Privacy Policy

1.1. Onmind.coach is an online educational service for background learning of the English language, the operator of personal-data processing for which is English Club TV Ltd (United Kingdom, registration number 07771326). User data are collected and processed solely within the limits necessary for the operation of the Service.

1.2. This Policy is an integral part of the Terms of Service and is applied inseparably from them.

1.3. The Policy has been drawn up taking into account the legislation of Ukraine on the protection of personal data, the legislation of the United Kingdom (UK GDPR and the Data Protection Act 2018) as the country of registration of the Rightholder, and the corresponding principles of the GDPR (the General Data Protection Regulation of the EU) in the applicable part.

2.1. Registration, authorization, subscription, the linking of a payment card, or any other conscious interaction with the Service means that You have familiarized Yourself with this Policy and grant unambiguous consent to the processing of Your personal data on the conditions set out herein.

2.2. Consent is granted for an unlimited term and may be withdrawn in the manner described in § 12. The withdrawal of consent does not have retroactive effect with respect to processing that took place prior to the moment of such withdrawal.

3.1. We are guided by the principle: we collect only that without which the Service cannot function or improve. No excessive, surplus, or “just in case” data.

4.1. Registration data that You provide directly:

• name or username;
• email address;
• password (stored in a secure, encrypted form);
• language and other personal interface preferences (native language, the language being learned, level of preparation).

4.2. Data related to subscription and payment:

• the fact of subscription, its type and status (monthly at EUR 5 / annual at EUR 30 with a 7-day trial — or the equivalent in the User’s currency);
• the date the payment card was linked, the dates of trial start and end, the scheduled charge date;
• payment history — in the form of technical transaction identifiers provided by Stripe.
• Important: the full payment details (card number, expiration date, CVV) are not collected or stored by us. All of this information is transmitted directly to our payment partner — Stripe — and is processed exclusively on its side in accordance with international payment security standards (PCI DSS) and Stripe’s own policy. On our side we receive from Stripe only an anonymized token and, if necessary, the last four digits of the card and the name of the payment system (Visa, Mastercard, etc.) for display to You in the personal account.

4.3. Technical data collected automatically:

• IP address;
• type and version of browser, operating system, device (in particular, smartphone, tablet, computer may be encountered; platforms such as Android, iOS, web, and others — in the currently supported or planned variants);
• system language, time zone;
• pages You open within the Service, time spent on them, sequence of transitions, audio listened to, and materials read;
• cookies and similar technologies (see § 7 for details).

4.4. Educational and user data: levels, themes, and tasks completed; words learned in the personal vocabulary; progress statistics; playback-speed settings; selected books and bookmarks; and other data that You consciously enter or generate in the process of learning.

4.5. Support requests: the text of Your messages, descriptions of situations, attached files, and accompanying service data.

4.6. Data related to security and Agreement compliance: technical logs of actions within the Service, indicators of possible breaches, attempts at unauthorized access, non-standard methods of using the Service — to the extent necessary to protect the rights of the Rightholder, other Users, and third parties.

5.1. We do not collect and do not store: full bank-card numbers, CVV codes, passwords for third-party services, biometric data, or special categories of personal data (concerning health, religion, political views, sexual orientation, and the like), unless You yourself decide to share such information in the text of a response in the interface — for which, we remind You, responsibility for the decision to share rests with Your choice.

6.1. Personal data are processed solely to achieve the following purposes:

• providing You with access to the Service and its functionality;
• identification of the User and ensuring the security of the account;
• technical support of the annual subscription trial: recording the moment of card linkage, tracking the seven-day period, and timely initiation of automatic charging through Stripe;
• processing of subscriptions, renewals, cancellations, and other payment operations (via Stripe);
• personalization of the educational experience — selection of levels, themes, and repetitions in line with Your progress;
• sending service messages — about subscription status, the approach of the trial’s end, upcoming charges, updates, technical maintenance, and important changes;
• sending informational and marketing messages — solely with Your separate consent and always with the possibility of opting out;
• analysis of User behaviour in anonymized, aggregated form — in order to make the Service better;
• detection, prevention, and termination of abuse, breaches of the Terms of Service, actions aimed at hacking, unauthorized access, or other unlawful conduct; protection of the Rightholder’s intellectual property rights;
• responding to Your requests to the support service;
• compliance with the requirements of applicable law.

6.2. We do not use Your data for purposes not specified in this Policy without obtaining additional consent. Whatever is not expressly and obviously permitted by this Policy as a purpose of processing is not carried out.

7.1. The Service uses cookies and similar technologies (browser local storage, pixels) for:

• preserving Your session and settings;
• ensuring correct operation of the interface;
• analytics (in anonymized form).

7.2. You may manage cookies through Your browser settings — prohibit, delete, or allow them. Please note: a full disabling of cookies may render part of the Service’s functionality inaccessible.

8.1. We do not sell Your personal data. We do not exchange them and do not transfer them to advertising networks in a personally identifiable form.

8.2. We transfer a limited amount of data solely to those trusted service providers without which the operation of the Service would be impossible:

• Stripe — for payment processing, card linkage, trial management, and subscription management;
• providers of cloud infrastructure and hosting — for data storage and ensuring stable operation;
• analytics tools (in anonymized form);
• email delivery services — for sending technical and (with Your consent) informational messages;
• application stores (in particular Apple App Store, Google Play, etc.) — to the extent necessary for the distribution and updating of mobile applications, where such applications are currently released or planned for release.

8.3. Each such partner operates on the basis of its own privacy policies and data-security obligations. We choose those who maintain high standards.

8.4. We may disclose data at the request of authorized state bodies — solely in cases expressly provided for by law and to the extent corresponding to such requirements. We may also disclose data to the minimum extent necessary to protect the rights of the Rightholder, other Users, and third parties — for example, in cases of detected abuse, fraud, hacking, or other breaches.

8.5. Since the Rightholder is registered in the United Kingdom, and the Service’s infrastructure may use international cloud platforms, part of the data may be transferred and processed outside Ukraine — including in countries that ensure an adequate level of data protection, or on the basis of appropriate contractual safeguards (standard contractual clauses).

9.1. We take reasonable and available technical and organizational measures to protect Your data: encryption of communication channels (HTTPS), secure storage of passwords, restriction of staff access, and regular security updates.

9.2. At the same time, we state honestly: no digital system in the world is absolutely invulnerable. We do everything within our power, but we do not guarantee the impossibility of any leak, hack, or unauthorized access in force-majeure circumstances or as a result of the actions of third parties.

9.3. Security is a shared matter. On Your part, You undertake to:

• set a strong password and not share it with others;
• use up-to-date software;
• be cautious with public Wi-Fi networks;
• notify us immediately of any suspicion of unauthorized access.

9.4. If You do not observe basic rules of digital security, we cannot bear responsibility for the consequences.

10.1. Personal data are stored for exactly as long as is necessary to achieve the purposes of processing, but no longer than the periods established by law.

10.2. General reference points:

• account data — for the entire time the account exists and for a reasonable period after its deletion (for the resolution of possible disputes and compliance with legal requirements);
• payment and subscription data — for the period prescribed by the tax and financial legislation of Ukraine and the United Kingdom;
• technical logs and security data — for the periods necessary for the detection and investigation of possible breaches;
• analytical data in anonymized form — may be stored longer for statistical purposes.

11.1. As a data subject, You have the right to:

• know which of Your data are being processed;
• obtain access to them;
• demand clarification, correction, or supplementation of inaccurate information;
• withdraw Your consent and demand the deletion of data (subject to lawful exceptions — for example, financial and tax reporting and data-retention obligations connected with possible disputes or investigations);
• restrict processing in defined cases;
• transfer data in machine-readable format (in cases provided for by applicable law);
• unsubscribe from marketing communications with a single click.

12.1. All inquiries related to the exercise of Your rights should be sent to the support service using the contacts provided in Section XI. We respond within reasonable time frames.

13.1. The Service is not intended for persons who have not reached the age at which, under the current legislation of Ukraine, the United Kingdom, or the User’s country of residence, a person may independently grant consent to the processing of personal data and conclude paid contracts.

13.2. If You are a parent or legal guardian and have discovered that a child uses the Service without Your knowledge, please notify us, and we will take the necessary measures.

14.1. We reserve the right to update this Policy from time to time. The current edition is always available on the website with an indication of the update date.

14.2. By continuing to use the Service after an update, You confirm Your consent to the new edition.

15.1. This Policy is interpreted and enforced in accordance with the current legislation of Ukraine and the United Kingdom (UK GDPR, Data Protection Act 2018), and the applicable norms of international law in the field of personal-data protection.

English Club TV Ltd

6, St David’s Square, Westferry Road, London, E14 3WA, United Kingdom

Registration number: 07771326

VAT: GB 129 3366 06

DUNS: 217450301

Partner website of the Rightholder: https://english-club.tv

Service: https://onmind.coach

Contacts page: https://english-club.tv/contacts/

For privacy and personal-data questions (Customer Support):

Email: customer.support@english-club.tv

Tel: +44 (208) 133 66 77

Marketing: marketing@english-club.tv

Distribution: distribution@english-club.tv