Privacy Policy
Effective date: April 18, 2025
1. Who We Are
Sulitko ("we", "our", "us") operates the online language learning platform available at sulitko.com. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our Platform.
2. Information We Collect
We collect the following categories of information:
- Account information: Name, email address, profile photo, and password (stored as a secure hash).
- Profile information: Languages spoken, biography, teaching experience, and country (for Teachers).
- Payment information: Billing details processed by Stripe. We do not store full card numbers on our servers.
- Usage data: Pages visited, lesson activity, messages exchanged on the Platform, and booking history.
- Technical data: IP address, browser type, device identifiers, and cookies.
- Communications: Messages you send through our in-platform messaging or to our support team.
3. How We Use Your Information
- To create and manage your account.
- To match Students with Teachers and facilitate bookings.
- To process payments and payouts.
- To send transactional emails (booking confirmations, reminders, receipts).
- To improve and personalise the Platform experience.
- To detect and prevent fraud or abuse.
- To comply with legal obligations.
4. Legal Bases for Processing (GDPR)
If you are in the European Economic Area, we process your data under the following legal bases:
- Contract performance — to provide the services you signed up for.
- Legitimate interests — to improve the Platform, ensure security, and prevent fraud.
- Legal obligation — to comply with applicable laws.
- Consent — where you have provided explicit consent (e.g., marketing emails).
5. Sharing Your Information
We do not sell your personal data. We may share it with:
- Stripe — payment processing.
- Jitsi Meet — video lesson infrastructure.
- Nodemailer / email providers — transactional email delivery.
- Analytics tools — to understand usage patterns (data is anonymised where possible).
- Law enforcement — when required by law or to protect the rights and safety of users.
All third-party providers are contractually required to handle your data securely and only for specified purposes.
6. Cookies
We use essential cookies to operate the Platform (e.g., session management and authentication). We may also use analytics cookies to understand how the Platform is used. You can control cookie preferences through your browser settings. Disabling essential cookies may affect Platform functionality.
7. Data Retention
We retain your account data for as long as your account is active, plus a reasonable period thereafter to comply with legal obligations (typically up to 7 years for financial records). You may request deletion of your account at any time by contacting support.
8. Your Rights
Depending on your location, you may have the right to:
- Access the personal data we hold about you.
- Correct inaccurate data.
- Request deletion of your data ("right to be forgotten").
- Object to or restrict certain processing.
- Data portability — receive your data in a structured format.
- Withdraw consent at any time (where processing is based on consent).
To exercise any of these rights, email [email protected].
9. Security
We implement industry-standard security measures including HTTPS encryption, hashed password storage, and access controls. However, no system is completely secure. Please use a strong, unique password and notify us immediately if you suspect unauthorised access to your account.
10. Children's Privacy
The Platform is not intended for children under 13. We do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal information, please contact us immediately so we can delete it.
11. International Transfers
Your data may be stored and processed in countries outside your own. We ensure appropriate safeguards are in place (such as Standard Contractual Clauses for EU data transfers) wherever such transfers occur.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes by email or via the Platform. Your continued use of the Platform constitutes acceptance of the updated policy.
13. Contact Us
For privacy-related enquiries or to exercise your rights, contact us at: [email protected].