Updated: July 24, 2022
3524 Silverside Road Suite 35B Wilmington city, New Castle County, DE, 19810-4929
To contact Data Protection Officer: email: firstname.lastname@example.org
Anyone can access our Website without the necessity to register an account. Therefore, limited use of the Services is always possible without the provision of your personal details (for example, browse the Website, check how GIOS Inc works, look through the list of tutors, read the GIOS Inc Blog, review the variety of services, etc.). However, whenever you access the Website, we collect log information and put cookies on your device, by which we track your activity on the Website. You can always opt out of cookies except those, without which the Website cannot work. When you are a registered User GIOS Inc may collect from you and process Cookie identifiers and those data you specifically provide us with upon registration, including first name, last name, email, phone number, Skype ID, or social network ID (if assigned through Facebook or Google+ or if accessing Google Calendar), time zone, interface language, IP address, and device type, as well, whereas in case of Telegram subscription, your Telegram ID may also be processed by GIOS Inc.
Specifically, if you are a tutor, we may also collect and process, besides the aforementioned information, the other data provided by you, including zip-code, gender, year of birth, city of residence, and education experience.
Registered Users may additionally provide us with added profile pictures as well as chosen currency to perform actions pursuant to our Refund and Payment Policy.
Any questions regarding this Policy and our services should be sent to email@example.com
Personal data is any information relating to you and that alone or in combination with other pieces of information allows a person that collects and processes such information to identify you as an individual.
Processing of the personal data means any operation with your personal data, whether or not by automated means, as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; means you as a user of GIOS Inc.
Consent of the data subject/user is any freely given, specific, informed, and unambiguous indication of the data subject/user's wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
GIOS Inc processes your personal data only when we have lawful bases. Specifically, GIOS Inc processes your personal data if:
In all cases, we will notify you about the applied legal basis for processing and other relevant details, before we start the processing of your personal data on a specific legal basis unless we are not able to do so in accordance with our obligations under any applicable legislation.
GIOS Inc collects from you only the following information and only for the stated below purposes:
(1) Account for Students
GIOS Inc collects and processes personal data submitted by you upon registration and further editing of settings in your Account. For registration purposes, you submit your login credentials (username and passwords), first name, last name, and email. You may also edit your Account anytime with additional information as well as sync your Google and GIOS Inc Calendars. Such additional information may help you to find a suitable time slot with a tutor or to have more visibility of your schedule. At the same time, you are not required to provide additional information, not specifically necessary for the registration, it is your choice.
(2) Account for Tutors
GIOS Inc collects and processes personal data submitted by you upon registration and further editing of your Profile. For registration purposes, you submit your login credentials (username and passwords), first name, last name, and email. You may also edit your Profile anytime with additional information as well as sync your Google and GIOS Inc Calendars. Such additional information may help you to find a suitable time slot with a student or to have more visibility of your schedule. At the same time, you are not strictly required to provide additional information, not specifically necessary for the registration. Therefore, it is your choice whether to include additional data in your profile, or not, such as zip code, country, language skills, education, and work experience.
Some personal data, such as users’ names, and location that is listed in your user profiles or derived from IP Addresses may be publicly visible to other users on the Services or to the web. We may implement a feature that permits you to choose what information is made public by changing your privacy setting in "Edit My Profile" within the Service.
(3) Subscription to the GIOS Inc BlogYou may decide to subscribe to the GIOS Inc Blog to receive newsletters and weekly updates from the GIOS Inc Blog and/or the email sequences. For this, we require you to give us your email.
(4) Posting of Information
We process personal data freely submitted by you on GIOS Inc. This may be a survey and online form you fill in on GIOS Inc, a question or comment left in the Q&A section of our website, or feedback you provide us with.
GIOS Inc may also process information provided by you (including content and messages) that you post on/through our Website, including personally identifiable information. By doing so, you acknowledge that any information you share through the Services will be available to GIOS Inc and to other users of the Services (students/tutors). You also acknowledge that parts of your content cannot be deleted from the Service as it may be connected to the Lessons created by you and used by other users (students/tutors).
From our turn and unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with the Terms of Service.
(5) Service Use, Cookies and Other Similar Technologies
When you use our Services, we monitor and analyze web traffic and keep track of your behavior while using our Services.
In particular, we may collect the following categories of information:
(6) Billing Information
We process the details of transactions you carry out through our Website (as ID, date and time of transaction).
We may collect your name, email, company name, and phone number to give you more information regarding GIOS Inc Enterprise Services.
(8) Sensitive Data
Unless you expressly agree, GIOS Inc does not process your sensitive data.
(9) Pages on Social Networks and GIOS Inc Tutors Community on Facebook (for Tutors Only)
We maintain GIOS Inc official pages in social networks, such as Facebook or LinkedIn. When you make interactions with our social network pages, such as subscribe to the pages, leave comments or preferences (e.g., ‘like’ our posts), we can analyze these data for measuring our efficiency and conduct an analysis of our social media marketing in our legitimate interests.
We maintain a "GIOS Inc Tutors Community" group on Facebook. To join the group, you shall provide your email address, with the one you are registered at GIOS Inc, and answer the questions of the Tutors Community rules. As this group is deployed on Facebook, we will process your Facebook profile information.
(10) Information Required for Submitting Tax Documentation
To comply with the applicable tax and accounting legislation, we may be required to submit various tax documentation containing your personal data. For example, a federal tax form 1099 or such other required tax form(s) necessary to receive a sweepstakes prize or withhold taxes. For submitting tax documentation, we may process your personal data including but not limited to your full name, country of citizenship, permanent residence address, mailing address, date of birth, U.S. taxpayer identification number, or foreign tax identifying number.
(11) Analysis of Speech Activity
When you give/take lessons on the GIOS Inc platform, we may analyze your microphone activity and measure the volume of the sound. We do it to provide you with an overview of your speaking activity, and to let you know how active you were during the lesson. Please be assured that we do not record your voice, words, or the content of your conversations.
If you are based in any country within the European Economic Area (EEA) or Switzerland, we will provide you with an opportunity to turn this feature off to your own preference as the processing is based on our legitimate interest.
(12) Language assessment
We process your personal data to assess your level of language proficiency. For this, we may additionally process your name, email address, and the results of your language assessment. Such an assessment may take place before or after you register on the GIOS Inc platform.
We may process the personal data you provided us voluntarily for the purposes defined below. From our perspective, we process your personal data to personalize the use of GIOS Inc to the fullest extent possible and to provide you with high-quality Services under the Terms of Service.
(1) Provision of Services
Primarily, we process your personal data to authorize access to our Services and to fulfill our obligations under the Terms of Service for Services provision. Specifically, we use your personal data upon registration to help others (be it a tutor or a student) to find your account or profile, schedule, give and/or take lessons, and track your learning progress.
In order for you to use the Services, you will need to provide payment (e.g. credit card details) and billing information through our partners – third-party payment providers, which process your personal data encrypted and securely. Please see our Refund and Payment Policy for more information.
We may also ask you to take a language assessment test in order to establish your language skills.
For Companies, we process the personal data of their Employees to create their accounts, enable access to the Services, provide language assessment and language learning performance reports.
Please note, that without the information provided by you under our Terms of Service, we will be unable to provide you with the functionality of our platform, connect you with other users, allow you to communicate with them and take/give lessons.
(2) Payment Services
We use third-party payment providers to bill you through an online account payment in lieu of directly processing your credit/debit card information. Your paid balance for one or more lessons is safe in your account as we use an integrated iframe for checkouts from our partners- payment providers (Braintree, Stripe, PayPal) and tutors get the payment for each confirmed lesson securely through third-party payment providers (Braintree, Stripe, PayPal, TransferWise). Correspondingly all transactions are secured as our partners-payment providers use SSL encryption protection. All payment information is stored encrypted and securely by Braintree, a PayPal service. We do not store your payment information on our servers.
We may also use your payment card transaction data as shared by third-party service providers to confirm a specific transaction occurred and that you qualify for a promotional offer; for example, the date and amount of your purchase and the last 4 digits of your card number so that we can verify your purchase with our records.
For referral service purposes named "Tell-A-Friend", we generate a personalized referral link for you to share with your friends to sign them up.
We may contact you via email and other ways, including through publicly available notices, for Services-related purposes (welcome letter, security and legal notices, announcements, GIOS Inc updates, reminders, suggestions, etc.). We may also use your data to enable you to communicate with other users through GIOS Inc, including exchanging messages, conducting video calls, and/or leaving feedback about other users.
Your contact data (including email, phone number, Skype name, etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including:
Your feedback will not be video recorded, audio recorded, or webcast by the Interviewer without obtaining consent from you first. The same applies to your voice and/or image recording.
Having received the communications from us, you are always able to opt out of such communications in each message, excluding legal notices, or changes of user settings on GIOS Inc.
(5) Marketing and Promotion of GIOS Inc
We may process your first name, last name and email on our mailing list or for the newsletter and send you messages with some commercial or promotional information about our Services. But don’t worry, we will request your consent first, and you may always opt out of our marketing messages, using the mechanisms described under the respective link in each message, and through the user settings available on GIOS Inc.
If you provide us with your phone number, we may also contact you with some commercial or promotional information about our Services.
To promote the GIOS Inc platform through blog and influencer channels, we allow individuals to participate in the affiliate program on our Website. When we receive the information to participate in the affiliate program, we process this information to register you as an affiliate and further track the progress of the promotion of our platform.
Also, please pay attention that we may use the information provided by you as feedback. The latter, under Section 12 of the Terms of Service, may be used by GIOS Inc without any additional compensation to you.
(6) Identifying Influencers for Potential Collaborations
We may use third party services, such as Captiv8, Inc. and LiveRamp Holdings, Inc. to analyze the information you provide to us at the time of registration (such as your name and other identifiers), execute a matching exercise, and discover our most influential students for the purposes of proposing collaboration with us. In doing so, we may receive some of your personal information from Captiv8, Inc. (such as your social media profiles), and form a joint controllership over your data. In case we discover that you are an influencer and decide to propose collaboration, we will provide you with a short privacy notice explaining this processing activity in detail.
(7) Analytics and Development
In order to establish new ways to improve the GIOS Inc Platform, find the points of interest in our Services and for the purposes of analytics, we monitor and analyze the personal data you provide us with, including information you provide upon the registration, the web traffic, Cookies and Usage data, such as the parts of our Services you visit, the date and duration of your visit, your location, type of the device you used during your visit and other relevant data on the use of the GIOS Inc Platform. For these purposes, we use Google Analytics for Firebase, Hotjar Heat Maps & Recordings, Amplitude Analytics, Branch.io, Braze, and Intercom, the use of which ensures compliance with our privacy commitments.
For the purposes indicated above, we may also run occasional research activities, including personalized "A/B" tests. During the tests, we will display different website content to the users based on various criteria, such as their country. The purpose of such tests is to understand user engagement and satisfaction of certain features in order to improve the user experience, develop new useful features, and streamline our Services.
We may also carry out polls and surveys through GIOS Inc using external GDPR-compliant services. You are not obliged to respond to them and you may opt out of such polls and surveys through user settings.
In order to inform, optimize and serve you relevant advertising based on your past use of our Services, we may process your Usage Data and Cookies. Please, follow our Cookies Policy for additional information.
(8) Tutor Verification and Program Preparation
To ensure a high quality of lessons given by tutors on GIOS Inc, we collect and process tutor credentials to verify their eligibility to teach subjects claimed by them. Besides that, we cooperate with the tutors and use their information to help them develop the learning programs.
For the purposes of analytics, we additionally process tutors’ registration data to automate and improve the tutor verification process.
(9) GIOS Inc Tutors Community on Facebook
We process data of GIOS Inc Tutors Community participants to manage our Facebook group and provide tutors with an ability to come together and share their best practices, get official up-to- date information, and interact with each other and with GIOS Inc based on our legitimate interest in community building. We also use the collected information to supervise tutors’ participation and behavior within the group.
(10) Support and Platform Supervision
In case of any disputes on GIOS Inc and other Services-connected issues, we may use data (including communications) to resolve such matters, supervise user behavior on the platform, and respond to any complaints or requests.
(11) Events and Webinars Conducted by GIOS Inc
We use the personal data we collect from you when you register and/or attend any of our events or webinars to provide you with access to such events or webinars, as well as to send you registration confirmation, reminders, associated useful materials or the information you have requested about our Services.
(12) Competitions and Sweepstakes
Competitions. From time to time, we conduct learning-focused competitions for individuals that meet certain criteria. Participants are required to fill in the registration forms to register for the competition and prove they are eligible. We process this information exclusively to organize and conduct the competition, determine the winner(s), and contact them regarding the results and prizes.
Sweepstakes. From time to time, we conduct sweepstakes among registered users that meet certain sweepstakes entry requirements. We would process your user ID, name, date of birth, country of legal residence, and email address associated with your account on the GIOS Inc platform to administer the sweepstakes (including verifying eligibility to participate in the sweepstakes, contacting you in the event you are selected to win a prize, providing the prize) and to comply with other legal requirements. To get the prizes the winners are required to submit an affidavit of eligibility and a federal tax form (or such other required tax form(s)). In addition, we may post the name of the sweepstakes winners on our Website upon your consent.
(13) Compliance with Legal Requirements
We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and/or establish our legal rights.
(14) Fraud Prevention
Certain information, such as your log information, payment information and your behavior on the platform are subject to our supervision to prevent fraudulent activities on the platform and assist you in managing your user sessions.
In order to provide high-quality services, GIOS Inc hires people, enters into agreements with independent contractors as well as cooperates with other services providers, companies and organizations strictly under data processing agreement (DPA) or Standard Contractual Clauses (SCCs). For those reasons, some of your personal data can be passed to the persons mentioned. GIOS Inc uses only secure places of storage, such as provided by AWS (Amazon, the USA) with servers located in Ireland, Germany and the United States, and other services and applications listed below.
(1) Third Party Service Providers
GIOS Inc engages service providers to support us in providing our Services. These include:
(2) Social Network Pages
We use social media platforms to maintain our public pages and communities, who are, in this case, joint controllers with GIOS Inc. Please, be advised that Facebook is a joint controller for the processing of personal data of the "GIOS Inc Tutors Community" group. In particular, Facebook and GIOS Inc are joint controllers for the group insight data and statistics, and the general data of your Facebook profilesMore information on Facebook joint controllership arrangement you may find under the following link: https://www.facebook.com/legal/terms/page_controller_addendum.
To exercise your data subject rights in respect of the "GIOS Inc Tutors Community" Facebook group, you may contact us regarding any questions related to your participation in "GIOS Inc Tutors Community" and Facebook regarding all questions devoted to your Facebook profile.
These well-known service providers will help us to ensure that your data is secure within GIOS Inc.
(3) Data transfer in case of change of control or asst disposition
(4) Companies enrolled in GIOS Inc Enterprise
We may share Employees’ language learning progress and results of language assessment with their Companies.
Your personal data will be stored by GIOS Inc no longer than is necessary for the purposes for which the personal data is processed.
Generally, GIOS Inc retains your personal data as long as your account is active. In case your account expires or you decide to delete your account GIOS Inc retains your personal data no longer than 90 days after the account is expired.
However, in case of conflict situations in progress GIOS Inc may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defense of legal claims and for compliance with a legal obligation that requires processing by Union or Member State law to which the controller is subject in case of an expired account or in case data subject requested to delete his personal data. Upon the expiry of this period or earlier, if a conflict situation is settled, all personal data gets deleted.
In case your last activity on GIOS Inc, as of the last payment date, was more than 180 (one hundred eighty) days ago, your account will be considered expired and gets deleted. Along with your account or profile, all personal data processed by GIOS Inc will be erased.
As you are entitled to delete your account or profile after such a request it will be permanently removed within 30 days or earlier from our active systems, servers and back-ups. By deleting your account or profile all your personal data will be removed as well within 90 days.
Personal Data collected when you registered on our mailing list or for the newsletter will be stored as long as you are interested in receiving our emails. We consider that you’re interested in this until you unsubscribe from the mailing list or the newsletter by clicking the respective link contained in each of our emails.
If you have registered for any of our events or webinars using your account credentials, we will merge and store this information along with your account data. If you have used other contact details, we will delete them within 30 days after conducting the event or webinar.
Lists of participants of the sweepstakes including those who entered the sweepstakes via the alternative method of entry (mail-in) will be deleted in 30 days after the close of the sweepstakes. The names of the sweepstakes winners published on our Website will remain publicly available till the withdrawal of your consent.
After the expiration of the retention period, GIOS Inc shall terminate the processing of your personal data, unless otherwise is set by the relevant legislation.
(1) Right of Confirmation
You can obtain confirmation from GIOS Inc as to whether personal data concerning you is being processed.
(2) Right of Access
You can access your personal data processed by GIOS Inc.
(3) Right to Rectification
You can ask GIOS Inc to have incomplete personal data requiring corrections completed.
(4) Right to Erasure (Right to Be Forgotten)
You can request GIOS Inc to erase personal data. In most cases, GIOS Inc will erase it unless otherwise required by legislation.
To delete your personal data, you can:
(5) Right of Restriction of Processing
You can contest the accuracy of your personal data or in case GIOS Inc is not interested in processing your personal data any longer, but you want GIOS Inc to do this for different reasons, for example, to bring a claim against somebody and, instead of the erasure of information, its processing will be restricted.
(6) Right to Data Portability
You can have your personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
(7) Right to Object to Processing of Your Personal Data by GIOS Inc
You can object to our processing of your personal data when the processing is related to the performance of our task carried in the public interest or the exercise of official authority vested in us. The other case is if we process your data for the purposes of the legitimate interests pursued by us or by a third party and you believe that such interests are overridden by your interests or fundamental rights and freedoms. If you make a request with objection to processing, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing.
(8) Right to Withdraw Consent at any Time by Contacting Us
After we at GIOS Inc receive a withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data unless otherwise is set by law.
If you believe that our use of your data violates your rights, you can lodge a complaint with the competent data protection authority.
Please note that when the processing of your personal data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification and we will no longer process your data with such direct marketing purposes.
(1) Cross-border Transfers
(2) Time for Reply and Reaction
GIOS Inc will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if GIOS Inc is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. GIOS Inc will inform you of any such extension within one month of receipt of the request, together with the reasons for such delay.
GIOS Inc takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage. For example, GIOS Inc uses verified contractors that might have access to the data with which the relevant data processing agreements are signed.
(4) Accessing Account to provide support
In exceptional circumstances, such as required customer support, our support specialists may need to access your account. When such an occasion occurs, they will be able to see the personal data submitted to your account, including your scheduled personal events, if your Google Calendar and GIOS Inc Calendar are connected.
We undertake to always ask for your permission to access your account before we start troubleshooting. Prior to granting us your permission, you might also consider editing your Google Calendar privacy settings with Google Calendar Help Center to hide your personal events from us.
Please note that if you do not want to grant your permission to access your account, it may affect the time and quality of the provision of customer support.
(5) Children’s Privacy
The privacy of children is one of our concerns. GIOS Inc Services are not intended for use by children under the age of 18 without the express permission of their parent or legal guardian. If you are under the age of 18 you will need to get your parent’s/legal guardian’s permission before submitting any personal data to GIOS Inc. We may process the personal data of children under the age of 18, provided that data has been consensually provided by parents/legal guardians for the express purpose of using GIOS Inc Services.
(6) Breach Notifications
If any personal data of yours would be under the breach, we would inform you and the respective data protection agencies as to the accidents without undue delay, if there are high risks of violation of your rights as the data subject. We would also do our best to minimize any such risks.
(7) "DoNotTrack" Requests
GIOS Inc does not share personal data with third parties for their direct marketing purposes. Also, our Services do not support "Do Not Track" requests.
(8) California Privacy Rights
In case you are a resident of California, the California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data by GIOS Inc, Inc. or its subsidiaries to a third party for the third party's direct marketing purposes. This right granted to California residents applies only to their activities within the State of California. To make such a request, please send an email to firstname.lastname@example.org
GIOS Inc considers your use of its Service to be private. However, we may disclose your personal data stored in our databases, in order to:
Your GIOS Inc Team