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Privacy Policy


Policy on personal data processing based on REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (GDPR)

Introduction

This Privacy Policy explains how Theia Moira Ltd processes personal data when you use LearnItalianOra, create or use a student account, submit a lesson intake form, book lessons, purchase a lesson package, contact us, or otherwise use services available through learnitalianora.com. Theia Moira Ltd is the data controller for the processing described in this policy, except where an identified third-party service acts as an independent controller for its own processing.

Theia Moira Ltd
Sliema, Malta
VAT MT 2168-2832
Email: info@theiamoira.com

Registration and Student Area

The Company processes the personal data needed to create and administer student accounts, provide secure login, email verification, password setting and password reset, and make restricted student services available. When you register for a student account, you are required to complete a learning-needs questionnaire with your current Italian level, learning goals, preferred lesson frequency and availability. You may also provide optional learning preferences or particular needs. These responses are associated with your account so that LearnItalianOra can assess your learning needs, select a suitable teacher and administer any free trial or purchased lessons you choose.

When you request, book or receive a lesson, or purchase a lesson package, the Company may also process booking details, package type, package start and expiry dates, lesson balance, scheduled and completed lessons, cancellations, rescheduling, no-shows and relevant administrative history.

Marketing

If you provide your explicit consent, the Company shall process your data to send you promotional communications and/or newsletters regarding products offered for sale by the Company or by third parties.

Direct marketing to existing customers

Where permitted by applicable law, the Company may use an email address obtained in connection with the sale of its own products or services to send information about similar products or services. You may object to this use at any time, free of charge, including through any unsubscribe or opt-out mechanism provided in the communication.

Article 1. Purpose of the processing. Legal basis. Mandatory or optional nature of data provision and consequences of any refusal.

The Company shall process the personal data provided by you for the following purposes:

  1. to create and administer a student account, provide secure login, email verification, password-setting and password-reset functions, and provide services restricted to registered users. The legal basis is the performance of a contract or steps taken at your request before entering into a contract, together with the Company’s legitimate interest in protecting the security and integrity of the service;
  2. to administer lesson-intake information, organise trial or paid lessons, manage bookings, packages, lesson balances and lesson history, process online purchases, confirm payment status, activate purchased packages and comply with tax, accounting and other legal obligations. The legal basis is the performance of a contract, steps taken at your request before entering into a contract, and compliance with legal obligations;
  3. where permitted by applicable law, to use an email address obtained in connection with the sale of the Company’s own products or services to communicate about similar products or services, subject to your right to object at any time. The legal basis is the Company’s legitimate interest within the limits permitted by applicable law;
  4. if you provide your explicit consent, for the Company to send you a newsletter for market research purposes also aimed at evaluating the level of customer satisfaction and to send you promotional communications about the products of the Company and/or third parties, by email (marketing purposes); The legal basis for the processing is your consent;
  5. to administer external booking and scheduling services used to select dates and times and confirm lessons. The legal basis is the performance of a contract or steps taken at your request before entering into a contract;
  6. to provide customer support and respond to requests sent by email or through forms available on the Website. The legal basis is the Company’s legitimate interest in responding to users and administering its services, or the performance of a contract where the request relates to an existing service;
  7. to prevent misuse, protect accounts and systems, maintain service security, establish or defend legal claims and comply with applicable legal or regulatory obligations. The legal basis is the Company’s legitimate interests and, where applicable, compliance with legal obligations.

Where information is necessary to create an account, complete a purchase, administer a booking or provide a requested lesson service, failure to provide the relevant information may prevent LearnItalianOra from providing that service.

Consent for marketing purposes is optional. If you do not consent, you will not receive consent-based promotional communications or newsletters. You may withdraw consent at any time using the relevant unsubscribe mechanism or by contacting the Company.

The Company may also process personal data where necessary to comply with legal obligations, protect the security of the service, or establish, exercise or defend legal claims.

Payments and external payment providers

Payments for paid lesson services and lesson packages are handled through external hosted payment services. LearnItalianOra does not store full payment-card or payment-account credentials on systems under its control. When you follow a payment link, the selected payment provider processes the information required to complete and authenticate the transaction under its own privacy and security terms.

LearnItalianOra receives and retains only the information reasonably necessary to identify the transaction, confirm payment, administer the purchased service or package, keep required accounting records and deal with payment-related support or disputes.

Where Stripe is used, payment information is processed through Stripe’s hosted services under Stripe’s own privacy and security terms.

Booking provider

LearnItalianOra may use an external scheduling provider, including TidyCal, to allow students to select dates and times and confirm bookings. When you follow an external booking link, the provider processes the information required to provide its service under its own privacy terms. LearnItalianOra receives the booking information reasonably necessary to administer your lessons.

Special categories of personal data

LearnItalianOra does not request special categories of personal data or judicial data as part of the ordinary registration, booking or lesson-purchase process. Please do not include sensitive information in free-text fields unless it is genuinely necessary for your request. If information of this kind is voluntarily provided and is necessary to deal with the request, it will be handled in accordance with applicable data-protection law.

Geolocation and timezone information

LearnItalianOra does not request access to the precise geolocation of your device as part of the ordinary Website service. An external scheduling or payment provider may process timezone, device, network or location-related information where necessary to provide its own service, in accordance with that provider’s privacy terms.

Article 2. Methods of Processing Personal Data

The processing of your data will be carried out by electronic or automated means, in the manner and with the appropriate tools to ensure security and confidentiality by the GDPR.

The information and methods of processing will be relevant and not excessive in relation to the type of services provided. Data will be managed and protected in environments where access is under constant control.

Article 3. Data Disclosure and service providers

For the purposes described in this Privacy Policy, personal data may be disclosed or made available, where necessary, to:

  1. public authorities or other parties where access or disclosure is required by law, regulation, court order or a competent authority;
  2. hosting, website, email, security, maintenance and technical service providers used to operate LearnItalianOra;
  3. payment providers, including Stripe where used, for payment processing, transaction confirmation, fraud prevention and related support;
  4. booking and scheduling providers, including TidyCal where used, for appointment selection, booking confirmation and related scheduling functions;
  5. professional advisers, including legal, accounting, tax and administrative advisers, where reasonably necessary;
  6. employees, authorised collaborators or service providers who need access to the relevant information in order to provide or administer the requested service;
  7. providers used to send newsletters or service communications, where such services are activated and the relevant legal requirements are met.

Personal data is shared only to the extent reasonably necessary for the relevant purpose. Anonymous or aggregated information may be used for statistical, administrative or research purposes where individuals are not identifiable.

International transfers

Some external service providers may process personal data outside Malta or outside the European Economic Area. Where the GDPR requires safeguards for an international transfer, the Company will rely on an appropriate transfer mechanism and the safeguards required by applicable data-protection law.

Article 4. Data Controller

The Data Controller is:

Theia Moira Ltd
Sliema, Malta
VAT MT 2168-2832
Email: info@theiamoira.com

Requests concerning personal-data processing or the exercise of data-protection rights may be sent to the email address above or through the Contact page of the Website.

Article 5. Data Storage

Personal data is retained only for as long as reasonably necessary for the purpose for which it was collected, subject to any longer period required by applicable law or needed to establish, exercise or defend legal claims.

  • Student account data: retained while the account and related services remain active and thereafter only for the period reasonably necessary to administer closure, resolve disputes or comply with legal obligations.
  • Intake, package and lesson records: retained for the duration of the relevant teaching relationship and thereafter as reasonably necessary to administer completed services, respond to queries, establish or defend legal claims and comply with applicable obligations.
  • Payment, invoicing and accounting records: retained for the period required by applicable Maltese tax, VAT and accounting rules. Certain records may therefore need to be retained for six years or for any longer period required by another applicable legal obligation.
  • Customer-support communications: retained for as long as necessary to resolve the request and for a reasonable follow-up period where needed.
  • Marketing data: retained until consent is withdrawn, an objection is made, the address is suppressed from future marketing, or the information is otherwise no longer required.
  • Legal or security records: retained for as long as reasonably necessary for security, fraud prevention, compliance or legal claims.

Where deletion is requested, information will be erased or anonymised where applicable, except to the extent that retention remains necessary or lawful for one of the purposes above.

Article 6. Rights of the Data Subject

Subject to the conditions and limitations provided by the GDPR and applicable law, you may have the right to:

  1. request access to your personal data;
  2. request rectification of inaccurate or incomplete personal data;
  3. request erasure of personal data;
  4. request restriction of processing;
  5. object to processing based on legitimate interests and object at any time to direct marketing;
  6. receive personal data in a portable format where the right to data portability applies;
  7. withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal;
  8. lodge a complaint with a competent supervisory authority, including the Office of the Information and Data Protection Commissioner in Malta.

These rights may be exercised by contacting info@theiamoira.com.

Cookies and similar technologies

LearnItalianOra uses cookies or similar technologies that are necessary or functional for the operation, security and authenticated areas of the Website. Where optional technologies requiring consent are introduced, they will be handled through the Website’s consent-management mechanism before they are activated. Further information is provided in the Cookie Policy available on this Website.

Article 7. Amendments

The Company reserves the right to change this Privacy Policy when necessary to reflect changes in the Website, services, providers or applicable law. Where appropriate, users will be informed of material changes. The current version will remain available on the Website.

Definitions and legal references

This Application

The property that enables the provision of the Service.

Agreement

Any legally binding or contractual relationship between the Owner and the User, governed by these Terms.

Business User

Any User that does not qualify as a Consumer.

European (or Europe)

Applies where a User is physically present or has their registered offices within the EU, regardless of nationality.

Owner (or We)

Indicates the natural person(s) or legal entity that provides this Application and/or the Service to Users.

Service

The service provided by this Application is described in these Terms and on this Application.

Terms

All provisions applicable to the use of this Application and/or the Service as described in this document, including any other related documents or agreements, and as updated from time to time.

User (or You)

Indicates any natural person or legal entity using this Application.

Consumer

Any User qualifying as a natural person who accesses goods or services for personal use, or more generally, acts for purposes outside their trade, business, craft or profession.