Privacy Policy

1. Introduction

EnglishMaster ("we," "us," "our," or "Company") is committed to protecting your privacy and ensuring transparency about how we collect, use, and protect your personal data. This Privacy Policy explains our practices regarding data collection, processing, and your rights under applicable laws including the General Data Protection Regulation (GDPR), UK GDPR, and other international privacy regulations.

Company Details:
EnglishMaster
45 Oxford Street
London, W1D 2EB
United Kingdom
Email: info@englishmaster.com
Phone: +44 20 7946 0958

2. What Data We Collect

We collect the following categories of personal data:

Identity Information: Full name, date of birth, nationality
Contact Information: Email address, phone number, postal address
Educational Data: Current English proficiency level, learning goals, test scores, course history
Payment Information: Billing address, payment method details (processed securely through third-party payment processors)
Technical Data: IP address, browser type and version, device type, operating system, cookies and tracking identifiers
Usage Data: Pages visited, time spent on site, click paths, lesson completion rates, quiz results
Communication Data: Email content, support tickets, feedback forms, survey responses
Conversion Events: Form submissions, course enrollments, lesson bookings, purchase confirmations

3. Cookie Categories and Consent

We use cookies and similar tracking technologies divided into three categories:

3.1 Essential Cookies

Purpose: Core site functionality, security, session management, and preference storage.

Examples: session_id, csrf_token, cookie_consent_status, authentication tokens

Consent Required: No — these cookies are activated automatically and are necessary for the website to function.

Retention: Session duration or up to 12 months for preference storage

3.2 Analytics Cookies

Purpose: Measuring traffic, user behavior, site performance, and improvement of user experience.

Tool Used: Google Analytics 4

Examples: _ga, _ga_XXXXXXX, _gid, _gat

Consent Required: Yes — these cookies are activated only after the user explicitly accepts analytics cookies.

Retention: Up to 14 months

IP Anonymization: IP addresses are anonymized before storage.

3.3 Marketing and Advertising Cookies

Purpose: Remarketing, personalized ad delivery, conversion tracking, and audience building.

Consent Required: Yes — these cookies are activated only after explicit user consent.

Retention: Up to 540 days (Google Ads default)

Tools Used: Google Ads, Google Remarketing, Meta Pixel, Google Tag Manager

4. Marketing Cookies and Advertising Technologies

4.1 Third-Party Ad Serving

Third-party vendors, including Google, use cookies to serve ads based on a user's previous visits to this website and other sites on the internet. This allows us to show you relevant advertisements as you browse the web.

4.2 Advertising Partners

We work with advertising partners such as Google and Meta to deliver advertisements tailored to your interests across various websites, apps, and platforms. These partners use data collected from your browsing activity to show you relevant course offers and learning opportunities.

4.3 Remarketing

We use remarketing services to advertise to previous visitors of our website. After visiting our site, you may see our ads on other websites, apps, or platforms you visit. This helps us stay connected with interested learners.

4.4 YouTube and Display Network

Advertisements for EnglishMaster may appear across Google services including YouTube, Gmail, and the Google Display Network, based on your browsing history and engagement with our content.

4.5 Tracking Technologies in Use

We use the following tracking technologies on this website:

Cookies (first-party and third-party)
Tracking pixels (Google Ads tag / gtag.js, Meta Pixel)
Device identifiers (browser fingerprint, IP address)
Conversion event tags and page view tags

4.6 Advertising Measurement

We use conversion tracking to understand which advertisements lead to actions on our website such as form submissions, calls, lesson bookings, or purchases. This allows us to measure campaign effectiveness and allocate budget appropriately. Conversion data may be shared with Google Ads and Meta for optimization purposes.

4.7 Technologies Active on This Site

The following advertising and analytics technologies are active on this site:

Google Ads (gtag.js / Google Tag Manager)
Google Analytics 4
Google Remarketing Tag
Meta Pixel (Facebook / Instagram)

4.8 Opting Out from Personalized Advertising

You may opt out of personalized advertising at any time through the following channels:

Google Ads Settings: Visit https://adssettings.google.com to manage your Google advertising preferences
Your Online Choices (EU): Visit https://www.youronlinechoices.eu to manage your European advertising preferences
Network Advertising Initiative: Visit https://optout.networkadvertising.org to opt out of network advertising
Digital Advertising Alliance: Visit https://optout.aboutads.info to manage your ad preferences

Important: Opting out does not remove ads entirely. You will continue to see non-personalized advertisements based on your current page content and general location.

4.9 Cookie Preferences Management

You may manage your cookie preferences at any time by clicking the "Manage cookie preferences" link in the website footer. This opens a preference panel where you can accept or reject each cookie category independently. Essential cookies cannot be disabled as they are required for site functionality.

5. Consent Requirements and Cookie Banner

When you first visit our website, you will see a cookie consent banner that offers the following options:

Accept All: Activates all cookies including analytics and marketing cookies
Reject Non-Essential: Deactivates analytics and marketing cookies; only essential cookies remain active
Manage Preferences: Opens a detailed panel where you can toggle each category independently

Analytics and marketing cookies are not activated until you explicitly accept them. Your choice is stored in your browser's local storage for 12 months. You may withdraw your consent at any time without penalty by clicking "Manage cookie preferences" in the footer.

5.1 GDPR Compliance for EEA and UK Users

Users in the European Economic Area and the United Kingdom receive this consent notice in compliance with the General Data Protection Regulation (GDPR) and UK GDPR. Marketing and analytics cookies are activated solely after explicit, informed, freely given consent under GDPR Article 6(1)(a). Consent is recorded with a timestamp and may be audited upon request by supervisory authorities.

5.2 Withdrawal of Consent

You may withdraw consent at any time by clicking "Manage cookie preferences" in the website footer, or by clearing cookies via your browser settings. Withdrawal of consent does not affect the lawfulness of processing that occurred while consent was valid.

6. Data Sharing with Advertising Partners

We share certain data with advertising partners for campaign delivery and measurement. The following recipients and data categories are involved:

6.1 Google LLC

Data Shared: Cookie identifiers, conversion events, anonymized behavioral data, remarketing lists

Governing Document: Google's Privacy Policy at https://policies.google.com/privacy

Legal Basis: Standard Contractual Clauses (SCCs) for international data transfers

6.2 Meta Platforms, Inc.

Data Shared: Pixel events, conversion data, custom audiences for remarketing

Governing Document: Meta's Data Policy at https://www.facebook.com/privacy/policy

Legal Basis: Standard Contractual Clauses (SCCs) for international data transfers

6.3 Data Protection Principles

We do not sell personal data to unaffiliated third parties. All transfers to Google and Meta operate under Standard Contractual Clauses where applicable, ensuring appropriate safeguards for personal data. Google and Meta may use this data across their own platforms in accordance with their respective policies. We encourage users to review those policies directly for full transparency.

7. Lead Forms and Contact Requests

When you submit a contact form, request a consultation, or register interest in our courses, we collect the information you provide. This typically includes full name, email address, phone number, current English level, and your specific learning goals.

7.1 Legal Basis for Processing

Consent: GDPR Article 6(1)(a) — your explicit consent given by submitting the form
Contract Performance: GDPR Article 6(1)(b) — where a service relationship exists or is being established

7.2 Data Retention

Form submission data is retained for up to 2 years from the date of submission, unless a longer period is required by applicable law or for service delivery. You may request deletion of your data at any time by contacting us at info@englishmaster.com.

7.3 Privacy Notice on Forms

A link to this Privacy Policy appears adjacent to every submission button on this site. Submitting a form constitutes acknowledgment of this policy and your consent to processing as described herein.

8. Google Services and Advertising

This website uses the following Google services:

8.1 Google Analytics 4

Google Analytics 4 collects anonymized usage data, device information, and behavioral signals to help us understand how users interact with our website. IP anonymization is enabled to protect user privacy. Data retention is set to 14 months. Users may opt out via the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout

8.2 Google Ads Conversion Tracking

We use Google Ads conversion tracking to record when a user completes a defined action after clicking one of our advertisements. Actions tracked include form submissions, course enrollments, lesson bookings, and other key conversions. This data is used solely for measuring ad campaign performance and optimizing our marketing spend.

8.3 Google Remarketing

We use Google Remarketing to display EnglishMaster advertisements to previous visitors across Google's network. Remarketing lists are built from behavioral data only and do not include sensitive data categories such as health status, financial information, religion, sexual orientation, or political views.

8.4 Google Tag Manager

Google Tag Manager acts as a container for deploying various tracking tags on our behalf. GTM itself does not collect personal data; it simply manages the implementation of other tracking tools listed above.

8.5 Google's Privacy Policies

Google's advertising products and services are governed by their comprehensive privacy policies available at https://policies.google.com/technologies/ads

9. Meta Advertising Services

This website uses the Meta Pixel to measure the effectiveness of our advertising on Facebook and Instagram platforms. The pixel may record page views, time on site, specific conversion events (form submissions, course enrollments), and custom audience membership for retargeting purposes.

9.1 Data Protection Standards

We do not use the Meta Pixel to collect sensitive personal data, nor do we use it to target users based on health status, financial situation, religion, political views, sexual orientation, or any other special-category attribute prohibited under Meta's advertising policies and GDPR.

9.2 Meta's Role as Data Controller

Meta acts as an independent data controller for data collected via the Meta Pixel and processed within its own platform. Meta's use of this data is governed by their Data Policy at https://www.facebook.com/privacy/policy

9.3 Managing Your Ad Preferences

To manage your ad preferences on Meta platforms (Facebook and Instagram), visit https://www.facebook.com/adpreferences/ where you can control the types of advertisements you see based on your interests and data.

10. Prohibited Content Declaration

This website does not promote, sell, or facilitate access to prohibited product or service categories including but not limited to: weapons, controlled substances, counterfeit goods, unlicensed gambling services, adult content, or services that make misleading health or financial claims. All advertising conducted through Google Ads and Meta Ads complies with the respective platform policies in full.

11. Landing Page Integrity and Transparency

The content of this website accurately represents the products and services advertised. No bait-and-switch practices are employed. The experience delivered to users arriving from paid advertisements is identical to the experience for all other visitors. Cloaking, automatic redirects, and content variation by traffic source are not used on this website, ensuring transparent and consistent user experience.

12. Legal Basis for Processing (GDPR Article 6)

We process personal data under the following legal bases:

Contact Form Data: Consent (Art. 6.1.a) and contract performance (Art. 6.1.b)
Analytics Data: Consent (Art. 6.1.a)
Marketing and Remarketing Data: Consent (Art. 6.1.a)
Security and Fraud Prevention: Legitimate interest (Art. 6.1.f)
Course Enrollment and Learning: Contract performance (Art. 6.1.b)

13. Data Retention Periods

We retain personal data for specific periods depending on the category and purpose:

Contact Form Submissions: 2 years from date of submission
Analytics Data (GA4): 14 months
Marketing Cookies (Google Ads): Up to 540 days
Email Communications: Duration of customer relationship plus 1 year
Server Logs: 90 days
Cookie Consent Records: 3 years (for audit and compliance purposes)
Course Data and Learning Progress: Duration of course enrollment plus 1 year

14. Children's Privacy

This website is not directed at individuals under the age of 16. We do not knowingly collect personal data from minors. If we discover that data has been collected from a person under 16 without verifiable parental consent, we will delete it promptly. Parents or guardians who believe we have received data from a minor should contact us immediately at info@englishmaster.com

15. International Data Transfers

Personal data collected through this website may be transferred to and processed in countries outside the European Economic Area, including the United States, where Google LLC and Meta Platforms, Inc. are based. These transfers are conducted under Standard Contractual Clauses (SCCs) approved by the European Commission, which provide appropriate safeguards for personal data in accordance with GDPR Article 46. A copy of the applicable SCCs can be requested by contacting us directly at info@englishmaster.com

16. Your Rights Under GDPR (Articles 15-22)

If you are located in the European Economic Area or the United Kingdom, you have the following rights:

16.1 Right of Access (Article 15)

You may request a copy of all personal data we hold about you in a structured, commonly used format.

16.2 Right to Rectification (Article 16)

You may correct any inaccurate or incomplete personal data we hold about you.

16.3 Right to Erasure (Article 17)

You may request deletion of your personal data ("right to be forgotten") in certain circumstances where we no longer need it or if you withdraw consent.

16.4 Right to Restriction (Article 18)

You may request that we limit how we process your personal data in certain situations.

16.5 Right to Data Portability (Article 20)

You may receive your personal data in a structured, machine-readable format and transmit it to another controller.

16.6 Right to Object (Article 21)

You may object to processing of your personal data based on legitimate interest at any time.

16.7 Withdraw Consent (Article 7.3)

You may revoke your consent to processing at any time without penalty. Withdrawal does not affect processing that occurred while consent was valid.

16.8 Exercising Your Rights

To exercise any of these rights, email us at info@englishmaster.com with your request. We will respond within 30 calendar days. You also have the right to lodge a complaint with your local supervisory authority:

EU Users: https://edpb.europa.eu
UK Users: https://ico.org.uk

17. Security Measures

We implement comprehensive technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include SSL/TLS encryption for data in transit, secure password hashing, access controls, and regular security audits. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security of your data.

18. Third-Party Links

Our website may contain links to external websites, resources, and third-party services. EnglishMaster is not responsible for the privacy practices, content, or policies of these external websites. We encourage you to review the privacy policies of any third-party websites before providing your personal information.

19. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting a prominent notice on the homepage at least 14 days before the changes take effect. Your continued use of the website after such notice constitutes your acceptance of the updated policy.

20. Contact Information

If you have questions about this Privacy Policy, your data rights, or our privacy practices, please contact us:

EnglishMaster
45 Oxford Street
London, W1D 2EB
United Kingdom
Email: info@englishmaster.com
Phone: +44 20 7946 0958