Privacy Policy

Person responsible for data collection:

Lewins, Gasser, located at Obere Leihofstrasse 11, 8820 Wädenswil (Switzerland), (hereinafter referred to as "Lewins" or "We").

E-mail address: privacy@lewins.com

General Information

Lewins offers online language services (hereinafter the "Services") to users, which are accessible via the website www.Lewins.com / (hereinafter the "Site") or via a learning platform installed on the user's device (hereinafter the "Platform"). In this context, Lewins is committed to respecting the privacy of Users. Lewins is therefore committed to protecting the confidentiality of the data collected and to complying with both national legislation on the collection and processing of data and the European Regulation 2016/679 of 25 May 2018, known as the General Data Protection Regulation (hereinafter: "GDPR"). This policy on the use of personal data (hereinafter: "Privacy Policy") describes Lewins' practices regarding the collection of personal data (hereinafter: "Data") when consulting the Website, placing orders, requesting information and performing services through the Website or the Platform or through other electronic means of communication. By "use of personal data" we mean any handling of data that can identify you as a natural person. On the other hand, the data collected by Lewins as part of a study on language skills (in particular to refine the tests offered to users) are anonymized and are used solely to compile anonymous aggregate statistics. This data is not subject to individual processing and is therefore not subject to the data protection provisions. The data we collect is defined in detail in the section "Data Collection", which we ask you to read carefully. Lewins is committed to respecting your privacy and providing you with as much information as possible so that you can control what happens to your data.? Therefore, below you will find more information about what data we collect, why we collect it, how long we keep it, what rights you have and how you can exercise them.

Data Collection

Lewins collects data about different types of users who may combine different profiles:

Regular users who browse the Website without voluntarily providing data to Lewins (hereinafter referred to as "Users"). Individuals who actively express interest in acquiring Services and voluntarily provide data to Lewins (hereinafter referred to as "Interested Parties"). This may include:

  • - A User who shares his or her email address in order to take a free trial offered by the Services (hereinafter referred to as a "Tester").
  • - A user who creates a customer account in order to order the Services (hereinafter referred to as the "Customer")
  • - The final recipient of the Services, who activates the "Load&Learn" key in order to receive the Services (hereinafter referred to as the "Student").

Below are the different types of data that we collect and that may be collected cumulatively:

The data that is automatically collected each time a user accesses the Website:

  • - IP address
  • - Date and time of access to the website
  • - Pages used
  • - Type of browser used
  • - The platform and/or operating system installed on the device (computer, tablet, smartphone)
  • - The search engine and keywords used to find the page

Data provided to Lewins by interested parties that enables us to contact you and provide the Services (login, gender, first name, last name, email address, date of birth, interests, native language, preferred language, time zone, city, country, Facebook,and Google login API)

Data related to your orders with Lewins Services

Data collected from interested parties when contacting our customer service (in particular by email) in order to provide you with the best possible services (for the performance of the services concerning you or in the context of pre-contractual measures) The information collected automatically when a student or customer uses the website or the platform:

  • - Operating activities (which are recorded in a designated file in the form of a "log"), including the user's login, functions performed, execution time or "timestamp," and workstation used via the user's IP address
  • - Connections to the course platform

Lewins will only use your data to the extent necessary for the purposes for which it was collected.

For what purposes and on what legal basis do we use your data?

Lewins uses your data for various purposes; in each case, we only use the data that is necessary to achieve the intended purpose. We use data when it is necessary:

In the context of the initiation of a contract, its performance or its termination (Article 6.1.b. GDPR). For example, to provide you with the requested services, to answer your questions about the services, to ask your opinion about the services and to optimize your searches when you are on our website.

To comply with the legal and regulatory requirements to which Lewins is subject (Article 6.1.c GDPR). On the basis of our legitimate interests, ensuring in such cases that these are balanced with respect for your privacy, especially if you are a minor (see the section on "Handling Children's Data") (Article 6.1.f. GDPR). We may therefore use the contact details of data subjects for the purposes of information, advertising and marketing Lewins' products and services. In particular, this allows us to do the following:

  • - Send you our newsletter
  • - Offer you new products, services or special promotions that may be of interest to you (by mail, phone, email or via social media)
  • - Send you promotional offers

Finally, Lewins may, with your consent, collect and use data to send you promotional messages if you are not already listed as an interested party. In this regard, you may request to unsubscribe from these promotional messages at any time. With whom may we share your data?

We only transfer your data to third parties if:

  • - it is necessary for the proper performance of our services
  • - it is necessary for the fulfillment of a legal obligation
  • - you give us permission

In order to perform our services, we may subcontract some or all of our tasks to technical subcontractors, such as an IT company for website hosting and data storage and backups. We ensure that subcontractors handle your data in the same way we do, i.e. in a secure, respectful and responsible manner, and we provide appropriate contractual safeguards in this regard. Lewins therefore requires its subcontractors to comply with data protection laws and to provide sufficient guarantees regarding the implementation of appropriate technical and organizational measures so that the use of data complies with the requirements of applicable data protection laws and ensures the protection of your rights.

Your rights

Right of access You have the right to access your data at any time and free of charge.

Right to rectification You have the right to request the rectification of inaccurate data and the deletion of data that is inappropriate or no longer needed.

Right to deletion If you no longer wish your data to be used and request its deletion, we will delete your data from our database.

It should be noted that it is not always possible to delete all requested personal data, for example, if their processing is essential for the establishment, exercise or defense of legal claims or because the judicial authorities are obliged to retain such data. You will receive further information on this subject, if necessary, in the response to your request.

Right to data portability To the extent necessary, you also have the right to data portability under the terms of applicable data protection laws. Please note that data portability is only possible for data that you yourself have provided to Lewins on the basis of consent or a contract. This right to data portability therefore only applies to customer and student data.

Right to object to the processing of your data What happens if you no longer want or are able to receive commercial communications? You have the right to object to the use of your personal data for direct marketing purposes without having to provide a reason. For this purpose, you can request to unsubscribe from these commercial communications at any time.

Right to restrict use Finally, you have the right to restrict Lewins' use of your data in accordance with applicable data protection laws.

Exercising your rights You may exercise the above rights at any time by either sending us an email at the address privacy@Lewins.com or by sending a letter to Lewins headquarters at this address: Place de Obere Leihofstrasse 11 , 8820 Wädenswil, Switzerland. How long do we keep your data??

We are not able to retain your information beyond the period necessary to fulfill the purposes for which it was collected. However, Lewins may use the contact information of prospective customers to identify them and notify them of new Lewins products and promotions for a period of 2 years. As a reminder, you may request to unsubscribe from these promotional communications at any time. After the expiration of the retention periods described above, the personal data will be deleted or anonymized, unless its retention is required by law, in particular in the case of compliance with the obligation to keep records for accounting and tax purposes.

Security

We have developed adapted technical and organizational security measures to prevent the destruction, loss, falsification, alteration, unauthorized access and unintentional disclosure of data to third parties, as well as any other unauthorized handling of data. For example, Lewins securely synchronizes databases containing user or customer data on three different physical carriers in different locations. To protect the entire system from viruses and security breaches, system software and application software packages are updated as soon as a security update is available. To protect against outside attacks, a firewall is installed on each server and configured by our network administrator. Access to the servers is also restricted by a private-public key, with the private key encrypted (DES 256). Finally, each Lewins employee's individual computer is equipped with automatically updated and professional virus protection. In addition, developers or employees working on the infrastructure are equipped with a computer that has a fully encrypted hard drive. In the event of a data leak with adverse consequences for your data, you will be personally notified under the circumstances and within the time limits required by law. To ensure the security of your data, we advise you to:

  • - Do not share your password with third parties
  • - Change your password regularly
  • - Make sure that access to your computer/tablet/smartphone is secure

You are solely responsible for your customer account and the consequences of its use, as well as for information of any kind you share with Lewins. Lewins will not be liable for any damages resulting from incorrect, incomplete or fraudulent information you submit to us.

Privacy guarantee for telecommunications

All transmissions of personal data are encrypted via "https" pages. ?This mainly concerns all administration tools (server administration, database access, server access). ?All communication between servers is encrypted using TLS technology, and access to the server is via encrypted SSH and VPN connections.?This guarantees a high level of data security and confidentiality.? In addition, all user and supervisor passwords are stored encrypted (SHA256) in our database and cannot be read externally or internally by Lewins. For this reason, we also only send new passwords and never an existing password. This is a very important security measure to prevent unauthorized access to strictly personal and confidential data.?

Links to third party sites

We would like to inform you that our website may contain links to third party websites, and that some of our services may give you access to third party services (e.g. social networks). We have no control over how third party websites and services handle your information. We do not review third-party websites and services, and we are not responsible for these third-party websites and services or their Practices related to the protection of your data. We invite you to carefully read the data processing policies of third party websites that you access from our website.

Handling of data relating to children

We do not intentionally collect personal information from children under the age of 16 without the express permission of a parent or guardian. In the event that we have inadvertently collected data from children under the age of 16, we will take steps to delete that data as soon as possible, unless we are required by law to retain it.

Changes to the Privacy Policy

Lewins reserves the right to change this Privacy Policy from time to time, especially in the event of changes in the law. We therefore ask you to always consult the latest version of the Privacy Policy on our website Lewins.com/privacy/).? Contact us

If you wish to contact Lewins regarding this Privacy Policy (for example, to exercise your rights or to lodge a complaint about the processing of your data), you may do so:

By email: privacy@Lewins.com By mail to the address: ?Lewins, Gasser
Obere Leihofstrasse 8820 Waedenswil Switzerland?

Please do not hesitate to contact us if you feel that we have not handled your information properly. We will do our best to process your request as soon as possible. If you are dissatisfied with our response, you can also contact us directly and file a complaint with the data protection authority. ?

Data protection supervisory authority

Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter Feldeggweg 1, CH - 3003 Bern +41 (0)58 462 43 95. https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/kontakt/kontaktformular.html

COOKIE POLICY

General Information

This Cookie Management Policy aims to provide as clear and complete information as possible about the cookies we use and their purpose. We also invite you to read our Privacy Policy to learn more about the rules that apply to the protection of personal data. A cookie is a small data file that is stored on the hard drive of your computer, tablet or smartphone when you visit a website. The cookie is placed on your device by the server that hosts the website. The server recognizes your device based on the unique ID number of a cookie when you return to that website. There are different types of cookies, categorized by origin, function and lifetime.

What types of cookies do we use?

Essential cookies: these cookies ensure that you can browse our websites and applications as well as use functions (e.g. the shopping cart and your privacy settings).

Functional cookies: these cookies facilitate the operation of our websites and applications and enable a personalized browsing experience, for example, by storing login names, passwords and preferences, such as language settings. These encrypted cookies are installed directly by Lewins for a period of one year.

Analytics and advertising cookies: these cookies collect data about the use of our website and platform, such as the number of visitors, popular web pages and the time users spend on a particular page. To this end, we use third-party cookies for statistical and marketing purposes, such as Google Analytics, Google Universal Analytics, Google Tag Manager, and Facebook.

These cookies contain information that we use to process your requests and improve our services on the Internet. You can control or prevent the storage of cookies. Please note that a website may not work as well after changing the settings. The same applies to mobile applications. If you would like to learn more about controlling and managing cookies, please visit www.allaboutcookies.org.