managers, partners and teachers) to monitor and adapt the service to the learner’s needs;
    • Generating learner engagement and achieving optimal engagement rates.

 

  • With your consent, we implement data processing for the following purposes:
    • managing membership in the 7Speaking user community;
    • managing cookies subject to consent.

 

  • In accordance with our legal and regulatory obligations, we implement data processing for the following purposes:
    • General accounting
    • Managing responses to official requests from public or judicial authorities authorized for this purpose.

 

  • Based on our legitimate interests, we implement data processing for the following purposes:
    • providing proof of the transactions carried out on the site;
    • fraud prevention;
    • analyzing your data, in particular to personalize the products and services we offer according to your profile, to send you messages, personalized or not, regarding our products or services;
    • managing cookies not subject to consent.

 

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

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

 

2 – Processed data

7Speaking hereby agrees to collect and process only the data necessary for its activities, in particular for the provision of the services we offer you, as well as products and services customized to your profile. As a result, 7Speaking collects various details about you.

Some of the data processed by 7Speaking is collected indirectly from the following sources:

  • publications or databases made available by the authorities;
  • third parties, such as data providers, i.e. employers and/or teachers.

 

3 – Data subjects

The persons concerned by the data processing are:

  • prospects who contact 7Speaking in order to obtain information on the products and services offered;
  • 7Speaking’s customers;
  • any user of www.7speaking.com, and user.7speaking.com.

 

4 – Data recipients

In order to achieve the purposes described above and within the limits necessary for the pursuit of these purposes, the data collected by 7Speaking may be transferred to all or part of the following recipients:

  • 7Speaking’s internal departments authorized to manage our commercial relationships (all persons in charge of the conclusion, management and execution of contracts);
  • employers of learners for statistical purposes;
  • the persons in charge of the marketing department, the sales department, the departments in charge of handling customer relations, complaints, prospecting, administrative departments, IT departments and their line managers;
  • our partners, service providers and subcontractors, where applicable;
  • lawyers, court officials and ministerial officers, administrative or judicial authorities to whom a dispute has been referred, where applicable, in order to comply with the legal obligations incumbent on 7Speaking or to enable 7Speaking to defend its rights and interests;
  • mediators, regulatory and supervisory authorities authorized to receive such data
  • supervisory authorities such as auditors and internal auditors.

 

5 – Data retention period

In accordance with the right to be forgotten, 7Speaking keeps the personal data it collects only as long as necessary for the purposes of the processing and in accordance with the applicable legislation.

Data collected by 7Speaking will therefore be retained for the time necessary to fulfill the purposes described above, plus the period of legal limitation.

Specifically, we organize our data retention policy as follows:

Aims

Retention period

Providing a learner with access to personalized language training,

Assessing the level and specific needs of a learner,

Mapping the language level of a company, an administration, a community, or an institution of higher education,

Gathering the language training needs of a company, an administration, a community, or an institution of higher education,

Helping the targeted employees become operational 4 times faster in their job,

Helping training professionals (training managers, partners and teachers) monitor and adapt the service to the learner’s needs.

Generating engagement and achieving optimal engagement rates.

 The entire duration of the contractual relationship, after which only the data necessary for pre-litigation or litigation purposes are archived until the legal statute of limitations has expired. The statute of limitations in civil and commercial matters is five (5) years. In the event of litigation, this data is kept for the duration of the procedure and until expiry of ordinary and extraordinary appeal procedures.
Assessing the products or services we can offer you and under what conditions The data is kept for three (3) years from the last incoming contact
Managing the operations necessary for the products or services to which you have subscribed The data is kept for three (3) years from the last incoming contact
Managing our business relationship with you, including responding to your contact requests The entire duration of the contractual relationship, after which only the data necessary for pre-litigation or litigation purposes are archived until the legal statute of limitations has expired. The statute of limitations in civil and commercial matters is five (5) years. In the event of litigation, this data is kept for the duration of the procedure and until expiry of ordinary and extraordinary appeal procedures.
Accounting purposes The current fiscal year plus ten (10) years from the closing date
Implementing security measures to prevent abuse and fraud

Data may be retained for up to twelve (12) months from the issuance of alerts before being qualified.

Alerts that are deemed irrelevant or unqualified at the end of the twelve (12) month period are deleted.

Qualified alerts are retained for a maximum of five (5) years after the fraud case is closed. For persons registered on a list of proven fraudsters, their data is deleted after the five (5) year period from the date of registration on the list.

If legal proceedings have been initiated, the data is kept until the end of the legal proceeding, increased by the duration of the acquisition of legal prescriptions. The limitation period of common law in civil and commercial matters is five (5) years from the end of the contract.
Detecting unusual transactions

Data may be retained for up to twelve (12) months from the issuance of alerts before being qualified.

Alerts that are deemed irrelevant or unqualified at the end of the twelve (12) month period are deleted.

Qualified alerts are retained for a maximum of five (5) years after the fraud case is closed. For persons registered on a list of proven fraudsters, their data is deleted after the five (5) year period from the date of registration on the list.

If legal proceedings have been initiated, the data is kept until the end of the legal proceeding, increased by the duration of the acquisition of legal prescriptions. The limitation period of common law in civil and commercial matters is five (5) years from the end of the contract.
Managing responses to official requests from public or judicial authorities empowered to do so The entire duration of the proceedings, plus the duration of the acquisition of legal prescriptions. The limitation period of common law in civil and commercial matters is five (5) years from the end of the contract.
Providing proof of the transactions carried out The entire duration of the contractual relationship, after which only the data necessary for pre-litigation or litigation purposes are archived until the legal statute of limitations has expired. The statute of limitations in civil and commercial matters is five (5) years. In the event of litigation, this data is kept for the duration of the procedure and until expiry of ordinary and extraordinary appeal procedures.
Preventing fraud

Data may be retained for up to twelve (12) months from the issuance of alerts before being qualified.

Alerts that are deemed irrelevant or unqualified at the end of the twelve (12) month period are deleted.

Qualified alerts are retained for a maximum of five (5) years after the fraud case is closed. For persons registered on a list of proven fraudsters, their data is deleted after the five (5) year period from the date of registration on the list.

If legal proceedings have been initiated, the data is kept until the end of the legal proceeding, increased by the duration of the acquisition of legal prescriptions. The limitation period of common law in civil and commercial matters is five (5) years from the end of the contract.
Analyzing your data in order to personalize the products and services that we offer according to your profile, to send you messages, communications personalized or not, concerning our products or services The data is kept for three (3) years from the last incoming contact
Managing subscriptions to the newsletter The data is kept until the subscriber unsubscribes
Managing the recording of telephone conversations

Registration data is kept for six (6) months from the time of collection

Analysis document data (reports and analysis grids) are kept for one (1) year from the time of collection
Managing cookies The duration of data retention shall not exceed 13 months

 

6 – Data Security

7Speaking considers the security of personal data to be of great importance.

It has put in place technical and organizational measures adapted to the degree of sensitivity of personal data, with a view to ensuring the integrity and confidentiality of the data and protecting it against any malicious intrusion, loss, alteration or disclosure to unauthorized third parties.

7Speaking conducts regular audits to verify operational compliance with data security policies.

Thus, it agrees to take the physical, technical and organizational security measures necessary to:

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

Nevertheless, the security and confidentiality of personal data depend on the good practices of each individual, so you are invited to remain vigilant on this issue.

 

7Speaking chooses its subcontractors and service providers carefully and requires them to:

  • offer a level of personal data protection equivalent to its own;
  • use personal data or information only for the purpose of managing the services they are to provide;
  • strictly comply with applicable laws and regulations on privacy and personal data;
  • implement all appropriate measures to ensure the protection of personal data that they may be required to process;
  • define technical and organizational measures necessary to ensure security.

In accordance with legal obligations, 7Speaking signs contracts with its subcontractors that precisely define the terms and conditions of personal data processing.

 

7 – Transfer of Data Outside the European Union

7Speaking stores personal data within the European Union.

 

 

8 – Focus on Extra Services

As part of your subscription to 7Speaking products and services, you may be eligible for extra services. You may freely subscribe to these services with the provider of such services. Only the provider of the subscribed extra service(s) is the data controller in the sense of the regulation on personal data, for the personal data concerning you that it processes. It is your responsibility to find out the terms and conditions according to which said supplier processes your personal data from the supplier directly.

Please be aware that we may have to transfer your personal data to an extra service supplier, if it is necessary for said supplier to provide you with their services.

 

9 – Your rights and how to exercise them

 

 

9.1- The content of your rights

Any person concerned, benefits from the following rights related to the data which concern them:

  • right of information;
  • right of access;
  • right of rectification ;
  • right of erasure (except if is is necessary for the performance of the services, or if they are necessary for 7Speaking to comply with its legal obligations or to establish or exercise its rights);
  • the right to set up instructions on what to do with the data after the death of the person concerned.

Under the right of access, 7Speaking may charge you a reasonable fee based on administrative costs for any additional copies of the data beyond the copy that is provided.

You also have:

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

You may request to exercise your right to object to the processing of your personal data on grounds relating to your particular situation where the processing is based on the legitimate interests of 7Speaking. This right to object also applies to profiling.

If you exercise your right to object, 7Speaking will stop processing the data, except where 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 may also object to any processing related to canvassing without having to cite reasons related to your particular situation.

 

 

9.2 – L’exercice des droits

You can exercise your rights by sending an email to the address [email protected] or by mail to the Delegate for the protection of personal data, accompanied by any means allowing to establish your identity to the following address:
7Speaking – Délégué à la Protection des Données personnelles
Tour Europe – 33 Place des Corolles
92400 Courbevoie

 

The communication of specific post-mortem instructions and the exercise of rights shall be made by postal mail, accompanied by any means of establishing your identity, to the Personal Data Protection Officer, at the following address:

7Speaking – Délégué à la Protection des Données personnelles
Tour Europe – 33 Place des Corolles
92400 Courbevoie

 

9.3 –  Withdrawal of consent

You may also withdraw your consent at any time, in cases where you have been asked to do so (the withdrawal of your consent will not affect the lawfulness of the processing carried out before the withdrawal of consent).

 

9.4 –  Filing a claim

If you believe, after having contacted us, that your rights on your data are not respected, you can address a complaint to the National Commission of Data processing and Freedoms (CNIL).