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Privacy PolicyLast modified: Oct 10, 2018

We at Nagwa know that you care about how your personal information is used and shared, and we take your privacy seriously.

Your use of Nagwa Services is at all times subject to this Privacy Policy and accompanying Terms and Conditions.

What does this Policy Cover?

This Privacy Policy explains how Nagwa collects and uses information, including our treatment of personally identifiable information in both Nagwa’s free and paid-for services.

You will be required to read and accept this Privacy Policy when signing up for an Account.

Our Commitment

Our privacy policy is controlled by our commitment to uphold the rights of users as defined under the European Union General Data Protection Regulation (GDPR), and by following these Privacy Principles:

  • We are deeply committed to creating a safe and secure online environment for you
  • We do not sell your personal information to third parties
  • We strive to provide you with access to and control over the information you give us, and we take the protection of your information very seriously
  • We do not show any external advertisements on Nagwa. We use your information to provide you with a better learning experience and improve our products

Data Sharing

We do not share any personal information with any third parties not directly involved in the delivery of the Nagwa service unless required to by law.

Nagwa may release personal information if it has a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent, or otherwise address fraud, security, or technical issues; or (d) protect against imminent harm to the rights, property, or safety of Nagwa, its users, or the public as required or permitted by law.

For further information on how Nagwa manages your information, please see the section “Nagwa Data Controllers and Data Processors”.

Personal Information that Nagwa Collects and Stores

In order to provide our services effectively, there are a number of pieces of information that Nagwa needs to collect and store.

The legal basis for the processing of your personal data is consent and by signing up to our services, you agree to Nagwa storing and processing the following information about you:

  • Your name and username
  • Your date of birth
  • Your email address
  • Country of residence
  • Your mobile number if desired (for SMS notifications and authentication)
  • Your personal usage data including, but not limited to questions answered, videos watched, and search patterns

We hold this data in order to optimize the user experience and provide a service which is unique. We will use your usage data to enhance search functionality, identify popular content, improve your user experience, and provide students with a more personalized learning experience.

A parental account has the ability to create a subsidiary account for their children. In order to do this a parent needs to provide their child’s first and last names along with a date of birth. There will also be an option to input their email address. This would be used to provide your child with reports on their academic progress including assessment scores and worksheet progress.

Additional Information Required to Use Nagwa’s Paid-for Services

If you use Nagwa’s paid-for services, the legal bases for processing will be both contractual and consent. In addition to the personal data mentioned above, we will process the following information:

  • Usage statistics for tuition services
  • Financial data including transactions and refunds
  • For the purposes of quality control and safeguarding we will store a recording of all tuition sessions
  • Any communication between yourself and Nagwa

We collect and store this data to ensure an excellent user experience and monitor the service being provided. We may review the recorded tuition sessions in the event of a complaint, or refund request.

Anonymous Data Collection Using Third-Party Analytic Services

Nagwa uses Google Analytics to collect, monitor, and analyze information to increase our Service’s functionality. Google has its own privacy policy addressing how it uses such information, see: https://policies.google.com/privacy.

Specific purposes of collecting this information include:

  • Providing anonymous statistical analysis of web page traffic patterns
  • Administration of our services and servers
  • Allowing for auditing of our services by third parties
  • Improving our general services
  • Ensuring users compliance with our Terms and Conditions

Cookies

Cookies are small text files that we transfer to your hardware, through your web browser or app in order to (a) speed your navigation on the Service, (b) recognize you and your access privileges, (c) track your usage and preferences of the Service, (d) detect the existence of any cookies previously set by our server, (e) identify certain information on how and when you accessed the Service such as type of browser, operating system, domain names, IP addresses, and the like, (f) provide you with content relevant to your locale, and (g) combat and activity that violates our policies or otherwise degrades our ability to provide our services.

The cookies used on the Nagwa website are:

Cookie Name What it does
lastlocale This cookie saves your last visited locale to redirect you to the same locale on your next visit
IamInBrowserSession This cookie links your browser session to redirect you to an appropriate locale following a previous visit.
firstvisit This cookie stores a number related to the privacy policy that you viewed so we can easily inform you when changes are made to this policy.
ASPXAUTH We use the asp auto generated cookie for the purposes of authentication.
Google Analytics We use Google Analytics cookies to inform us how users navigate our site to help us improve and optimize our website.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some features of our Service.

Nagwa Data Controllers & Data Processors

Nagwa Limited is the data controller, along with our associated company Chestnut Learning Technologies based in Egypt, for your personal information and content as defined by the GDPR. The policies set out in this document apply to both companies. The contact details for Nagwa Limited are set out at the end of this document.

Nagwa provides its 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 Nagwa service, we use a number of third party data processers who are contractually committed to deliver the privacy policy described in this document. These include:

  • Chestnut Learning Technologies, Egypt
  • Amazon Data Hosting Services, USA
  • Mailchimp, USA
  • PayPal, USA
  • Apple Store, USA
  • Google Play Store, USA

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. This includes areas outside of the European Union. To ensure GDPR compliance Nagwa has Standard Contractual Clauses in place where necessary and U.S. Companies 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 regards to the international transfer of data, you agree that the courts of England and Wales shall have exclusive jurisdiction over the matter.

Right to be Forgotten

Any user of our website reserves the right to be forgotten at any time. Upon request {link}, Nagwa will delete any and all personal information which we hold, subject to our retention policy (see below). Usage statistics will be anonymised upon a request to be forgotten and will be used to continually inform and optimize the user experience.

Right to Request Personal Data

Any user has the right to make a request {link} to access all personal information that Nagwa holds. Any such request will be acted on as quickly as possible and within the one-month period laid down by the GDPR.

Updating or Correcting Personal Information

If you register and provide Nagwa with your Personal Information, you may update, or correct your account and information at any time by reviewing your profile information. We advise you to review your information from time to time, so that you can ensure that it as accurate as possible.

Data Security

Securing users’ data and information is very important to us. We take appropriate security measures to protect against unauthorized access, and to verify your identity before granting your account access or making corrections to your information.

However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

We also advise you to create and maintain a strong password to help ensure the security of your account.

Mergers or Partnerships

If Nagwa becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, your personal information may be transferred to the purchaser. The legal basis for such a transfer would be our legitimate interests. You would be given notice of the proposed transfer at the relevant time and the option to have your account deleted. In such an event, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

Marketing

Nagwa allows you to opt-in to the receiving of marketing communications regarding our Products and Services. You have the right to object at any time to the processing of your personal data for marketing purposes.

You can manage your contact preferences, including unsubscribing, by clicking the link provided on each communication, or by contacting nagwa@nagwa.com.

Right to Object to Processing

You have the right to reject to the processing of your personal data. Our processing of your personal data is vital to our ability to provide our services; if you would like to exercise this your right to the rejection of processing you will no longer be able to have an account with Nagwa. To do this, please contact us using nagwa@nagwa.com and we will remove your account and follow the process outlined in “Right to be Forgotten”.

Right to Restriction of Processing

You have the right to demand the restriction of our processing of your personal data where we dispute your right to object to processing. In the event of your exercising of this right, we will suspend all activity on your account for the duration of any subsequent investigations.

Right to Data Portability

You have the right to request that all of your personal data be transferred to a third party. In the event of such a request to transfer your data, Nagwa will provide you with a full report of all your personal data that we hold which can be shared with a third party. We will then remove your data as outlined in ‘Right to be Forgotten’.

Right to Lodge a Complaint with a Supervisory Authority

If you are resident within the European Economic Area, you have the right to lodge a complaint with the supervisory authority in your country of residence. The supervisory authority to which Nagwa is subject is the U.K. Information Commissioner’s Office (www.ico.org.uk).

Automated Decision-Making

Automated decision making with respect to personal data encompasses any decision that is made about you by an entirely automatic process.

Nagwa does not apply automated decision-making to your personal data.

Retention Periods

We will store any financial information for a period of 6 years for tax and accounting purposes. Other personal information related to the defence or bringing of legal claims will be held for a period of 6 years. If an account becomes inactive, after a period of 2 years, we will delete your account and anonymize any usage data. If the account contains any monetary balance after this period it will be refunded to the account from which is was paid.

Changes to the Privacy Policy

We may update our Privacy Policy from time to time. We will notify you by email of any changes to this policy and will post the new Privacy Policy on this page for you to review.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If we make any material changes to this Privacy Policy, we will also notify you, either through the email address you have provided us, or by placing a prominent notice on our website.

Data Controller

Nagwa Ltd
Queen Caroline House
3 High Street
Windsor
SL4 1LD
T: +44 (0)1753 832 522
Email: nagwa@nagwa.com