What Does This Privacy Policy Cover?
This Privacy Policy explains how Nagwa Limited ("Nagwa") collects and uses personal information in connection with the products and services governed by this Policy. These products and services shall be referred to as our “Services” for the rest of this Policy.
Our Services may be purchased by providers of educational services, such as schools, universities, education authorities, and educators (collectively referred to as “Organizations” in this Policy). They may also be purchased by individuals such as students (collectively referred to as “Individuals” in this Policy).
In this Policy, a "User" refers to any individual who utilizes Nagwa’s Services, including employees and students of Organizations that have purchased Nagwa’s Services, as well as Individuals who have purchased Nagwa’s Services themselves. In each case, we may need to collect "User Data" (defined as any personal information or data related to a User that is collected by or on behalf of Nagwa) to provide our Services.
This Policy covers how Nagwa handles User Data as a data processor when providing Services to Organizations. It also covers how Nagwa handles User Data as a data controller when providing Services to Individuals.
Nagwa’s Commitment
We are committed to upholding the rights of users as defined under the UK Data Protection Act 2018 and the UK GDPR and by following these Privacy Principles:
- Creating a safe and secure digital learning environment for you,
- Not sharing or selling your personal information to third parties that are not directly involved in delivering Nagwa Services (unless we are required to by law),
- Providing you with access to and control over the information you give us,
- Not showing any external advertisements on Nagwa Services.
We consider all User Data that we collect to be strictly confidential. In general, we do not use such data for any purpose other than improving and providing our Services to the User. Our collection, use, and sharing of User Data is governed by our contracts with the Organization or Individual that has purchased our Services.
What If My Account Was Provided for Me by an Organization?
If your access to Nagwa’s Services is provided by an Organization, then the Organization is the data controller for any User Data uploaded or accessed through the Services. The Organization is responsible for ensuring it has a legal basis for processing this data. Nagwa may process this data on the Organization’s behalf as a data processor.
What User Data Does Nagwa Collect and Store?
To provide our Services effectively, Nagwa needs to collect and store certain pieces of User Data.
By subscribing to our Services, you consent to Nagwa storing and processing the following information about you:
- First and last name
- Email address
- Country of residence
- Phone number (for authentication and SMS notifications)
- Usage of Nagwa’s Services, such as the pages you visit and the actions you take
- Education-specific data such as en, grade, and term
- In some instances, for Services used by Organizations, additional data may be collected, for example, when a school is using our admissions system. Please consult your Organization for more details.
Organizations are responsible for ensuring that any information they upload to the Services is accurate. Administrators and tutors who use Nagwa Services may also generate User Data. For example, Nagwa Services may track learner assignment scores, responses to interactive exercises, grades, and more. This data can be compiled into reports in some Nagwa Services. Nagwa is not responsible for the disclosure of such data by Users.
For more information on what data will be collected by specific Nagwa Services, please contact [email protected].
How Do Nagwa Services Collect User Data?
We collect the information that forms your User Data when
- you or your Organization share your information with us by registering or using our Services,
- you contact us through electronic or non-electronic methods,
- you open emails from us or interact with our website, mobile apps, or other Services. This information is collected through cookies. Please read our cookie policy for more information.
We use Google Analytics to collect, monitor, and analyze information. Google has its own privacy policy, which can be found at https://policies.google.com/privacy. Google Analytics collects data on demographics, behaviour, and interactions with websites.
We use Adjust, a mobile app analytics and marketing software. Their privacy policy can be found at https://www.adjust.com/terms/privacy-policy/. Adjust collects data on user behaviour and ad interactions.
We also use META Services (such as advertising and social login). Their privacy policy can be found at https://web.facebook.com/about/privacy/. META collects personal information data, activity data, device information, location data, and content interactions. In order to opt out of META collecting your data, please visit the META privacy center and you will be able to manage how your data is collected and used there.
Who Will Nagwa Share My Data With?
We do not sell any User Data. We also do not share any User Data with any third parties not directly involved in delivering Nagwa Services, unless required to by law.
Nagwa may disclose User Data if it has a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to
- satisfy any applicable law, regulation, legal process, or enforceable governmental request;
- enforce applicable Terms of Service, including investigation of potential violations thereof;
- detect, prevent, or otherwise address fraud, security, or technical issues;
- protect against imminent harm to the rights, property, or safety of Nagwa; its users; or the public as required or permitted by law.
We may also have to share User Data if Nagwa becomes involved in a merger, acquisition, or any form of sale of some or all of its assets. The legal basis for such a transfer would be our legitimate interests. You would be notified of the proposed transfer and given the option to delete your account. In such an event, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.
We use anonymized aggregated data to analyze how our Users interact with our Services in order to improve them and develop new Services. When we do this, we ensure that all direct identifiers to any person are removed, meaning the data is no longer considered personalized under data privacy regulations.
What Laws and Regulations Does Nagwa Follow When Handling My Data?
When you purchase access to Nagwa’s Services or when we contact you for marketing purposes, we act as a data controller. In accordance with the GDPR, we are required to inform you of the legal basis for processing your User Data.
We may use User Data
- to enter into a contract with you (such as when you purchase Nagwa’s Services),
- to comply with our legal obligations (such as if we are required to report, share, or archive personal information in a specific way),
- for business purposes that align with our legitimate interests as a commercial provider of educational Services,
- with your consent (such as when we explicitly ask for your permission to use your User Data in a particular way).
When we process User Data on behalf of an Organization, the Organization acts as the data controller and determines the legal basis for processing your User Data. If you have any questions regarding this, please contact the Organization that has provided you with access to Nagwa’s Services.
Will Nagwa Send Me Marketing Communications? How Can I Opt Out?
We may use the contact details provided by Users of our Services to inform them about other Services offered by Nagwa, unless they choose to opt out.
Marketing communications will not be sent to any User who has opted out. Users may opt out of receiving marketing communications at any time. All marketing communications from Nagwa will include an “Unsubscribe” link at the end.
How Can I Help Keep My Data Safe?
Securing your User Data is very important to us. We implement appropriate security measures to protect against unauthorized access and to verify your identity before granting your account access or making corrections to your information.
We recommend creating and maintaining a strong password to help protect your account and never sharing it with others.
We also advise using our Services only on secure networks and keeping your internet security and virus protection up to date on any devices used to access our Services. If you suspect a data breach or have security concerns, please change your password immediately and contact us at [email protected].
Improper collection or misuse of User Data is considered a violation of this Privacy Policy. Please report any such incidents to [email protected].
Organizational customers and their Users must not misuse any User Data accessible through the Services or collect User Data either manually or in a semi-automated or automated manner.
If we become aware that any Individual or Organization (including its Users) has violated this Privacy Policy or our Terms and Conditions, we may immediately terminate their access to our Services without notice.
How Long Will Nagwa Keep My Data?
We will keep your User Data for as long as you are a Nagwa customer and for any duration after this time where your data is required for processing in order to fulfill our Services, unless the law requires or permits longer.
Will My Data Be Sent to Another Country?
We provide our Services internationally. In accordance with GDPR requirements, all service providers are audited to check that they comply with GDPR requirements and substantially follow Nagwa’s Privacy Policy.
To deliver the Service, we use a number of third-party data processors that are contractually committed to delivering the Privacy Policy described in this document.
Your information, including personalized User Data, may be transferred to (and maintained on) computers located outside of your state, province, eg, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. This includes areas outside of the European Union. To ensure GDPR compliance, Nagwa has standard contractual clauses in place where necessary. For example, companies in the US are registered with Privacy Shield.
Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.
In the event that a dispute arises with regard to the international transfer of data, you agree that the courts of England and Wales shall have exclusive jurisdiction over the matter.
What If I Am under 18 Years of Age?
We provide Services that may be aimed at Users under the age of 18. We take the utmost care to only request the information necessary to provide our Services from these Users.
If you are under the age of 18 and have any questions regarding your User Data and how it is used by our Services, we recommend you contact your parent or legal guardian or the Organization through which your access to our Services has been set up.
What Rights Do I Have Regarding My User Data?
You may have rights in certain regions, such as the European Economic Area, in relation to your User Data. These include the rights to updating and correcting your personal information, obtaining a copy of your data upon request, and erasure of your data if it is no longer essential for us to retain it in order to fulfill the purposes for which it was collected. You may also request to restrict the processing of your data, in which case we may no longer be able to offer you our Services.
If you have access to Nagwa Services through your Organization and you have queries or concerns, then please contact the administrator for the Organization. If you directly purchased access to Nagwa Services as an Individual customer, then you can contact us with your request using the contact details given at the end of this Privacy Policy. We will consider and act upon any request in accordance with any applicable data protection laws.
If your access to Nagwa Services was purchased by yourself, a parent, or a guardian, and you are unhappy with our privacy practices, you may have the right to complain to the Information Commissioner (if you are based in the UK), or to your local data protection supervisory authority.
Data Deletion
Users who wish to delete their personal data can do so through the Nagwa Classes app. To delete your account and all associated data,
- navigate to “My Account”,
- go to “Account Management”,
- select “Delete Account”.
By clicking “Delete Account”, all User Data will be permanently removed, including access to any purchases made.
User data will be deleted immediately unless otherwise required by law.
Alternatively, Users can request data deletion by contacting us at [email protected]. We will process the request accordingly.
Will We Make Changes to This Privacy Policy?
From time to time, we may make changes to this Privacy Policy. We will always clearly display the date on which the latest update was made.
How Can I Contact Nagwa?
If you have any queries about our Privacy Policy, please contact us at
Nagwa Limited
York House
41 Sheet Street
Windsor
SL4 1DD
T: +44 (0)1753 832 522
Email: [email protected]