Privacy Policy

PRIVACY POLICY & CHILD SAFEGUARDING STATEMENT

Last Updated: October 2026

This Privacy Policy describes how LearnFrenchWithJen/learnfrenchwithjen.com("we", "us", or "our") collects, uses, processes, and protects your personal data when you purchase a membership or access our Leaving Certificate French Oral preparation platform.

We operate as a sole trader in Ireland. The Data Controller responsible for your personal data is Jennifer Asada, with a trading address at Moycullen, Co.Galway, H91R5PW, Ireland.and contact email learnfrenchwithjen@gmail.com.

Because our services are designed for secondary school students preparing for the state examinations, we implement heightened security and privacy workflows to protect children and minors under the age of 18.

1. The Digital Age of Consent & Parental Control

• Irish Legal Framework: In accordance with Section 31 of the Irish Data Protection Act 2018, the Digital Age of Consent in Ireland is 16.

• Students Aged 16 or 17: Students who are 16 or 17 years old may legally register an account, input their own email addresses, and consent to data processing for educational purposes.

• Students Under 16: If a student is under 16 years of age, we do not knowingly process their personal data without prior parental authorization. A parent or legal guardian must complete the registration and payment process, explicitly consenting to the data collection on behalf of the minor student.

2. Personal Data We Collect

We collect only the minimum amount of data required to deliver our educational platform securely:

• Account Credentials: Username, password, first name, and last name.

• Contact Information: Email address (used for platform communication, notifications, and updates).

• Billing and Transaction Data: Stripe or PayPal handles all financial transactions. We do not store full credit card numbers or financial credentials on our servers; we only receive transaction statuses and billing addresses.

• Social Network Data: If you opt to build a profile, we process your chosen display name, your profile photograph, peer-to-peer messages, text inputs on the community feed, and images/videos uploaded to your user stories.

• Live Interactive Data (Optional): If a student chooses to participate actively in our live portal calls, we may capture their display name, typed text chat inputs, or temporary audio/video feeds if they choose to unmute or enable their webcam.

3. Child Safeguarding & Privacy by Design in Live Calls

We take child safety and privacy seriously during live interactive calls hosted inside the membership area. We apply the following "Privacy by Design" measures:

• Default Privacy Settings: All live sessions are configured so that student webcams and microphones are strictly disabled and muted by default upon entering the room.

• Anonymity Options: Students are explicitly permitted to use a first-name-only display alias and are encouraged to interact via text chat to ask oral exam questions if they wish to avoid their voice or identity being recorded.

• Recording Guardrails: Live calls are recorded by the instructor to serve as permanent revision resources for members. The software is configured to record the "Host/Speaker View Only" to ensure student faces or gallery grids are not permanently stamped onto the video resources.

• Strict Anti-Sharing Rules: Our terms strictly prohibit members from screen-recording or distributing footage capturing other minor students. Any violation is met with an immediate account ban.

• Peer-to-Peer Privacy Safeguards: Because this platform functions as a closed social network for teenagers, private messages and user feeds are hosted securely and are strictly inaccessible to the public internet or search engines. We explicitly advise students never to share sensitive personal information (such as their home address, personal phone number, Snapchat handles, or school location) publicly on the community feed or stories.

4. How We Use Your Personal Data

We process personal data based on the following legal grounds under the GDPR:

• Performance of a Contract: To create your student account, track your course progress, grant access to our digital French resources, and facilitate live classes.

• Legal Obligation: To comply with Irish accounting, taxation, and corporate disclosure regulations as a sole trader.

• Consent: When a student or parent voluntarily opts into receiving study tip newsletters or explicitly turns on their microphone during an oral exam practice session.

5. Data Retention & The End-Of-Year Purge

We do not hold student personal data longer than necessary. Because our service operates on a fixed-term contract for the school year, we enforce a strict data retention timeline:

• Fixed Expiry: All student platform access expires on June 30th following the state examinations.

• Data Destruction: On or shortly after June 30th, all student personal profiles, account metrics, login logs, text chat logs, and live workshop video assets containing student vocal tracks from that academic year are permanently and securely deleted from our live servers and databases.

6. Data Sharing & Third-Party Processors

We do not sell, rent, or lease student information to third parties. Data is only shared with trusted software applications necessary to run the website infrastructure:

• Estage Genesis / Membership Software: To securely host your user account dashboard.

• Stripe / PayPal: To securely process payment transactions.

• Estage Video: To deliver secure, encrypted, non-downloadable streaming oral audio and video resources.

7. Your GDPR Privacy Rights

Under EU and Irish data protection laws, you (and your parents/guardians, where applicable) have robust rights regarding your information:

• The Right to Access: You can request a digital copy of all personal data we hold about you.

• The Right to Rectification: You can request that inaccurate personal details be corrected.

• The Right to Erasure ("Right to be Forgotten"): You can request that we delete your data. For example, if a student leaves a voice comment during a live call replay and later wishes it removed, we will edit or delete that segment within 30 days of a formal request.

• The Right to Complain: If you believe we are mishandling your data, you have the right to lodge a complaint with the Irish Data Protection Commission (DPC) at info@dataprotection.ie.

8. Contacting Us

To exercise any of your privacy rights or to ask a safeguarding question, please contact the site operator directly at: learnfrenchwithjen@gmail.com