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Privacy Policy - nwmoon Education LLC

Last updated: November 07, 2025

1) Who we are (Controller)

nwmoon Education LLC ("nwmoon", "nwmoon", "we", "us") is the controller of your personal data.
Registered in: Armenia

Registered office: NO38, Building 7 Nikoghayos Tigranyan 1st DeadEnd Nikoghayos Tigranyan St., Komitas Ave. Yerevan, Armenia

Privacy contact: privacy@nwmoon.com

EU Representative (GDPR Art. 27):

Name: Soheil Lotfi Address: 21 Rue André Maginot, Paris, France Postal code: 91400 Orsay, Email: soheil@nwmoon.com

2) Scope

This Policy applies to personal data processed when you use our Services, including:
Websites, web and mobile apps, dashboards, placement tests

Live 1-to-1 or group classes

Lesson audio recordings and transcripts

Messaging, voice/video, whiteboards, community forums

Scheduling, billing, CRM, customer support

This Policy does not apply to third-party websites or services that link from ours.

3) Data we collect

We may collect:
Account & Identity: name, username, password, profile photo, age/date of birth, level, goals.

Parent/Guardian (for minors): name, contact details, consent records.

Contact: email, phone, address, preferences.

Learning & Content: assignments, placement results, messages/chats, uploads, notes.

Audio Recordings & Transcripts: audio of lessons is systematically recorded for quality assurance, compliance monitoring, dispute resolution, and safety. Transcripts may be generated for feedback or review.

Payment & Billing: payment details (via provider), invoices.

Device & Usage: IP, device ID, browser, OS, session logs, cookies.

Support & Surveys: help tickets, ratings, responses.

Teacher/Applicant: CV, qualifications, recruitment details.

Consent & Preferences: cookie choices, marketing subscriptions, privacy requests.

Special categories: We do not collect sensitive data (e.g., health, religion, political opinions, biometric identifiers) unless you voluntarily provide it in learning content.

4) How we use data & legal bases

We only process data when we have a legal basis.

PurposeDataLegal basisRecipientsRetention
Account creation & managementAccount, Contact, GuardianContractHosting, CRMLife of account + 24 months
Deliver classesLearning, Audio, DeviceContract; Legitimate interest (safety/quality); Parental consent for minorsTutors, video/voice, AI toolsAudio recordings 12 months
Placement & personalizationLearning, DeviceContract; Legitimate interestAI/analyticsCourse duration + 24 months
Payments & invoicingBilling, ContactContract; Legal obligationPayment providers, accountants7–10 years
Support & safetyAccount, Support, Logs, AudioLegitimate interest; Legal obligationCRM, trust & safety toolsTickets 24 months; logs 12 months
Analytics & improvementUsage, CookiesConsent (non-essential); Legitimate interest (essential)Analytics providers14 months
MarketingContact, PrefsConsent; Legitimate interest (soft opt-in)Email/SMS vendorsUntil unsubscribed
Research & publicationsLearning, Performance, Aggregated DataConsent (if personal/pseudonymised); Legitimate interest (if anonymised)Internal teams, research institutionsAnonymised indefinite; pseudonymised until research complete
Legal & complianceAnyLegal obligation; Legitimate interestRegulators, courtsAs required

Automated assistance: Placement tests and AI suggestions may guide learning, but they never have legal or significant effects without human review.

5) Children & Teens

Age thresholds
In the EU/EEA, parental or guardian consent is required if the user is under the digital age of consent (13–16 depending on the country).

To ensure compliance across all EU markets, we require verified parental/guardian consent for all users under 16.

We do not knowingly permit children to register or use our services without verified parental/guardian involvement.

Parental consent & verification
During signup, users under 16 must provide a parent/guardian’s contact information.

Parents/guardians confirm consent by email and/or checkbox verification before lessons begin.

If consent is withdrawn, the child’s account is suspended and personal data deleted, unless retention is required for safety, disputes, or legal obligations.

How we use children’s data
Lesson scheduling, account management, and progress tracking.

Audio lesson recordings for quality assurance, compliance, and child safety.

Anonymised or aggregated learning data may be used for research/publications, never identifiable to a child.

No targeted advertising to minors; marketing cookies are disabled for under-18s.

Parents’ rights
Parents/guardians can:
Access their child’s data, including lesson recordings.

Correct or update data.

Request deletion of their child’s account.

Contact: parents@nwmoon.com.

Safety & inappropriate behavior reporting
All lessons are recorded.

Teachers may not exchange personal contact details with children.

Reports of inappropriate behavior can be sent to safety@nwmoon.com.

Reports are reviewed within 24 hours; urgent cases may trigger immediate suspension and, if necessary, referral to authorities.

Data retention for minors
Lesson recordings for minors are kept for at least 12 months for safety monitoring.

After this period, recordings may be anonymised or deleted unless required for legal/safety reasons.

6) Research and Data Use

We may use student performance data, lesson transcripts, and related learning analytics for internal research to improve teaching methods and develop new educational insights.
We may also:
Publish research findings in aggregated or anonymised form (e.g., articles, reports).

Share or sell anonymised, aggregated datasets to third-party research institutions, laboratories, or partners.

Important:
Any dataset shared externally will be fully anonymised so that no student or child can be identified.

If we ever use personal or pseudonymised data for research, we will request your explicit consent in advance.

Research use is separate from lesson delivery and you may decline without affecting your access to services.

7) Cookies & Tracking

Consent: EU/EEA users are asked to consent to analytics/marketing cookies. Consent can be changed anytime via “Cookie Settings.”

Categories:

Strictly necessary (always on)

Analytics (consent)

Cookie list: A live vendor list with purposes and lifetimes is available a Cookies .

We do not use third-party ad networks on the learning platform.

We use Sentry to monitor and improve website performance. It collects technical data about errors and usage. This tracking is optional.

8) Sharing & Recipients

We share data only as needed:
Service providers: hosting, video/voice, storage/CDN, scheduling, analytics, payments, CRM, email/SMS, AI tools.

Tutors/contractors: limited access under confidentiality agreements.

Research partners: only anonymised, aggregated datasets, unless explicit consent is obtained for pseudonymised use.

Legal/disputes: if required by law or to resolve complaints.

Corporate transactions: mergers, acquisitions, sales.

We do not sell identifiable personal data.

9) International transfers

We are based in Armenia, which does not have an EU adequacy decision. Transfers from the EU/EEA to Armenia (and elsewhere) use Standard Contractual Clauses (SCCs) with supplementary measures.
For US vendors, we rely on SCCs and, where available, the EU-US Data Privacy Framework.

10) Security

We apply:
Encryption in transit and at rest

Access controls and MFA

Vendor due diligence and DPAs

Monitoring, logging, incident response

If a breach risks EU/EEA users, we notify them and regulators within 72 hours.

11) Retention

Account/profile: life of account + 24 months

Audio lesson recordings: 12 months, unless longer is required for dispute resolution, compliance, or safety

Lesson transcripts: 12 months

Research datasets: anonymised data may be kept indefinitely; pseudonymised research data is retained only until research is complete

Support/chat: 24 months

Analytics: 14 months (vendor default)

Security logs: 12 months

Payments/invoices: 7–10 years (tax law)

Backups are retained temporarily and deleted automatically.

12) Your rights (EU/EEA)

You have the right to:
Access, rectify, or erase your data

Restrict processing

Port your data in machine-readable format (CSV/JSON)

Object to processing (including research use)

Withdraw consent anytime (including research consent)

Lodge a complaint with your national supervisory authority (see EDPB list)

In Armenia, you may also contact the Personal Data Protection Agency under the Ministry of Justice.
How: contact privacy@nwmoon.com Response within one month.

13) Marketing choices

You can unsubscribe anytime. We only send marketing if you consent or under soft opt-in rules.

14) Social logins

If you connect Google, LinkedIn, or others, we receive identifiers for login. You can disconnect anytime.

15) AI and automation

We use AI tools (e.g., transcription, feedback). Vendors are configured to opt out of model training where possible, however, we are not in control of the actions of third parties, that are out of our legal control. We do not make solely automated decisions with legal or significant effects.

16) Teacher & applicant data

Applicants’ data (CVs, qualifications) are processed for recruitment and onboarding, retained for compliance or future hiring.

17) Changes to this Policy

We may update this Policy. Material changes will be notified by email or in-app before they take effect.

18) Contact

Your use of the Services is also governed by our Disclaimer & Liability Notice, Notice.
Controller:
nwmoon Education LLC,
Privacy email: privacy@nwmoon.com
EU Representative:

Name: Soheil Lotfi Address: 21 Rue André Maginot, Paris, France Postal code: 91400 Orsay, Email (EU GDPR Contact): soheil@nwmoon.com

Contact;
privacy@nwmoon.com
safety@nwmoon.com
parents@nwmoon.com
info@nwmoon.com

Kids’ Privacy Statement

This page is written for children and teens.
We want you to know how we keep your information safe at nwmoon.

Your account
When you sign up, we ask for your name, age, and your parent or guardian’s email. If you are under 16, your parent must say “yes” before you can start lessons.

Lesson recordings
All lessons are recorded. This helps us check teacher quality and keep you safe. Your parents can ask to listen to these recordings.

What we do with your data
We use your information to:

  • Book and run lessons
  • Track your learning progress
  • Keep our platform safe

We do not use your data for ads.

Your parent’s rights
Your parent or guardian can:

  • Ask to see what data we keep about you
  • Ask us to fix or delete your data
  • Stop your account if they want

They can contact us at parents@nwmoon.com.

Staying safe
Teachers are not allowed to talk to you outside nwmoon.

If anything feels wrong or uncomfortable, you or your parents can report it at safety@nwmoon.com. We check reports within 24 hours.

Cookies
We use small files called cookies to make the site work. For children, we only use the cookies needed for lessons - never ads.

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nwmoon is an online English learning platform combining live 1-on-1 coaching with AI-powered practice. CEFR-aligned from A1 to C1. Students in 30+ countries.

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