Privacy Policy
This Privacy Policy explains how English Grows collects, uses, protects and shares personal information, and how you can exercise your data protection rights.
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1. Who is responsible for your personal data?
English Grows is operated by an independent self-employed professional established in Spain and is subject to the General Data Protection Regulation (GDPR) and Spain's Organic Law 3/2018 (LOPDGDD).
- Trading name: English Grows
- Data controller: Edna Torres Munill
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Postal correspondence address:
English Grows
Apartado de Correos 0024
08350 Arenys de Mar, Spain - Privacy contact: info@englishgrows.com
English Grows determines the purposes and essential means of processing for its own training delivery, academic assessment and business administration. Corporate clients remain responsible for their own processing activities, including selecting employees for training and determining their lawful use of training information.
2. What personal information do we process?
This policy applies to website visitors, people making enquiries, placement-test participants, registered users, learners, employees undertaking training, teachers, company administrators, corporate contacts and marketing subscribers.
Account and profile information
Name, email address, authentication information, account role and any optional profile information you provide, such as country, language preferences or profile photograph.
Course and academic information
Course assignments, enrolment status, timetables, attendance, learning needs, language levels, assessments, teacher feedback and progress records.
Placement-test information
Email address, submitted answers, test score, recommended course level and CEFR reference. Registered users' results may also be associated with their platform accounts.
Communications and marketing
Information provided in enquiries and communications, together with optional marketing subscription details and records of consent or withdrawal.
Billing and payment information
Billing identification details, invoices, amounts charged, payment status and transaction references required for payment administration and accounting. Payment card details entered on Stripe-hosted payment pages are collected directly by Stripe.
Technical information
Technical information necessary for website operation, authentication, security and maintenance.
Sources and required information
Most information is provided directly by you. Where an employer arranges training, we may receive your identification, professional contact details and course assignment from that employer. Teachers and authorised administration may also create academic and training records.
Information required for registration, assessment or the provision of a requested service must be supplied to enable that service. Optional profile details and marketing subscription are not required to access training services.
3. Why do we process your personal data?
Individual training and account management
We process the information necessary to manage accounts, organise courses, arrange lessons, deliver training and communicate with learners about the services they have contracted.
Legal basis: Performance of a contract under Article 6(1)(b) GDPR.
Company-funded training
Where an employer contracts English Grows, we process information necessary to organise participation, deliver training, assess learning and maintain relevant training records.
Legal basis: Legitimate interests under Article 6(1)(f) GDPR in organising and delivering agreed corporate training and supporting learners' academic development.
Academic assessment and Learning Needs
Academic information is processed to identify learning requirements, personalise teaching, assess language development and support training delivery.
Legal basis: Article 6(1)(b) GDPR for individually contracted training, or Article 6(1)(f) GDPR for company-funded training, as applicable.
Placement tests
We process submitted answers and assessment information to calculate a recommended course level and communicate the result to the participant. Where a teacher is assigned, a separate result notification is sent to that teacher; otherwise, authorised English Grows administration receives the result for placement administration.
Legal basis: Legitimate interests under Article 6(1)(f) GDPR in providing the requested assessment and supporting appropriate course placement.
Optional marketing communications
Where you actively subscribe, we use your email address to send English Grows news, offers and information about our training services. Subscription is optional and requires an affirmative action through a checkbox that is not preselected.
Legal basis: Consent under Article 6(1)(a) GDPR, together with the applicable requirements of Article 21 LSSI-CE.
Completing a placement test or creating an account does not automatically subscribe you to marketing. You may withdraw consent at any time using the unsubscribe mechanism in our marketing emails or by contacting us.
Enquiries and customer support
We process information provided in enquiries to respond to requests and manage communications concerning our services.
Legal basis: Article 6(1)(b) GDPR where necessary for steps preceding a contract, or Article 6(1)(f) GDPR for general enquiries and customer support.
Billing and payment administration
We process billing and transaction information to administer payments, issue invoices and maintain accounting records.
Legal basis: Article 6(1)(b) GDPR where necessary for the contracted service and Article 6(1)(c) GDPR for applicable accounting and tax obligations.
Platform operation and security
Necessary technical information is processed to maintain the website, protect accounts, investigate technical incidents and prevent unauthorised access.
Legal basis: Legitimate interests under Article 6(1)(f) GDPR in maintaining a secure and functional service, or Article 6(1)(c) GDPR where a specific legal obligation applies.
4. Learning Needs and employer access
The Learning Needs questionnaire helps teachers understand learners' communication requirements, priorities and confidence in different language skills.
Learners can access their own responses. Assigned teachers and authorised English Grows administration may access the information required for teaching and academic administration.
Company administrators can view questionnaire submission status only (Pending or Submitted). They cannot access individual answers, confidence ratings, communication priorities or additional free-text responses through the company administration interface.
5. Who can access or receive your information?
Access to personal information is restricted according to the user's role and responsibilities. Learners access their own information, teachers access information required for their assigned courses, and company administrators access information necessary to administer their organisation's training, subject to the restrictions described above.
External service providers
English Grows uses the following providers to operate its platform, manage business communications and process customer payments.
| Service provider | Purpose of processing |
|---|---|
| Render Services, Inc. | Hosting the English Grows website, learning platform, database and associated infrastructure. |
| Google Workspace | Business email hosting and the management and delivery of service-related communications. |
| Stripe | Processing customer payments through Stripe-hosted payment pages, including payment confirmation and transaction management. |
When customers pay through Stripe-hosted pages, payment card details are provided directly to Stripe. English Grows receives the information necessary to confirm payments and maintain billing records. Stripe acts as a processor for certain activities and as an independent controller for others, in accordance with its applicable privacy terms.
Information may also be disclosed to public authorities where required by applicable law. Further information about international processing is provided in the following section.
6. International data transfers
Our service providers may process personal data outside the European Economic Area (EEA), including in the United States.
International transfers are subject to Chapter V of the GDPR and the applicable contractual arrangements. Depending on the recipient and circumstances, transfers may rely on an adequacy decision, including the EU–US Data Privacy Framework where applicable, or on appropriate safeguards such as the European Commission's Standard Contractual Clauses.
Applicable provider arrangements
- Render: Its Data Processing Addendum addresses international processing and provides for applicable Data Privacy Framework or Standard Contractual Clause arrangements. View agreement.
- Google Workspace: Its Cloud Data Processing Addendum establishes the applicable international-transfer provisions. View agreement.
- Stripe: Its Data Processing Agreement and incorporated Data Transfers Addendum establish the applicable transfer mechanisms. View agreement.
You may request further information about international transfers affecting your data and how to obtain a copy of the relevant safeguards by contacting us at info@englishgrows.com.
7. How long do we retain your information?
Personal information is retained for the period necessary to fulfil the relevant processing purpose, taking account of applicable legal, contractual and evidential requirements.
- Account information: While the account is required for the service, and afterwards only where a valid retention purpose remains.
- Course and academic records: For training administration and academic follow-up, subject to applicable contractual or legal requirements.
- Placement-test attempts: For result delivery and related placement administration, including necessary follow-up.
- Marketing information: While the subscription remains active. Following withdrawal, limited information may be retained where necessary to respect the request or demonstrate compliance.
- Billing and accounting records: For the periods required under applicable commercial, accounting and tax legislation.
When information is no longer required for its original purpose or another valid retention basis, it is deleted or anonymised where appropriate.
8. Your data protection rights
Subject to the conditions established by law, you may request access, rectification, erasure, restriction of processing and data portability, or object to processing where applicable.
You may withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal. You may object to direct marketing at any time.
You may also exercise applicable rights concerning automated individual decision-making.
To exercise your rights, contact us at info@englishgrows.com. We may request additional information where necessary to verify your identity. Requests are normally answered within one month, subject to extensions permitted by the GDPR.
You also have the right to lodge a complaint with the Spanish Data Protection Authority (AEPD). Visit the AEPD website .
10. Security and automated assessment
English Grows applies technical and organisational safeguards designed to protect personal information against unauthorised access, disclosure, alteration and loss.
Placement-test answers are scored automatically to generate a recommended course level. The result supports course placement, may be reviewed by a teacher and does not constitute formal CEFR certification.
11. Changes to this Privacy Policy
This policy may be updated to reflect changes in our services, processing activities or applicable legal requirements. The current version and revision date will be available on this page.