What Does This Privacy Policy Cover?
This Privacy Policy explains how Nagwa collects and uses personal information in relation to the products and services that are linked to 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, teachers, tutors, etc. (collectively referred to as “Organizations” in this Policy). Our Services may also be purchased by individuals such as students (collectively referred to as “Individuals” in this Policy).
In this Policy, a “User” is defined as any person making use of 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 have to collect “User Data” (here defined as any personal information or data pertaining to any User that is collected by, or on behalf of, Nagwa) in order 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 European Union General Data Protection Regulation (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 to you by an Organization, then the Organization is the data controller for any User Data uploaded or accessed by 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?
In order to provide our Services effectively, there are a number of pieces of information (User Data) that Nagwa needs to collect and store.
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 language, grade, and term,
- In some instances, for Services used by Organizations other 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, teachers, and tutors that 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 with us or using our Services,
- You contact us via either 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.
We use Appsflyer, a mobile app analytics and marketing software. Their privacy policy can be found at https://www.appsflyer.com/trust/privacy/.
We also use Facebook Services (such as advertising and social login). Their privacy policy can be found at https://web.facebook.com/about/privacy/.
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 the delivery of Nagwa Services, unless required to by law.
Nagwa may release 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 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.
We use anonymized aggregated data to analyze how our Users interact with our Services in order to improve them and come up with 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 for the purposes of 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. Following the European General Data Protection Regulation, we are required to inform you of the legal basis for handling 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 obligated to report, share, or archive personal information in a specific way),
- For a range of business purposes that are in our legitimate interests as a commercial provider of educational Services,
- With your consent (such as when we specifically ask you to consent to the use of your User Data in a particular way).
When we handle User Data on behalf of an Organization, the Organization is the data controller and will establish the legal basis for handling your User Data. If you have any questions regarding this, please contact the Organization that has provided you with the use of Nagwa’s Services on your behalf.
Will Nagwa Send Me Marketing Communications, and How Can I Opt Out?
We may use the contact details provided by Users of our Services to inform Users about other Services on offer from Nagwa unless the User chooses to opt out.
Marketing communications will not be sent to any User that has opted out of receiving them. Users may opt out of receiving marketing communications at any time. All marketing communications sent by Nagwa will contain an “Unsubscribe” link at the end of the communication.
How Can I Help Keep My Data Safe?
Securing your User Data 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.
We advise you to create and maintain a strong password to help ensure the security of your account and to never share it with others. We also urge you to only use our Services via secure networks and to maintain up-to-date internet security and virus protection on the devices from which you access our Services. Please change your password immediately if you suspect there has been a data breach or if you have security concerns, and contact us using [email protected].
If User Data is collected improperly or misused, this is considered a violation of this Privacy Policy. Please report it 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) are in violation of this Privacy Policy or our Terms and Conditions, we may immediately terminate, without notice, the Individual or Organization’s access to our Services.
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, country, 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. This includes the right to update and correct your personal information, obtain 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.
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]