1. Who we are

This Privacy Policy explains how Fluent-Online collects, uses, and protects personal data when you use our website and learning platform. Fluent-Online Ltd is incorporated in England and Wales with company number 17028237. For support and privacy contact, email support@fluent-online.com.

2. Data we collect

• Account data: name, email address, login identifiers, user role, account status, and parent/guardian details where relevant.
• Student and booking data: lesson schedules, attendance records, cancellations, progress cards, learning notes, language level, and optional support information.
• Payment data: transaction references, billing records, payment status, refund records, and payment provider references. Full card details are handled by payment providers.
• Technical data: IP address, browser and device data, security logs, classroom connection data, time zone, and platform activity.
• Lesson and safeguarding data: lesson recordings, chat messages, whiteboard content, attendance records, complaints, safeguarding reports, and quality review notes where applicable.
• Support data: messages, requests, evidence, screenshots, and information you submit via support channels.

3. Why we process data

• To create and manage user accounts.
• To schedule lessons, manage bookings, record attendance, and complete progress cards.
• To process payments, credits, refunds, and prevent fraud.
• To provide customer support and essential service communications.
• To monitor lessons for safeguarding, child protection, quality assurance, dispute resolution, training, legal compliance, and platform security.
• To meet legal, tax, accounting, safeguarding, and regulatory obligations.

4. Legal bases (UK GDPR / GDPR)

• Contract: processing necessary to provide requested services, bookings, lessons, credits, payments, and support.
• Legitimate interests: platform security, safeguarding, service improvement, quality assurance, dispute handling, and abuse prevention.
• Consent: cookies, analytics, or marketing where applicable.
• Legal obligation: accounting, tax, safeguarding, regulatory, and compliance requirements.
• Vital interests / public interest: where necessary to protect a child, vulnerable person, or other person from serious harm.

5. Sharing data

We may share limited data with trusted service providers such as payment processors, hosting providers, classroom technology providers, email delivery services, analytics providers, professional advisers, insurers, and support tools. We never sell personal data.

Where lawful and necessary, we may share relevant information with parents/guardians, regulators, law enforcement, courts, safeguarding authorities, payment providers, or other parties involved in a dispute or investigation.

6. Data retention

Data is retained only for as long as necessary to provide services, comply with legal obligations, support safeguarding, resolve disputes, prevent fraud, and maintain business records. Data is then deleted or anonymised where possible.

7. Your rights

• Access, correction, deletion, restriction, objection, and portability.
• The right to withdraw consent where processing is consent-based.
• The right to complain to a data protection authority where applicable.

8. Children’s privacy and parent requests

For child learner accounts, parents and guardians usually manage the account, bookings, and payments. However, where a child is old enough to exercise their own data protection rights under applicable law, we may need to involve the child, consider the child’s wishes, or ask for appropriate authority before responding to a parent or guardian request.

9. Contact

1. What cookies are

Cookies are small text files stored on your device that help websites function properly, remember preferences, and improve user experience.

2. Cookie categories

• Essential cookies: Required for login, security, session management, booking, payments, classroom access, and core platform functionality. These cannot be disabled.
• Analytics cookies: Help us understand how the platform is used so we can improve performance and usability. These are only set if you enable them.
• Marketing cookies: Used to measure advertising effectiveness and campaign performance. These are only set if you explicitly enable them.

3. Managing your preferences

4. Contact

1. Your GDPR rights

Under applicable data protection laws, including UK GDPR and GDPR where applicable, you may have the right to:

• Request access to the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request deletion of your data where legally permitted.
• Request restriction of certain processing activities.
• Request a copy of your data in a portable format.
• Object to processing based on legitimate interests.
• Withdraw consent where processing is based on consent.

2. How to submit a request

To exercise any of the rights above, contact us at: support@fluent-online.com

Please use the subject line “GDPR Request” and include:

• The email address associated with your account.
• The type of request, such as access, correction, deletion, restriction, objection, or export.
• Any relevant details that may help us locate your data, such as date ranges or booking references.

3. Identity verification

To protect your privacy and prevent unauthorised access, we may request reasonable proof of identity before processing your request. For child accounts, we may need to verify that the requester is the parent or legal guardian responsible for the account.

4. Child and young person requests

If a data rights request concerns a child or young person, we will consider the child’s age, understanding, best interests, local law, safeguarding needs, and who is authorised to act for the child. Where applicable, a child aged 13 or over may be able to make certain data protection requests themselves, or we may need to confirm that the child agrees to a parent or guardian making the request on their behalf.

5. Response timeframe

We will respond within the timeframe required by applicable law. Complex requests may take longer where the law allows, in which case we will keep you informed.

6. Legal limits and retained records

Some rights are not absolute. We may need to retain certain data for safeguarding, legal, tax, accounting, fraud prevention, dispute resolution, platform security, regulatory, or insurance reasons.

7. Contact

For data rights requests or privacy questions, contact: support@fluent-online.com

1. Student cancellation windows

Cancellation deadlines are calculated by reference to the scheduled lesson start time shown on the platform. It is your responsibility to check the lesson date, time, and time zone before booking or cancelling.

Late-cancellation and no-show charges reflect reserved teacher time, scheduling disruption, administrative work, loss of booking availability, and the fact that the lesson slot may not be capable of being reallocated at short notice.

2. Student lateness

If a student joins late, the lesson may still end at the scheduled end time. The teacher is not required to extend the lesson because of student lateness.

If the student joins so late that the lesson cannot reasonably be delivered, the lesson may be treated as completed and no credit may be returned.

3. Teacher cancellation, teacher no-show or company fault

If a teacher cancels before the lesson starts, we may offer a replacement teacher, reschedule the lesson, or return the lesson credit.

If the teacher does not attend, or the lesson cannot be provided due to Fluent-Online fault, you will receive either 100% credit returned or a rebooked lesson plus 25% credit towards a future lesson.

We will decide the appropriate remedy based on the circumstances, teacher availability, student preference, package type, technical records, and whether the lesson can reasonably be rebooked.

4. Refunds and credits

Where credit is returned, it will normally be returned to your Fluent-Online account rather than paid as cash. Where a cash refund is required by law or approved by us, it will normally be made to the original payment method where possible.

Purchased, returned, promotional, referral, bonus, goodwill, or account credits must be used within 3 months of purchase or issue unless a different expiry period is clearly shown at the time of purchase or issue, or unless applicable law requires otherwise.

Expired credits cannot be used, transferred, exchanged for cash, or refunded unless required by law.

Processing times may vary depending on the payment provider, bank, card issuer, or wallet provider.

Promotional credits, bonus credits, referral credits, discount tokens, and goodwill credits may be non-refundable unless required by law.

5. Subscriptions and auto-renewals

If we offer subscription or auto-renewing plans, the price, renewal period, included credits, cancellation method, and renewal terms will be shown before purchase.

You can cancel future renewals through your account settings or by contacting support. Cancelling future renewals does not automatically refund lessons or credits already used, expired, or allocated before cancellation unless required by law.

6. Payment disputes

If you believe a charge has been made in error, please contact support first so we can review and resolve the issue promptly.

Filing chargebacks without contacting support may result in temporary account restrictions while the dispute is reviewed.

7. Exceptional circumstances

If you believe exceptional circumstances affected your ability to attend or cancel a lesson, you may contact support. We may, at our discretion, offer a credit, partial credit, rebooking, or goodwill solution, but we are not required to do so unless required by law.

8. Statutory rights

Nothing in this policy affects your statutory consumer rights, including any rights you may have where services are not provided with reasonable care and skill.

1. Who this policy applies to

This Safeguarding Policy applies to all lessons involving child learners on Fluent-Online, and to all teachers, students, parents, guardians, and users interacting with child accounts.

2. Expected conduct

• Child-appropriate behaviour: language, topics, and teaching materials must always be age-appropriate.
• Professional boundaries: teachers, students, parents, and guardians must keep communication and behaviour professional at all times.
• Zero tolerance: harassment, grooming behaviour, sexual content, threats, hate speech, discrimination, intimidation, or abuse is not permitted.
• No personal contact requests: requesting or sharing private contact details outside the platform is not permitted.
• No off-platform meetings: teachers, students, parents, and guardians must not arrange in-person meetings through the Fluent-Online relationship.

3. Parent / guardian role

• Child accounts must be created and managed by a parent or legal guardian.
• Parents and guardians are encouraged to supervise lessons where appropriate for the child’s age and needs.
• Parents and guardians are responsible for ensuring the child joins lessons in a safe and appropriate environment.
• Parents and guardians should report concerns promptly and should not encourage private contact between children and teachers.

4. Monitoring and recording

Lessons, classroom activity, chat messages, whiteboard content, attendance data, technical logs, and platform activity may be monitored, joined, recorded, reviewed, transcribed, retained, and used by Fluent-Online for safeguarding, child protection, quality assurance, dispute resolution, training, fraud prevention, legal compliance, and platform-security purposes.

Monitoring or recording may be random, targeted, automated, manual, live, or retrospective.

Students, parents, and guardians must not record, screenshot, publish, stream, distribute, or share lessons, teachers, students, classroom content, or platform content without our prior written consent.

5. Reporting safeguarding concerns

If you have any safeguarding concern, contact support immediately at support@fluent-online.com.

Please include, if available: the child’s account email, teacher name, lesson date/time, and a clear description of what happened.

6. How we respond

We may take immediate action to protect learners, including:

• Pausing or restricting accounts pending review
• Investigating lesson records, booking history, recordings, attendance logs, and relevant communications
• Removing a teacher from the platform where appropriate
• Preserving evidence where necessary
• Cooperating with relevant authorities where required or necessary

7. Emergency situations

If a child is in immediate danger, contact your local emergency services first. You should also notify us as soon as possible so we can support the investigation and secure the platform.