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Privacy Policy

Privacy Policy

The company responsible for the processing:

PROLINGUA INTERNATIONAL srl (limited liability company).

Registered office in Rome via dei Lucchesi, 26 - CAP 00187

Rea n. RM-1466038 / VAT number and Fiscal Code 13680271007

Scope of Application

We are delighted by the interest expressed in our company and its activities, but we are also aware of the importance of protecting the data generated by this interest.

ProLingua International S.r.l. (“ProLingua”; “we”, “us”, “our”) provides consulting and project development for language training, services, and solutions for linguistic and cultural learning, both in-person and online, to public and private organizations, universities, training institutions, and individuals. We utilize digital tools for management and service delivery, as well as Web and Mobile applications through the ProLingua Portal https://portale.prolingua.it and related services with selected partners and platforms such as Rosetta Stone, Moodle, GlobalExam, and any other platform useful for achieving training objectives (the “Service”). We also manage the websites https://www.prolingua.it, https://www.prolingua.international, and https://www.unipont.it (the “Websites”) to promote enrollment in the Service.

We are committed to protecting the privacy of those who visit our Websites (“Visitors”), those who enroll in synchronous online and in-person courses with ProLingua staff (“Students”), and those who register to use the Service exclusively online (“Users”) — collectively referred to as “you” or “your.”

ProLingua’s Privacy Policy (“Privacy Policy”) applies to all personal data collected via the Websites (for example, through various digital tools such as chatbots, Landbot, forms, interactive questionnaires, specific landing pages, and third-party eLearning platforms from our partners). It also applies to the analysis of individual learning data tracked and processed on online learning applications (e.g., through adopted management systems and third-party platforms of our partners) to ensure monitoring, guidance for learners, and optimization of the user experience (“UX”) while helping achieve the goals of the learning plans for Learner Engagement (“Learner Engagement”).

Through this Privacy Policy, we explain our policies, practices, and measures taken to protect your personal data in compliance with Article 13 of the European Union GDPR Regulation on Data Protection 2016/679.

Our Fundamental Data Protection Principles

ProLingua is committed to implementing the following principles to safeguard the confidentiality of your personal data:

  • We collect only the personal information necessary to provide the Service or the Websites.

  • We use your personal information exclusively for the purposes specified in this Privacy Policy, unless otherwise agreed upon for specific services offered, including through third-party platforms or specific activities.

  • We do not retain your personal information once it is no longer necessary.

  • Apart from what is specified in this Privacy Policy, we do not share your personal information with third parties.

  • When we provide our Service under a contract with an organization (e.g., your university or employer enrolling you in our services), that organization controls the personal information processed by the Service. For more information, see the “Data Processing on Behalf of the Client” section.

General Information

Responsible Body

 

We, ProLingua International S.r.l., act as controllers under the European Data Protection Regulation (GDPR). This means that we are the legal entity determining the purposes and methods of processing personal data for our services, in collaboration with our partners for third-party platforms such as Rosetta Stone © and GlobalExam ©. If you have any questions or concerns about how your information is handled, please direct your inquiries to:
Address: Via dei Lucchesi, 26 – 00187 Rome
Phone: +39 06 3936 7722
Email: privacy@prolingua.it

 

Data Protection Officer

Our Data Protection Officer is:
Name: Leila Kamberi
Address: Via dei Lucchesi, 26 – 00187 Rome
Email: privacy@prolingua.it

 

Data Processing on Behalf of the Client

 

ProLingua also provides its Services to both public and private organizations. When the Service is made available to the user through their organization that has subscribed to ProLingua’s Service (e.g., their university, training institution, or employer), that organization acts as the data controller for the user’s personal data, and ProLingua is appointed as the data processor under Article 28, Paragraph 3 of the GDPR.
In such cases, data processing is subject to a specific Data Processing Agreement between the organization and ProLingua. For any questions or requests regarding your personal data for such User Service accounts, please contact your organization directly.

 

Processing for Another Purpose

The purposes for which we process your personal data are described above in the "Scope of Application" section of this Privacy Policy. We will inform you if your personal data is processed for any other purpose, such as one different from the original reason for which the data was collected.
If you are an organization and wish to ensure compliance with EU GDPR when using ProLingua's services as a provider, you may use our Consent Template for Personal Data Processing. Please return the completed and signed consent form to privacy@prolingua.it.

What information do we collect about you and why?

We process your personal data primarily to fulfill contractual obligations towards subscribers of our Services. Data processing is required, for example, to be able to provide you with our language training services in person or online and for all monitoring procedures and pedagogical and technical support to ensure the success of training projects.
We also process your data to preserve our legitimate interests taking into account your interests (for example when you sign up to our newsletter or ask us to update you on news and promotions or authorize us to use photos in which you may have been captured during live events in which you participated). In some cases, we are legally obliged to process the data (for example, to transmit data to authorities and for tax obligations).
In all other cases, we will expressly ask for your consent to the processing of your data (for example, when you register for one of our webinars, a promotional event or an online conference).

Information Provided by Users During Service Use or Website Visits

 

Information Provided by Users for Course and Exam Registration

We collect information about you when you register through enrollment forms to access courses offered by our language school, take exams, receive attendance certificates and level achievements, and make payments.
When you register, you create your profile, which you can later modify, set preferences, enroll in courses, or make purchases through the Service. For example, when you enroll in a course, you provide your contact information (name, address, phone number, email address, the organization/university/institution you belong to, and your direct supervisor, if applicable) so we can identify you, interact with you, and deliver the Service effectively.
You may also choose to add a nickname to protect your real identity when interacting with us or other Service users, and specify your time zone to ensure profile settings and Service schedules match. We record your preferences when you select settings within the Service (e.g., training objectives or topics of interest for language learning).
The collected data is processed using various digital tools to ensure the Service is delivered. We ensure that every platform we use complies with EU GDPR standards for data protection (see the “Privacy Policy of All Our Providers and Partners” section).

 

Information for Synchronous Online Language Learning

In addition to the “Information Provided by Users for Registration” mentioned above, for synchronous online courses, we collect data about users participating in virtual classroom sessions on Zoom or Teams to track attendance and deliver the Service.
This data may include participation details useful for educational purposes and monitoring the success of training programs. Some sessions may be recorded with prior authorization from individual students. These recordings are made available exclusively for educational use and are not shared with anyone outside the course attendees or school staff.

 

Information Provided for Our Partners’ Platforms

ProLingua partners with some online language learning platform providers, such as Rosetta Stone© and GlobalExam©. Data collected is used for user registration for the requested service. Necessary data includes name, surname, email address, language and subject of study, and interface language. Optional data may also be tracked to improve user management, such as phone numbers for support, organizational affiliation, division/department, and project-related notes.
The user’s email address serves as their username, and a password is chosen during profile setup. Users can modify or recover their password at any time.
Learning data is tracked to enhance user experience and guide users in their training journey. Data on training content usage can be viewed by the “Admin” responsible for the training project and downloaded as spreadsheet reports. Users can also download or request their learning progress reports. Reports for users registered through an organization (e.g., a university or employer) are made available to the “Admin” responsible for the organization’s subscription.
ProLingua analyzes learning data, such as usage time and accessed content, to provide pedagogical guidance and technical support to both users and organization admins. This usage is described further in the "Tracking Learning Data for Learner Engagement" section.

 

Tracking Learning Data for Learner Engagement

Data collected through our partners’ platforms is stored, processed, and managed on our cloud servers to ensure the Service’s functionality for registered users or organizations.
Analyzed data is used to send email communications to individual users. For example, user behavior is monitored to provide step-by-step guidance on using the platform (e.g., Best Practices). If a registered user does not complete their profile or begin using the registered Service, they are prompted with a detailed procedure to complete it. Similarly, users enrolled in specific applications based on their level or training needs receive automated tutorial emails explaining how to make the most of the platform and its content.
These automated communications are processed through the Active Campaign platform, which syncs a necessary subset of processed data from the server to facilitate the correct targeting of messages. Periodic follow-ups are also sent based on training strategies agreed upon with the user or organization, informing them of progress and providing tips for optimizing learning.
Users requiring personal support are routed to automated workflows in Active Campaign or Zendesk, depending on the type of support needed.

 

Content Provided Through the Service

The Service includes ProLingua products used by you, where we collect and store content you publish, send, receive, and share. Examples include comments on our Forum, responses during training, messages and interactions with our staff as part of the language training Service, and any feedback you provide. Content also includes files and links uploaded to the Service.

 

Information Provided as a Website Visitor

You may browse our websites without providing personal data. However, to access content such as manuals, tutorials, eBooks, infographics, or participate in webinars, events, or conferences hosted by ProLingua, you must provide personal data via our websites, such as name, surname, email address, and organizational affiliation (if applicable).
By submitting your data, you consent to its processing and the use of your email address to receive special ProLingua content or event invitations. You may update your mailing/content preferences or unsubscribe by clicking the link at the bottom of our emails.

 

Information Provided via Support Channels

The Service you’ve subscribed to includes customer support through our help desk system, where you can submit requests for pedagogical or technical support.
When requesting support, you may need to provide contact information, a summary of the issue encountered, and any additional documentation (e.g., screenshots or videos) necessary to resolve the issue through our help desk.
We use Zendesk as our help desk partner. Zendesk consolidates customer information and interactions in one place, ensuring priority-based issue resolution.
Zendesk Inc. is located at 1019 Market Street, San Francisco, CA 94103-1612, USA. Under GDPR Article 6.1.b, data processed via the help desk is protected by ProLingua’s agreement with Zendesk, which is certified under the EU-US Privacy Shield.
For more details on Zendesk’s data processing, please refer to their Privacy Policy: Zendesk Privacy Policy.

 

Payment Information

When registering for a paid Service, we collect specific payment and billing information, such as billing details, name, and contact information. Payment data (e.g., credit card information) is processed through secure payment processing services provided by Stripe and PayPal.
Stripe and PayPal are online payment providers that facilitate virtual card payments. Payment data is transmitted to these providers when you select “Credit Card Payment” during the checkout process.
Users may revoke consent for Stripe or PayPal to process their data at any time, though this does not affect data required for payment processing.

 

Privacy Policies of Our Providers and Partners

  • Google Drive

  • Bluecloud (ScuolaSemplice)

  • ArubaCloud

  • Wix.com

  • Rosetta Stone

  • GlobalExam

  • Active Campaign

  • Zendesk

  • Zoom

  • Microsoft Teams

  • Google Meet

  • Moodle GDPR

  • Teamsystem Enterprise

  • PayPal

  • Stripe

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