Privacy notice
This notice explains how SmartLingo Ltd handles personal data through the SmartLingo website, business enquiries and SmartLingo learning programmes. Client-specific programme processing may also be governed by a separate contract and data-processing agreement.
1. Who we are
SmartLingo Ltd, company number SC828487, registered office at 5 Gladstone's Gait, Bonnyrigg, Scotland, EH19 3GA. Contact: Peter Horvath, Program Director, peter.horvath@smartlingo.eu.
2. Our role
For website enquiries, supplier administration and SmartLingo’s own business records, SmartLingo normally acts as a data controller. For some corporate learning programmes, the client organisation may be the controller and SmartLingo may process learner data on the client’s instructions. The relevant contract or data-processing agreement should define those roles for each programme.
3. Personal data we may process
- Business contact details such as name, employer, role and email address.
- Website quiz selections, results and assessment requests where you choose to submit them.
- Programme information such as learner name, work email, group, tutor, schedule, attendance, language level, learning goals, assessments and approved feedback.
- Where enabled for a programme, lesson audio, speech-to-text transcript segments and AI-assisted learning analysis.
- Technical information needed for account access, security, service operation and troubleshooting.
- Correspondence, programme enquiries and commercial records.
4. Why we use the data
| Purpose | Typical basis |
|---|---|
| Responding to enquiries and preparing proposals | Legitimate interests and steps requested before entering a contract. |
| Delivering and administering contracted training | Performance of a contract, legitimate interests, or processing on a client controller’s documented instructions. |
| Assessment, feedback and programme reporting | Delivery of the learning service and the agreed programme purpose. |
| Account security and service operation | Legitimate interests in providing a secure, reliable service. |
| Legal, tax and accounting records | Compliance with legal obligations. |
The exact lawful basis may depend on the relationship and the client’s role as controller. We do not rely on one blanket basis for every type of programme data.
5. Lesson audio, transcripts and AI-supported features
Recording is not required by default. Where transcription or AI-supported feedback is enabled, the programme arrangement should explain what is processed, who can access it, how long it is retained and which service providers are involved. AI output is used as support for learning workflows, not as an automated employment decision. Tutors remain responsible for learning feedback that is shared with learners.
6. Service providers
Depending on the feature used, SmartLingo may use technology providers for hosting, database/authentication, video communication, transcription and AI processing. Current platform architecture may include Netlify, Supabase, Metered, AssemblyAI and OpenAI. Before live client rollout, relevant processing should be documented in the client data-processing arrangements. Providers may use infrastructure in different countries, so international transfer safeguards may be relevant.
7. Who sees what
Access is designed around roles. Learners and tutors may need lesson-level learning detail. Programme owners may need attendance, assessment and programme-level progress. Raw transcript content and private tutor notes are not intended as general management reporting. SmartLingo administrators may access data where necessary for delivery, support, security and maintenance.
8. Retention
We aim to keep personal data only for as long as it is needed for the agreed purpose, legal obligations, programme continuity or legitimate business records. Platform retention can vary by data type. Client-specific retention and deletion rules should be agreed before live rollout, particularly for transcript or audio data.
9. Your rights
Depending on the circumstances, you may have rights to access, correct or delete personal data, restrict or object to processing, and obtain data in a portable form. Where SmartLingo is acting only as a processor for a corporate client, we may need to coordinate your request with that client.
10. Complaints
You can contact us first at peter.horvath@smartlingo.eu. You also have the right to complain to the UK Information Commissioner's Office if you believe your data-protection rights have been infringed.
11. Changes
We may update this notice as the SmartLingo platform and legal requirements develop. The date at the top shows the latest version.