This Policy applies as between you, the User of this Web Site and About Global Media Group LLC the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.
About Global Media Group LLC is the data controller responsible for your personal data. We are a Florida Limited Liability Company (Document Number L22000412242) based in Orlando, Florida, United States.
In this Policy the following terms shall have the following meanings:
"Account": means collectively the personal information, Payment Information and credentials used by Users to access Material and / or any communications System on the Web Site;
"Content": means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site;
"Cookie": means a small text file placed on your computer by About Global Media Group LLC when you visit certain parts of this Web Site. This allows us to identify recurring visitors and to analyse their browsing habits within the Web Site.
"Data": means collectively all information that you submit to the Web Site. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems;
"About Global Media Group LLC": means About Global Media Group LLC, Orlando, Florida, United States;
"EEA": means the European Economic Area;
"GDPR": means the General Data Protection Regulation (EU) 2016/679;
"UK GDPR": means the GDPR as retained in UK law by the European Union (Withdrawal) Act 2018, as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019;
"Service": means collectively any online facilities, tools, services or information that About Global Media Group LLC makes available through the Web Site either now or in the future;
"System": means any online communications infrastructure that About Global Media Group LLC makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;
"User" / "Users": means any third party that accesses the Web Site and is not employed by About Global Media Group LLC and acting in the course of their employment; and
"Website": means the website that you are currently using (www.speakinglebanese.com) and any sub-domains of this site unless expressly excluded by their own terms and conditions.
Without limitation, any of the following Data may be collected:
2.1 name;
2.2 date of birth;
2.3 job title & profession;
2.4 contact information such as email addresses;
2.5 demographic information such as post code, preferences and interests;
2.6 payment information (processed securely by our payment processor — we do not store full card details);
2.7 IP address (automatically collected);
2.8 web browser type and version (automatically collected);
2.9 operating system (automatically collected);
2.10 a list of URLs starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected);
2.11 course progress, assessment results, and learning activity on the platform; [NEW]
2.12 communications you send us, including support requests; [NEW] and
2.13 Cookie information (see Clause 14 below).
3.1 Any personal Data you submit will be retained by About Global Media Group LLC in accordance with the retention periods set out in Clause 10 of this Policy.
3.2 Unless we are obliged or permitted by law to do so, and subject to Clause 5, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.
3.3 All personal Data is stored securely in accordance with applicable data protection and privacy laws, including the GDPR for users in the European Union, the UK GDPR and Data Protection Act 2018 for users in the United Kingdom, the Personal Information Protection and Electronic Documents Act (PIPEDA) for users in Canada, the Privacy Act 1988 (Cth) for users in Australia, and applicable United States federal and state privacy laws including the California Consumer Privacy Act (CCPA) for California residents. For more details on security, see Clause 13 below.
3.4 Where the GDPR or UK GDPR applies, we are required to identify a lawful basis for each type of processing we carry out. The following table sets out how and why we use your Data and the lawful basis we rely on:
3.4.1 Providing the course platform and your account — Lawful basis: Performance of a contract (Article 6(1)(b) GDPR). We need this data to deliver the service you signed up for.
3.4.2 Processing payments — Lawful basis: Performance of a contract (Article 6(1)(b) GDPR) and compliance with legal obligations (Article 6(1)(c) GDPR) (e.g. financial record-keeping).
3.4.3 Sending you course-related communications (e.g. progress updates, instructor messages) — Lawful basis: Performance of a contract (Article 6(1)(b) GDPR).
3.4.4 Sending you marketing emails about our products and services — Lawful basis: Consent (Article 6(1)(a) GDPR). You may withdraw your consent at any time by clicking the 'Unsubscribe' link in any marketing email.
3.4.5 Improving our platform and services, internal analytics and record keeping — Lawful basis: Legitimate interests (Article 6(1)(f) GDPR). Our legitimate interest is in running and improving our e-learning business. This processing does not override your rights and interests.
3.4.6 Complying with legal obligations (e.g. tax records, responding to lawful requests from authorities) — Lawful basis: Legal obligation (Article 6(1)(c) GDPR).
3.4.7 Contact for market research purposes — Lawful basis: Legitimate interests (Article 6(1)(f) GDPR), or consent where required.
About Global Media Group LLC may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, search engine facilities, advertising and marketing. The providers of such services do not have access to certain personal Data provided by Users of this Web Site. Any Data used by such parties is used only to the extent required by them to perform the services that About Global Media Group LLC requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with applicable data protection and privacy laws.
We use the following categories of third-party service providers who may process your personal Data on our behalf as data processors. All processors are required to handle your Data in accordance with applicable privacy law and our instructions:
5.1 Platform hosting — LearnWorlds (e-learning platform provider). Your account data, course progress, and activity are stored on their platform. LearnWorlds is certified under the EU-US Data Privacy Framework (including the UK Extension) and additionally applies Standard Contractual Clauses (SCCs) for EU/UK data transfers. Data is stored on Google Cloud servers located in Europe and the USA. LearnWorlds processes data in accordance with their Data Processing Agreement.
5.2 Email marketing — MailerLite, Inc. We use MailerLite to manage our mailing list and send marketing and transactional emails. MailerLite is certified under the EU-US Data Privacy Framework, the Swiss-US Data Privacy Framework, and the UK Extension to the EU-US DPF.
5.3 Payment processing — Stripe, Inc. handles all card and subscription transactions. We do not store full payment card details; these are handled directly by Stripe under PCI-DSS standards. Stripe is certified under the EU-US Data Privacy Framework. For details, see Stripe's Privacy Policy at stripe.com/privacy.
5.4 Scheduling — Calendly is used to book 1:1 tutoring sessions and oral proficiency assessments. Calendly collects your name, email address, and scheduling preferences. For details, see Calendly's Privacy Policy at calendly.com/privacy.
5.5 Live session delivery — 1:1 tutoring sessions and oral proficiency assessments are conducted via Zoom. Zoom may process your name, email address, and video/audio data during sessions. Zoom is certified under the EU-US Data Privacy Framework. For details, see Zoom's Privacy Policy at zoom.us/privacy.
5.6 We will update this section as we add new service providers. A current list is available on request by emailing hello@speakinglebanese.com.
6.1 About Global Media Group LLC may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.
6.2 In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller.
- 7.1 Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
- 7.1.1 use of Data for direct marketing purposes; and
- 7.1.2 sharing Data with third parties.
- 8.1 You may access certain areas of the Web Site without providing any Data at all. However, to use all Services and Systems available on the Web Site you may be required to submit Account information or other Data.
- 8.2 You may restrict your internet browser’s use of Cookies. For more information see Clause 10 below.
9.1 Where the GDPR, UK GDPR, or other applicable privacy laws apply, you have the following rights regarding your personal Data. We will respond to all valid requests within 30 days. There is no charge for exercising these rights in most circumstances. To exercise any of the rights below, please contact us at hello@speakinglebanese.com.
9.2 Right of Access — You have the right to request a copy of the personal Data we hold about you and information about how we process it (commonly known as a Subject Access Request).
9.3 Right to Rectification — You have the right to request that we correct any inaccurate or incomplete personal Data we hold about you. You can update most account information directly by logging into your account.
9.4 Right to Erasure ("Right to be Forgotten") — You have the right to request that we delete your personal Data in certain circumstances, for example where the Data is no longer necessary for the purpose for which it was collected, or where you withdraw your consent and there is no other lawful basis for processing. We may need to retain certain Data where we have a legal obligation to do so (e.g. financial records).
9.5 Right to Restriction of Processing — You have the right to request that we restrict how we process your Data in certain circumstances, for example while a dispute about accuracy is resolved.
9.6 Right to Data Portability — Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal Data in a structured, commonly used, machine-readable format and to have it transmitted to another controller where technically feasible.
9.7 Right to Object — You have the right to object to processing based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will stop processing your Data for that purpose immediately. Where you object to processing based on legitimate interests, we will stop unless we can demonstrate compelling legitimate grounds that override your rights.
9.8 Rights Related to Automated Decision-Making — We do not currently make decisions about you based solely on automated processing that produce legal or similarly significant effects. If this changes, we will update this Policy and provide you with appropriate rights and information.
9.9 Right to Withdraw Consent — Where we process your Data on the basis of consent (e.g. marketing emails), you may withdraw that consent at any time by clicking 'Unsubscribe' in any marketing email, or by contacting us at hello@speakinglebanese.com. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
9.10 California Residents — If you are a California resident, you have additional rights under the CCPA, including the right to know what personal information we collect and how it is used, the right to delete your personal information, the right to opt out of the sale of your personal information (note: we do not sell personal information), and the right to non-discrimination for exercising your privacy rights. To exercise your CCPA rights, contact us at hello@speakinglebanese.com.
10.1 We retain your personal Data only for as long as is necessary for the purposes set out in this Policy or as required by applicable law. Our general retention periods are as follows:
10.2 Account and course data — Retained for the duration of your active account, plus up to 3 years after account closure to allow for re-enrolment, dispute resolution, and legal claims. Course completion records and certificates may be retained for longer to support verification requests.
10.3 Payment and financial records — Retained for 7 years from the date of the transaction, as required by US tax law and applicable financial regulations.
10.4 Marketing data — Retained until you unsubscribe or withdraw consent, after which we will retain a suppression record (your email address only) to ensure we do not contact you again.
10.5 Support and communications — Retained for up to 3 years from the date of the communication.
10.6 Automatically collected technical data (logs, IP addresses) — Retained for up to 12 months for security and analytics purposes.
10.7 At the end of the applicable retention period, your Data will be securely deleted or anonymised.
11.1 About Global Media Group LLC is based in the United States, which is outside the European Economic Area (EEA) and the United Kingdom. When you use our services, your personal Data will be transferred to and processed in the United States.
11.2 The United States does not have a general EU or UK adequacy decision. We take the following steps to ensure that transfers of your Data from the EEA or UK to the US are lawful and protected:
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11.2.1 Our four primary third-party processors — LearnWorlds, MailerLite, Stripe, and Zoom — are all certified under the EU-US Data Privacy Framework (EU-US DPF), which has been recognised by the European Commission as providing an adequate level of protection for personal data transferred from the EU to the US. MailerLite and LearnWorlds are additionally certified under the UK Extension to the EU-US DPF, covering UK transfers.
- 11.2.2 As a supplementary safeguard, LearnWorlds additionally applies Standard Contractual Clauses (SCCs) approved by the European Commission under GDPR Article 46(2)(c).
- 11.2.3 For any processors not covered by the DPF, we rely on Standard Contractual Clauses (SCCs) for EEA transfers and the UK International Data Transfer Agreement (IDTA) or UK-addendum SCCs for UK transfers.
11.3 You can verify DPF certifications for our processors at dataprivacyframework.gov/list.
11.4 If you would like further information about the safeguards in place for international transfers of your Data, please contact us at hello@speakinglebanese.com.
12.1 Our services are not directed to persons under the age of 13. We do not knowingly collect personal Data from children under 13. If you are between 13 and 18, you should use our services only with the supervision or consent of a parent or legal guardian.
12.2 If we become aware that we have inadvertently collected personal Data from a child under 13 without appropriate consent, we will take steps to delete it promptly. If you believe we may have collected Data from a child under 13, please contact us at hello@speakinglebanese.com.
Data security is of great importance to About Global Media Group LLC and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online. Our platform is hosted on infrastructure that uses industry-standard encryption for data in transit (TLS) and at rest.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of it (where required by applicable law) and will notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms.
We use Cookies on this Web Site. For full details of the Cookies we use, the purposes for which we use them, and how to manage your Cookie preferences, please see our Cookie Policy at www.speakinglebanese.com/cookie.
15.1 If you are located in the European Union or European Economic Area and you are not satisfied with how we handle your personal Data or your privacy rights request, you have the right to lodge a complaint with the data protection supervisory authority in your country of residence, place of work, or place of the alleged infringement. A list of EU supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en
15.2 If you are located in the United Kingdom and you are not satisfied with how we handle your personal Data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO): https://ico.org.uk/make-a-complaint/
15.3 If you are located in Canada, you may contact the Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca
15.4 If you are located in Australia, you may contact the Office of the Australian Information Commissioner: https://www.oaic.gov.au
15.5 We would appreciate the opportunity to address your concerns before you contact a supervisory authority, so please reach out to us first at hello@speakinglebanese.com.
About Global Media Group LLC reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Web Site. Where changes are material, we will notify you by email. You are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations.
If you have any questions regarding this Privacy Policy, wish to exercise any of your data subject rights, or have a privacy complaint, please contact us:
About Global Media Group LLC
Orlando, Florida, United States
Email: hello@speakinglebanese.com
We aim to respond to all privacy-related enquiries within 30 days.
