Owner and Data Controller
Virtual Mentor Inc., 251, Little Falls Drive, City of Wilmington, County of New Castle, Delaware,19808, USA
Allright Limited, 67 Kennedy Avenue, Athienitis Kennedy Park, 4th Floor, Office 401, 1076 Nicosia, Cyprus
Owner contact email: privacy@allright.com
Types of Data collected
Among the types of Personal Data that Allright.com collects, by itself or through third parties, there are:
Tracker; Usage Data; first name; last name; gender; date of birth; phone number; email address; username; password; country; city; academic background; language; various types of Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geography/region; number of Users ; In-app purchases; Application opens; operating systems; Camera permission; Microphone permission; Apple's speech recognition servers permission; Storage permission; Photo Library permission; payment data; Universally unique identifier (UUID); Data communicated while using the service.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Allright.com.
Unless specified otherwise, all Data requested by Allright.com is mandatory and failure to provide this Data may make it impossible for Allright.com to provide its services. In cases where Allright.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by Allright.com or by the owners of third-party services used by Allright.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through Allright.com.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Allright.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Displaying content from external platforms, Tag Management, Handling payments, Hosting and backend infrastructure, Advertising, Contacting the User, User database management, Registration and authentication, Registration and authentication provided directly by Allright.com, Remarketing and behavioral targeting, Device permissions for Personal Data access, Data transfer outside the EU, Platform services and hosting, Social features, Managing data collection and online surveys, Access to third-party accounts, Heat mapping and session recording, Location-based interactions, Managing contacts and sending messages, Managing web conferencing and online telephony and Productivity.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Facebook permissions asked by Allright.com
Allright.com may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows Allright.com to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Email
Provides access to the User's primary email address.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Device permissions for Personal Data access
Depending on the User's specific device, Allright.com may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of Allright.com.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Allright.com.
Apple's speech recognition servers permission
Used for sending the User's Data to Apple's speech recognition servers.
Camera permission
Used for accessing the camera or capturing images and video from the device.
Microphone permission
Allows accessing and recording microphone audio from the User's device.
Photo Library permission
Allows access to the User's Photo Library.
Storage permission
Used for accessing shared external storage, including the reading and adding of any items.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Access to third-party accounts
This type of service allows Allright.com to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access (Facebook, Inc.)
This service allows Allright.com to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Email; Tracker.
Place of processing: United States – Privacy Policy.
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Allright.com, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google Ads conversion tracking (Google LLC)
Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on Allright.com.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Meta ads conversion tracking (Meta pixel)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Meta Audience Network with actions performed on Allright.com. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Facebook SDK
(1) tracking your actions after you have been redirected to our Platform by clicking on a Facebook ad;
(2) measuring the performance of Facebook ads for the purpose of market research and statistics, in particular to better understand and display ads and make them more relevant to you
TikTok pixel
tracking your actions after you have been redirected to our Platform by clicking on an ad on TikTok
Google Ad Manager
Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of Allright.com and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Ads Similar audiences
Similar audiences is an advertising and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of Allright.com.
On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.
Users who don't want to be included in Similar audiences can opt out and disable the use of advertising cookies by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google AdSense
Google AdSense is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. This service uses the “DoubleClick” Cookie, which tracks use of Allright.com and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
In order to understand Google's use of data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Taboola Europe (Taboola Europe Limited)
Taboola Europe is an advertising service provided by Taboola Europe Limited.
Personal Data processed: Tracker; Usage Data.
TikTok conversion tracking (TikTok Inc.)
TikTok conversion tracking is an analytics and behavioral targeting service provided by TikTok Inc. that connects data from the TikTok advertising network with actions performed on Allright.com. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of Allright.com.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google LLC)
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Allright.com, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Appsflyer (AppsFlyer Ltd)
Appsflyer is an analytics service provided by AppsFlyer Ltd.
Personal Data processed: Tracker; Usage Data.
Place of processing: Israel – Privacy Policy – Opt Out.
Amplitude Analytics (Amplitude Inc.)
Amplitude Analytics is an analytics service provided by Amplitude Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Google Analytics Advertising Reporting Features
Google Analytics on Allright.com has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics Demographics and Interests reports
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for Allright.com (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics for Firebase
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
In order to understand Google's use of Data, consult Google's partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
Allright.com uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data processed: Application opens; geography/region; In-app purchases; number of Users ; operating systems; Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Analytics collected directly (Allright.com)
Allright.com uses an internal analytics system that does not involve third parties.
Personal Data processed: Tracker; Usage Data.
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Contacting the User
Novachats
communicate with our clients and stakeholders and answer their questions and requests
Contact form (Allright.com)
By filling in the contact form with their Data, the User authorizes Allright.com to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name; phone number.
Mailing list or newsletter (Allright.com)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Allright.com. Your email address might also be added to this list as a result of signing up to Allright.com or after making a purchase.
Personal Data processed: city; country; date of birth; email address; first name; gender; last name; phone number; Tracker.
Phone contact (Allright.com)
Users that provided their phone number might be contacted for commercial or promotional purposes related to Allright.com, as well as for fulfilling support requests.
Personal Data processed: phone number.
Voximplant
Voximplant (Zingaya, Inc.) is used to communicate with our clients and stakeholders and answer their questions and requests.
Personal Data processed: phone number, name of the parent, name of the child, age, dates of latest lessons and payments.
Chat2Desk
Chat center provided by IT Prospect Limited Liability Company (IT Prospect LLC).
Personal Data processed: phone number, name of the parent, name of the child.
CallGear
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Device permissions for Personal Data access
Allright.com requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (Allright.com)
Allright.com requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Apple's speech recognition servers permission; Camera permission; Microphone permission; Photo Library permission; Storage permission.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Allright.com and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows Allright.com to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Site Search with AdSense
Google Site Search is a search engine embedding service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Allright.com to incorporate content of this kind on its pages.
Google Site Search may display AdSense advertisements. For details of which data are collected, please refer to the privacy policy of this service.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
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Handling payments
Unless otherwise specified, Allright.com processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Allright.com isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Payment by bank transfer (Allright.com)
In the event that the chosen payment method is a direct bank transfer to the current account indicated by Allright.com, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.
Personal Data processed: first name; last name; payment data.
Payments processed via the Apple App Store (Apple Inc.)
Allright.com uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.
Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.
Personal Data processed: payment data.
Place of processing: United States – Privacy Policy.
Payments processed via the Google Play Store (Google LLC)
Allright.com uses a payment service provided by Google LLC that allows the Owner to offer the purchase of the app itself or in-app purchases.
Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.
Personal Data processed: payment data.
Place of processing: United States – Privacy Policy.
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Heat mapping and session recording
Heat mapping services are used to display the areas of Allright.com that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Smartlook (Smartsupp.com, s.r.o.)
Smartlook is a session recording and heat mapping service provided by Smartsupp.com, s.r.o.
Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Czech Republic – Privacy Policy.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Allright.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Allright.com.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Germany – Privacy Policy.
Servers.com
Storage Service Providers
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Location-based interactions
ipdata.co
Ipdata.co may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by ipdata.co.
The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.
Personal Data processed: geographic position.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
ably.io
Ably (Ably Real-Time Ltd.) is used to exchange text messages
SendinBlue Email (SendinBlue SAS)
SendinBlue is an email address management and message sending service provided by SendinBlue SAS.
Personal Data processed: email address; Tracker; Usage Data.
Place of processing: France – Privacy Policy.
SendinBlue SMS (SendinBlue SAS)
SendinBlue is a phone numbers management and communication service provided by SendinBlue SAS.
Personal Data processed: phone number; Trackers; Usage Data.
Place of processing: France – Privacy Policy.
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Managing data collection and online surveys
This type of service allows Allright.com to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
SurveyMonkey (SurveyMonkey Inc.)
SurveyMonkey is a survey builder and data collection platform provided by SurveyMonkey Inc.
Personal Data processed: email address; first name; phone number.
Place of processing: United States – Privacy Policy.
Marquiz
Marquiz is an online marketing platform operated by a sole trader Balachkov Gennady Andreevich
Personal Data processed: first name; phone number.
Flow XO
Flow XO (Flow XO LLC) is an automation product that allows to build chatbots that help us to communicate and engage with our customers across different sites, applications and social media platforms.
Personal Data processed: name, title, address, telephone numbers, email address, photograph – if provided via LinkedIn or other social media
Place of processing: United States.
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Managing web conferencing and online telephony
This type of service allows Allright.com to manage the deployment, administration, hosting, recording, distribution and analysis of online telephony and web conferencing in order to communicate with Users.
The Personal Data collected depend on the information provided by the Users while using the respective service.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Opentok
Opentok (provided by Vonage Holdings Corp.) is used for videochat.
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Platform services and hosting
These services have the purpose of hosting and running key components of Allright.com, therefore allowing the provision of Allright.com from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Apple App Store (Apple Inc.)
Allright.com is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of Allright.com. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Google Play Store (Google LLC)
Allright.com is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
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Productivity
Video and audio recording
For some lessons held on our platform we record and keep video recordings of the lesson. In the application we record and keep audio of students' responses. These recordings are stored and processed on remote servers.
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Registration and authentication
By registering or authenticating, Users allow Allright.com to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Allright.com will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Facebook Authentication
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Registration and authentication provided directly by Allright.com
By registering or authenticating, Users allow Allright.com to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (Allright.com)
The User registers by filling out the registration form and providing the Personal Data directly to Allright.com.
Personal Data processed: academic background; city; country; date of birth; email address; first name; gender; language; last name; password; phone number; Tracker; username; various types of Data.
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Remarketing and behavioral targeting
This type of service allows Allright.com and its partners to inform, optimize and serve advertising based on past use of Allright.com by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Google Ad Manager Audience Extension
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that tracks the visitors of Allright.com and allows selected advertising partners to display targeted ads across the web to them.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Ads Remarketing
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Allright.com with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Remarketing with Google Analytics
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Facebook Remarketing
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of Allright.com with the Facebook advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
MyTarget
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Social features
Inviting and suggesting friends (Allright.com)
Allright.com may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.
Personal Data processed: various types of Data.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Allright.com in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Allright.com, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Allright.com.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Allright.com.
AmoCRM
(1) handling user requests;
(2) work with existing and potential clients
(3) working with teachers
Intercom (Intercom Inc.)
Intercom is a User database management service provided by Intercom Inc.
Intercom can also be used as a medium for communications, either through email, or through messages within Allright.com. Intercom Messenger may use Trackers to recognize and track Users behavior.
Personal Data processed: Data communicated while using the service; email address; Trackers; Universally unique identifier (UUID); Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Allright.com depends on the payment system used.
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Push notifications
Allright.com may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Allright.com, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Allright.com.
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The Service is directed to children under the age of 13
Allright.com is directed to children under the age of 13. It doesn't require the child to disclose any more information than is reasonably necessary to participate in its activity.
Parents may review the personal information about their child collected by Allright.com - if any - outlined in the rest of this policy, ask for its deletion and request any further collection or use to be omitted by contacting the Owner. Parents may also agree to the collection and use of their child’s information, but still not allow disclosure to third parties, unless disclosure is integral to the Service.
Cookie Policy
Allright.com uses Trackers. To learn more, Users may consult the Cookie Policy.
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Other legal basis for Data transfer abroad
If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:
- the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
- the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for establishment, exercise or defence of legal claims;
- the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via Allright.com.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Allright.com or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Allright.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Allright.com and any third-party services may collect files that record interaction with Allright.com (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Allright.com and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through Allright.com (or third-party services employed in Allright.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use Allright.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Allright.com who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Allright.com. The Data Controller, unless otherwise specified, is the Owner of Allright.com.
Allright.com (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Allright.com as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to Allright.com, if not stated otherwise within this document.