Privacy Policy

Updated: August 20, 2023

Sayra is committed to protecting your personal data. We tried to write down this Privacy Policy in the clearest and plain language possible. Likewise, we tried to provide you with our privacy commitments in a transparent and easily accessible way. That said, we hope you will get all the needed details to be assured your personal data is safe with us.

Before you give us your consent on the processing of your personal data or provide us with your personal data within any form on our mobile apps, we kindly ask you to read carefully this Privacy Policy, so we can be sure that you completely understand the conditions under which we would cooperate.

This Privacy Policy applies to your use of the Services of Sayra, as defined in our Terms of Service. Sayra offers you options concerning the data we process, use, and share as described in this Privacy Policy.

This Privacy Policy explains when, where, and why we process personal data about people who use Sayra, how we use it, the conditions under which we may disclose it to others, your rights in respect of your personal data, as well as how we keep it secure.

GENERAL

Whenever you access the Sayra (Student or Tutor app), we collect log information and save it in the local cache on your device, by which we track your activity on the Sayra.

When you are a registered User Sayra may collect from the data that you specifically provide us with upon registration, including first name, last name, email, year of birth, gender, city of residence, country of origin, or social network ID (if assigned through Google or if accessing Google Calendar), time zone, interface language, IP address, and device type.

Specifically, if you are a tutor, we may also collect and process, besides the aforementioned information, the other data provided by you, including personal information, a video introduction, education experience, and bank account information for payouts.

Registered Users may additionally provide us with added profile pictures as well as chosen currency to perform actions pursuant to our Refund and Payment Policy.

You can find out more about the specific cases of data collection and the purposes of the processing of such data in a separate section of this Privacy Policy.

We may change this Privacy Policy from time to time, so please check this page to ensure that you’re happy with any changes. We will post those changes on this page and update the Privacy Policy modification date at the top of this page. Additional notifications on any amendments will be sent to your email.

We may also occasionally experiment with different features of the Sayra Platform which can affect the scope, purposes, or other details of the processing of personal data. In such cases we will provide prior notification and, if necessary, obtain your consent.

Any questions regarding this Policy and our services should be sent to [email protected].

1. What Is Personal Data and the Processing of Personal Data? Main Definitions

Personal data is any information relating to you that alone or in combination with other pieces of information allows a person that collects and processes such information to identify you as an individual.

Processing of the personal data means any operation with your personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; which means you as a user of Sayra.

Consent of the data subject/user is any freely given, specific, informed, and unambiguous indication of the data subject/user's wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; which means you as a user of Sayra.

2. Sayra’s Lawful Bases for Processing

Sayra processes your personal data only when we have lawful bases. Specifically, Sayra processes your personal data if:

processing is based on the consent you have given. As such our newsletters, collection, analysis, and publication of user feedback and reviews, analysis of video Interviews and Speaking sessions, your participation in our events and webinars;
processing is necessary to provide our services to you according to our Terms of Service which constitute a contract between you and us as regards to information services of Sayra;
processing is necessary for the purposes of our legitimate interests. Those legitimate interests are:compliance with the U.S. financial and accounting legislation;the assessment of Sayra’s business efficiency by analyzing app traffic and financial performance indicators;promotion of Sayra through social media networks, media outlets, referees, and affiliates, such as bloggers or influencers; this in particular concerns the right of Sayra to use the tutor´s name, profile picture, and other details for marketing, advertising, or promotional purposes pursuant to the Terms of Service;performance of the contracts with enterprise clients and provision of reports on their Employees’ performance;user session control and fraud prevention, ensuring the appropriate protection of personal data;tutor verification and development of high-quality learning programs with tutors.
where necessary, compliance with applicable legislation (e.g., data subject request processing);
in exceptional cases, to protect your vital interests or the vital interests of another natural person, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

In all cases, we will notify you about the applied legal basis for processing and other relevant details, before we start the processing of your personal data on a specific legal basis unless we are not able to do so in accordance with our obligations under any applicable legislation.

3. Data We Collect: Scope

Sayra collects from you only the following information and only for the stated purposes:

(1) Account for Students

Sayra collects and processes personal data submitted by you upon registration and further editing of settings in your Account. For registration purposes, you should register through Google sign-in where you automatically provide your first name, last name, and email. You may also edit your Account anytime with additional information as well as sync your Google and Sayra Calendars. Such additional information may help you to find a suitable time slot with a tutor or to have more visibility of your schedule. At the same time, you are not required to provide additional information, not specifically necessary for the registration, it is your choice.

(2) Account for Tutors

Sayra collects and processes personal data submitted by you upon registration and further editing of your profile. For registration purposes, you should register through Google sign-in where you automatically provide your first name, last name, and email. You may also edit your Account anytime with additional information as well as sync your Google and Sayra Calendars. Such additional information may help you to find a suitable time slot with a student or to have more visibility of your schedule. At the same time, you are not strictly required to provide additional information, not specifically necessary for the registration. Therefore, it is your choice whether to include additional data in your profile, or not, language skills, education, and work experience.

Some personal data, such as users’ names, and location that is listed in your user profiles or derived from IP Addresses may be publicly visible to other users on the Services or to the app.

(3) Posting of Information

We process personal data freely submitted to you on Sayra. This may be a survey and online form you fill in on Sayra or feedback you provide us with.

Sayra may also process information provided by you (including content and messages) that you post on/through our Sayra apps, including personally identifiable information. By doing so, you acknowledge that any information you share through the Services will be available to Sayra and to other users of the Services (students/tutors). You also acknowledge that parts of your content cannot be deleted from the Service as it may be connected to the Interview and Speaking sessions created by you and used by other users (students/tutors).

We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with the Terms of Service.

(4) Billing Information

We process the details of transactions you carry out through our Sayra apps (as ID, date, and time of transaction).

(5) Business

We may collect your name, email, company name, and phone number to give you more information regarding Sayra Business Services.

(6) Sensitive Data

Unless you expressly agree, Sayra does not process your sensitive data.

(7) Pages on Social Networks and Sayra Tutors Community on Telegram (for Tutors Only)

We maintain Sayra’s official pages on social networks, such as Instagram or LinkedIn. When you make interactions with our social network pages, such as subscribing to the pages or leaving comments or preferences (e.g., ‘like’ our posts), we can analyze this data to measure our efficiency and conduct an analysis of our social media marketing in our legitimate interests.

We maintain a “Sayra Tutors Community” group on Telegram. To join the group, you shall provide the mobile phone number that you registered with on Telegram, and answer the questions about the Tutors Community rules.

(8) Information Required for Submitting Tax Documentation

To comply with the applicable tax and accounting legislation, we may be required to submit various tax documentation containing your personal data. For example, a federal tax form 1099 or other required tax form(s) necessary to withhold taxes. For submitting tax documentation, we may process your personal data including but not limited to your full name, country of citizenship, permanent residence address, mailing address, date of birth, U.S. taxpayer identification number, or foreign tax identifying number.

(9) Information Required for Marketing and Promotion

We may collect the tutor's postal address to promote the Tutoring Services that you provide via the Sayra Platform and help you reach more prospective students looking for Tutoring Services within a certain geographical area.

4. Data We Collect: Purposes

We may process the personal data you provided us voluntarily for the purposes defined below. From our perspective, we process your personal data to personalize the use of Sayra to the fullest extent possible and to provide you with high-quality Services under the Terms of Service.

(1) Provision of Services

Primarily, we process your personal data to authorize access to our Services and to fulfill our obligations under the Terms of Service for Services provision. Specifically, we use your personal data upon registration to help others (be it a tutor or a student) to find your account or profile, schedule, give and/or take Interview and Speaking sessions.

In order for you to use the Services, you will need to provide payment (e.g. credit card details) and billing information through our partners – third-party payment providers, which process your personal data encrypted and securely. Please see our Refund and Payment Policy for more information.

(2) Payment Services

We use third-party payment providers to bill you through an online account payment in lieu of directly processing your credit/debit card information. We use an integrated iframe for checkout from our partner-payment provider Stripe. Correspondingly all transactions are secured as our partner-payment provider uses SSL encryption protection. All payment information is stored encrypted and securely by Stripe. We do not store your payment information on our servers.

We may also use your payment card transaction data as shared by third-party service providers to confirm a specific transaction occurred and that you qualify for a promotional offer; for example, the date and amount of your purchase and the last 4 digits of your card number so that we can verify your purchase with our records.

(3) Communications

We may contact you via email and other ways, including through publicly available notices, for Services-related purposes (welcome letter, security and legal notices, announcements, Sayra updates, reminders, suggestions, etc.). We may also use your data to enable you to communicate with other users through Sayra, including conducting video calls, and/or leaving feedback about other users.

Your contact data (including email, etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including:

Feature development and product updates;
Marketing activities, including publishing them on Sayra on other information resources;
Customer Support updates;
Other service updates for improving your experience.

Having received the communications from us, you are always able to opt-out of such communications in each message, excluding legal notices, or changes of user settings on Sayra.

(4) Marketing and Promotion of Sayra

We may process your first name, last name, and email on our mailing list or for the newsletter and send you messages with some commercial or promotional information about our Services. But don’t worry, we will request your consent first, and you may always opt-out of our marketing messages, using the mechanisms described under the respective link in each message, and through the user settings available on Sayra.

We may use the postal address collected from you upon your consent in connection with search engine marketing and optimization.

Also, please pay attention that we may use the information provided by you as feedback. The latter, under Section 12 of the Terms of Service, may be used by Sayra without any additional compensation to you.

(5) Analytics and Development

In order to establish new ways to improve the Sayra Platform, find the points of interest in our Services and for the purposes of analytics, we monitor and analyze the personal data you provide us with, including information you provide upon registration, the app traffic, Usage data, such as the parts of our Services you visit, the date and duration of your visit, your location, type of the device you used during your visit and other relevant data on the use of the Sayra Platform. For these purposes, we use Google Analytics for Firebase, the use of which ensures compliance with our privacy commitments.

For the purposes indicated above, we may also run occasional research activities, including personalized “A/B” tests. During the tests, we will display different content to the users based on various criteria, such as their country. The purpose of such tests is to understand user engagement and satisfaction with certain features in order to improve the user experience, develop new useful features, and streamline our Services.

We may also carry out polls and surveys through Sayra using external GDPR-compliant services.

(6) Tutor Verification and Program Preparation

To ensure a high quality of Speaking sessions given by tutors on Sayra, we collect and process tutor credentials to verify their eligibility to teach subjects claimed by them. Besides that, we cooperate with the tutors and use their information to help them develop learning programs.

For the purposes of analytics, we additionally process tutors’ registration data to automate and improve the tutor verification process.

(7) Sayra Tutors Community on Telegram

We process data of Sayra Tutors Community participants to manage our Telegram group and provide tutors with the ability to come together and share their best practices, get official up-to-date information, and interact with each other and with Sayra based on our legitimate interest in community building. We also use the collected information to supervise tutors’ participation and behavior within the group.

(8) Support and Platform Supervision

In case of any disputes on Sayra and other Services-connected issues, we may use data (including communications) to resolve such matters, supervise user behavior on the Sayra Platform, and respond to any complaints or requests.

(9) Events and Webinars Conducted by Sayra

We use the personal data we collect from you when you register and/or attend any of our events or webinars to provide you with access to such events or webinars, as well as to send you registration confirmation, reminders, associated useful materials or the information you have requested about our Services.

(10) Compliance with Legal Requirements

We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the Sayra Platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and/or establish our legal rights.

(11) Fraud Prevention

Certain information, such as your log information, payment information, and your behavior on the Sayra Platform are subject to our supervision to prevent fraudulent activities and assist you in managing your user sessions.

(12) Changes

We may change Sayra's Privacy Policy from time to time. Upon any changes to this Policy, your rights may not be reduced unless you provide explicit consent. The latest version is posted on this page. If we make substantial changes, we will notify you by sending an email.

5. How Is Personal Data Shared?

In order to provide high-quality services, Sayra hires people, enters into agreements with independent contractors as well as cooperates with other services providers, companies, and organizations strictly under data processing agreements (DPA) or Standard Contractual Clauses (SCCs). For those reasons, some of your personal data can be passed to the persons mentioned. Sayra uses only secure places of storage, such as those provided by AWS (Amazon, the USA) with servers located in, Germany, and the United States.

(1) Categories of Third Party Service Providers

Customer communication solutionsPersonal data shared with this category of third-party service providers may include the information described in subsection 4 of section 3 of this Privacy Policy.
Services to manage emails and send out push notificationsPersonal data shared with this category of third-party service providers may include your contact details and the personal identifiers you provide to us.
SMS providers for mobile marketing and notificationsPersonal data shared with this category of third-party service providers may include your contact details and the personal identifiers you provide to us.
Payment services providersPersonal data shared with this category of third-party service providers may include the information described in subsection 4 of section 3 of this Privacy Policy.
Influencer marketing solution providers to identify and engage influencersPersonal data shared with this category of third-party service providers may include your name and other identifiers described in subsections 1 and 2 of section 3 of this Privacy Policy.
Search engine optimization and marketing toolsPersonal data shared with this category of third-party service providers may include the information described in subsection 9 of section 3 of this Privacy Policy.

(2) Data transfer in case of a change of control or asset disposition

In the event of any merger, acquisition, sale, or change of control, we’ll continue to ensure the confidentiality of your personal data and give affected users notice before personal data is transferred or becomes subject to a different privacy policy.

6. How Long Will the Personal Data Be Processed and Stored by Sayra?

Your personal data will be stored by Sayra no longer than necessary for the purposes for which the personal data is processed.

Generally, Sayra retains your personal data as long as your account is active. If your last activity on Sayra was more than 2 years ago, your account will be considered expired. In this case or when you decide to delete your Sayra account, we undertake to remove your personal data from our active systems and servers within 30 days or earlier.

However, in case of conflict situations in progress, Sayra may retain your personal data for longer in order to be able to establish, exercise, or defend legal claims. Upon the settlement of the conflict situation, all personal data gets deleted if the standard retention period has expired.

We may also retain some of your personal data for longer if we need it to comply with the applicable legal, regulatory, tax, accounting, or other requirements.

Personal Data collected when you registered on our mailing list or for the newsletter will be stored as long as you are interested in receiving our emails. We consider that you’re interested in this until you unsubscribe from the mailing list or the newsletter by clicking the respective link contained in each of our emails.

If you have registered for any of our events or webinars using your account credentials, we will merge and store this information with your account data. If you have used other contact details, we will delete them within 30 days after conducting the event or webinar.

After the expiration of the retention period, Sayra shall terminate the processing of your personal data, unless otherwise set by the relevant legislation.

7. Your Rights as Data Subject Regarding Your Personal Data Sayra Processes

(1) Right of Confirmation

You can obtain confirmation from Sayra as to whether personal data concerning you is being processed.

(2) Right of Access

You can access your personal data processed by Sayra.

(3) Right to Rectification

You can ask Sayra to have incomplete personal data requiring corrections completed.

(4) Right to Erasure (Right to Be Forgotten)

You can request Sayra to erase personal data. In most cases, Sayra will erase it unless otherwise required by legislation.

To delete your personal data, you can:

Contact us by email at [email protected]. We will respond to your request to delete your information within 30 days and notify you of the outcome.
Delete specific items from your account (such as your payment method, etc.) by going to your account “Settings” page.
Delete your entire account by going to your account “Settings” page and following the instructions for deleting your account.

(5) Right of Restriction of Processing

You can contest the accuracy of your personal data or in case Sayra is not interested in processing your personal data any longer, but you want Sayra to do this for different reasons, for example, to bring a claim against somebody and, instead of the erasure of information, its processing will be restricted.

(6) Right to Data Portability

You can have your personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

(7) Right to Object to Processing of Your Personal Data by Sayra

You can object to our processing of your personal data when the processing is related to the performance of our task carried out in the public interest or the exercise of official authority vested in us. The other case is if we process your data for the purposes of the legitimate interests pursued by us or by a third party and you believe that such interests are overridden by your interests or fundamental rights and freedoms. If you make a request with an objection to processing, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing.

(8) Right to Withdraw Consent at any Time by Contacting Us

After we at Sayra receive a withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data unless otherwise set by law.

If one of the aforementioned reasons applies, please contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately. These requests are free of charge.

If you believe that our use of your data violates your rights, you can lodge a complaint with the competent data protection authority.

Please note that when the processing of your personal data is carried out for direct marketing purposes, you have the right to object at any time to such processing without providing any justification and we will no longer process your data for such direct marketing purposes.

8. Other Privacy Commitments

(1) Cross-border Transfers

We process your personal data both within the United States and outside the United States. Although countries, where we process data, may have different laws, we take measures to ensure high privacy compliance (namely, as provided in section 5 of this Privacy Policy).

(2) Time for Reply and Reaction

Sayra will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if Sayra is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. Sayra will inform you of any such extension within one month of receipt of the request, together with the reasons for such delay.

(3) Security

Sayra takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage.

(4) Accessing the Account to provide support

In exceptional circumstances, such as required customer support, our support specialists may need to access your account. When such an occasion occurs, they will be able to see the personal data submitted to your account, including your scheduled personal events, if your Google Calendar and Sayra Calendar are connected.

We undertake to always ask for your permission to access your account before we start troubleshooting. Prior to granting us your permission, you might also consider editing your Google Calendar privacy settings with Google Calendar Help Center to hide your personal events from us.

Please note that if you do not want to grant your permission to access your account, it may affect the time and quality of the provision of customer support.

(5) Children’s Privacy

The privacy of children is one of our concerns. Sayra Services are not intended for use by children under the age of 18 without the supervision of their parents or legal guardian. If you are under the age of 18 but not less than the age of 13, you will need to ask your parent/legal guardian to set up an account on the Sayra Platform that you may use under their supervision.

We do not knowingly collect information from children under the age of 13, and discourage the use of Sayra Services by children under this age. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide information on our Sayra app without their permission.

(6) Breach Notifications

If any personal data of yours would be under breach, we would inform you and the respective data protection agencies as to the accidents without undue delay, if there are high risks of violation of your rights as the data subject. We would also do our best to minimize any such risks.

(7) “DoNotTrack” Requests

Sayra does not share personal data with third parties for direct marketing purposes. Also, our Services do not support “Do Not Track” requests.

(8) California Privacy Rights

In case you are a resident of California, you are entitled to certain rights over your personal data under the California Consumer Privacy Act of 2018. Specifically, as a resident of California, you have the right to:

know about the categories and specific pieces of personal data that we have collected about you and access a copy of your personal data (“Right to Know”);
have inaccurate personal data about you corrected (“Right to Correction”);
request deletion of your personal data that we have collected (“Right to Deletion”);
opt out of the sale of your personal data (“Right to Opt-Out”).

Please note that we may ask you and/or your agent to provide certain information to verify your and/or your agent’s identity and authorization before fulfilling the request. The information we request will depend on your prior interactions with us.

For more information about the personal data we collect and how we collect it, please refer to sections 2 and 3 of this Privacy Policy. To learn about the purposes for which your personal data is collected and the categories of service providers who have access to your personal data, please refer to sections 4 and 5.

Sayra undertakes to treat you like everyone else and not discriminate against you if you choose to exercise your rights. To submit the request to exercise your rights, please send an email to [email protected].

(9) Automated decision-making and profiling

As a part of the Sayra Platform functionality, we process the personal data of our tutors and students in a way that might be considered profiling.

Specifically, we use machine-learning algorithms that analyze various metric-based data and determine the tutor´s ranking on the Sayra Platform and their visibility to students. This is done to increase the matching efficiency between students and tutors on the Sayra Platform and allow tutors to connect with the optimal number of students who best fit their way of working.

Please note that this type of processing is necessary to provide our Services. To know more about this process and the logic involved, please refer to Section 3.6 of our Terms of Service.

If you want to request human intervention, express your point of view, or contest the decisions made by the algorithms, please send us an email to [email protected].

(10) Sale of personal data

We do not sell your personal data and the personal data of any minors under 16 years of age.

9. Legal Matters

Sayra considers your use of its Service to be private. However, we may disclose your personal data stored in our databases, in order to:

(1) comply with the law or legal process served on us;

(2) enforce and investigate potential violations of this Privacy Policy; including the use of this Service to participate in, or facilitate activities that violate the law;

(3) investigate potential fraudulent activities; or

(4) protect the rights, property, or safety of Sayra, its employees, its customers, or the public.

10. Governing Law

This Privacy Policy is governed by and construed with the laws of the USA, and, when applicable, Regulation 2016/679 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”), effective as of 25 May 2018.