Privacy Policy

1. Data controller

Mundus Verba sp. z o.o., trading as Emma English Club, is the controller of personal data processed in connection with your use of emmaenglishclub.com and enquiries about lessons.

2. Data we process

Data you provide through the contact form

• name, email address and — if provided — phone / WhatsApp number;
• information about your learning goal, preferred format and level;
• your message and the language version of the website used to submit the form.

Technical data

Our hosting provider may process basic technical data associated with serving the website, such as IP address, request date and time, browser or device type, and requested URL. This is used to deliver the site, maintain security and diagnose technical problems.

Placement test

Your placement-test answers and result are calculated locally in your browser. They are not automatically sent to Emma English Club and are not stored in cookies or localStorage. Reloading or closing the page resets the test progress.

3. Purposes and legal bases

• Responding to your enquiry, recommending lessons and arranging a trial lesson — Art. 6(1)(b) GDPR (steps taken at your request before entering into a contract).
• General correspondence, website security and technical administration — Art. 6(1)(f) GDPR (our legitimate interests).
• Tax, accounting or other legal obligations — Art. 6(1)(c) GDPR if a contract is concluded.

The contact form does not subscribe you to a newsletter or marketing communication. We do not use automated decision-making or profiling.

4. Service providers and international transfers

To operate the website we may use processors acting on our behalf, including:

• Netlify, Inc. — website hosting and content delivery (CDN);
• Formspree — contact-form processing and delivery of enquiries;
• email and IT service providers — only to the extent needed to handle correspondence and operate the business.

Netlify and Formspree are US-based providers. They use GDPR transfer mechanisms, including Standard Contractual Clauses (SCCs), for relevant international transfers. We do not sell personal data.

5. How long we keep data

• Enquiry data where no contract is concluded: normally up to 12 months after the last contact, unless earlier deletion is appropriate.
• If you become a client: data connected with the service is kept for the duration of the relationship and for periods required by tax, accounting and legal-claims rules.
• Technical hosting logs are retained according to the hosting provider’s operational and security settings for as long as necessary to deliver and secure the service.

6. Cookies and similar technologies

The website does not store placement-test progress in localStorage or similar browser storage. Therefore we do not display a cookie-consent banner. The hosting provider may process technical request data server-side to serve and secure the website; we do not use it for advertising profiles.

If we introduce analytics or marketing technologies that require consent in the future, we will update this policy and implement consent before those technologies are activated.

7. Your rights

Subject to the conditions set out in the GDPR, you may have the right to access, rectify, erase or restrict your data, receive portable data, and object to processing based on legitimate interests. Where processing is based on consent, consent can be withdrawn at any time without affecting prior lawful processing.

To exercise your rights, email hello@emmaenglishclub.com. You also have the right to lodge a complaint with the Polish supervisory authority, the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl.

8. Security and external websites

We use appropriate technical and organisational safeguards, including HTTPS encryption and access controls. Links to external services such as Instagram or LanguageCert lead to websites operating under their own privacy rules; once you visit them, their operators are responsible for their own processing.

9. Changes and contact

We may update this policy when website features, service providers or legal requirements change. The current update date appears at the top of the document.