Privacy Policy

At ThinkLab Media Co., Ltd, doing business as 7ESL, we prioritize the privacy and security of your personal information. By using our website and services, you are consenting to our processing of your personal data in line with our Privacy Policy. As our policy may change over time, we encourage you to review it periodically to stay informed about our practices.

It is important for you to understand what personal data we collect and process about you, and how we protect and uphold your rights with regards to data protection. Personal data encompasses any information that can be linked to an individual, whether directly or indirectly. This may include identifiers such as name, address, email, and more, as well as commercial, biometric, and geolocation data, among others. Our commitment as a company is to process this data in a lawful, fair, and transparent manner, ensuring that we respect your rights, minimize data collection, and maintain data integrity and confidentiality.

Safeguarding Visitor Information

We continuously scan our website for security vulnerabilities and potential threats to ensure a secure browsing experience. Our site undergoes regular malware checks. Additionally, our content focuses on providing articles and information, without requiring visitors to share personal details such as email addresses or credit card numbers.

Disclosure to Third Parties

We do not share your personal information with external entities unless we have informed you beforehand. Exceptions include our website hosting partners and other collaborators assisting us with our website, business operations, and user services, provided they commit to maintaining confidentiality. We may also disclose information if deemed necessary to abide by legal requirements, enforce site policies, or safeguard our or others’ rights, property, and safety.

Please note, we might supply non-personal visitor data to third parties for marketing, advertising, or other purposes.

External Links

Occasionally, we may present third-party products or services on our website at our discretion. These third-party websites maintain their own privacy policies, which are separate and unrelated to ours. As such, we are not responsible nor liable for the content or activities found on these linked websites. However, we strive to maintain the integrity of our website and encourage feedback regarding these external sites. We advise you to review the privacy statements of these linked sites, applications, or digital platforms to safeguard your privacy.

As a resident of the European Economic Area (EEA), you possess specific data protection rights. Our goal is to adopt reasonable measures to enable you to modify, correct, erase, or limit the use of your Personal Data.

Under certain circumstances, you have the following data protection rights:

  • The right to access, update, or delete your information. You can access, update, or request the deletion of your Personal Data whenever possible. If you cannot perform these actions independently, reach out to us for assistance.
  • The right to rectification. You possess the right to request corrections to your information if it is inaccurate or incomplete.
  • The right to object. You have the right to oppose our processing of your Personal Data.
  • The right to restriction. You can request that we limit the processing of your personal data.
  • The right to data portability. You are entitled to receive a copy of the information we have on you in a structured, machine-readable, and commonly used format.
  • The right to withdraw consent. You have the right to revoke your consent at any time if we relied on it to process your personal information.

To remove your personal data and account from our system, please contact us. Upon initiating the request, you will receive confirmation to finalize the deletion process.

Nevada Consumers

In compliance with Nevada law, we protect the rights of Nevada consumers by offering an option to request that their personal information not be sold, even if it’s not currently being sold. To exercise this right, Nevada consumers should email us at contact (at) 7esl.com or contact (at) thinklab.media.

Respecting California Residents’ Privacy Rights

In some instances, we have sold users’ Personal Information to Third Parties for their direct marketing purposes or disclosed it for our own business purposes, including within the past 12 months.

As a California resident, you are entitled to:

  • Opt-out of the sale of your Personal Information to certain affiliates and other Third Parties for their marketing objectives. To exercise this right, send your request to contact (at) 7esl.com. Identity verification is not required for opting out.
  • Inquire about the categories of Personal Information we have collected, used, sold, and/or disclosed to Third Parties for their direct marketing purposes or our business purposes during the previous twelve months.
  • Request that we delete your Personal Information and notify Third Parties to whom we have sold it within the 90 days before your request, informing them of your decision to opt-out, and instructing them not to further sell your information. To ensure no unintended deletions occur, we employ a two-step process in which we confirm your deletion request.
  • Be treated impartially by us when exercising your privacy rights under the California Consumer Privacy Act. To submit your request for information and/or deletion, please email contact (at) 7esl.com.
      1. We need to verify your identity before providing information on your Personal Information usage. Depending on the sensitivity of the data you request, the verification process may vary, but we will keep it as simple as possible.
      • (a) If you have a password-protected account, logging in or complying with item (b) may be necessary for identity confirmation.
      • (b) If you do not have a password-protected account, you will need to match personal information we have on file for you.
      1. Categories: When requesting specific categories of Personal Information we maintain, match at least two items of your Personal Information.
      1. Specific pieces: For specific pieces of your Personal Information, match at least three items and provide a sworn declaration confirming your identity.
      1. Request to delete: Depending on the sensitivity of the requested information, adhere to either item 1(a) or 1(b) in this Section.
      1. Authorized Agent: An Authorized Agent can exercise your right to know, delete, or opt-out. However, additional documentation is needed to confirm your authorization. The Authorized Agent must provide:
      • (a) Your written permission and their own identity verification, or
      • (b) A Power of Attorney.

We strive to protect your Personal Data by using secure communication and data transfer protocols (such as HTTPS), anonymizing, or pseudonymizing when appropriate, and monitoring our systems for potential vulnerabilities and attacks. When possible, stored data is encrypted.

Despite our efforts, we cannot guarantee total information security. Nevertheless, we commit to notifying relevant authorities and you if there is a threat to your rights or interests. We will take all reasonable measures to prevent security breaches and cooperate with authorities in the event of a breach.

If you have an account with us, remember to keep your username and password confidential.

Information We Collect

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.

Log Data

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, geolocation, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

Device Data

When you visit our website or interact with our services, we may automatically collect data about your device, such as:

  • Device Type
  • Operating System

Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

Personal Information

We may ask for personal information — for example, when you register an account or when you contact us — which may include one or more of the following:

  • Name
  • Email
  • Native language
  • Age
  • Social media profiles

Audio Data

Some speaking tasks involve you speaking on our website. To recognize speech your audio may be sent to a third party provider such as Google. Any audio you agree to send to us for our internal business purposes, including without limitation for purposes of language proficiency evaluation, dispute resolution, and improving our services. By accepting this policy you agree that we may transfer your audio for the purpose of language proficiency evaluation to our tutors and specialists or provide them with access to your audio files.

To have access to some of our services you will need to actively provide access to a microphone. We will then collect recordings of your voice speaking to improve our services, and do not derive a voice print or any other information that could be used to identify you from your vocal data.

Aggregated Data

We also collect, use and share aggregated data such as statistical, demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your personal data to provide statistics on language proficiency. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

Collection and Use of Information

We may collect personal information from you when you do any of the following on our website:

  • Register for an account
  • Use a mobile device or web browser to access our content
  • Contact us via email, social media, or on any similar technologies
  • When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to provide you with our platform’s core features and services
  • to respond to your requests, for example to contact you about a question you submitted to us, or contact you regarding your use of the website
  • to inform you about changes in your services and software, our service offering and other important service-related notices
  • to protect our rights and interests as well as the rights and interests of our users and any other person
  • to enable you to customize or personalize your experience of our website
  • for analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms
  • for technical assessment, including to operate and improve our website and other software, associated applications, and social media platforms
  • to perform research and analysis about your use of, or interest in, our software, products, services, content, or products, services or content offered by others
  • to comply with applicable legal or regulatory obligations, including complying with requests from law enforcement or other governmental authorities, or in legal proceedings involving our website
  • to fulfill our contractual obligations
  • to communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
  • initiate a payment, add value to an account, or pay a bill, if required
  • prevent and investigate fraudulent or other criminal activity

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, Our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our site to improve our site and your experience on it.

We do not collect the following special categories of personal data about you: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, data about your health data.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Children

Children’s Privacy

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Our priority is to safeguard the privacy of children. We have no intention of collecting, knowingly collecting, selling, or soliciting Personal Information from individuals below the age of 16. Our services are not aimed at children. If you are below 16, please abstain from using our website or providing any information through its features. If there is reason to believe that a child under 16 years old may have shared their Personal Data with us, we request that a parent or guardian reach out to us at contact (at) 7esl.com.

We utilize cookies and similar technologies in order to evaluate customer behavior, manage the website, monitor user interactions, and gather information about our users. This allows us to personalize and improve the user experience.

A cookie is a minuscule text file saved on your computer. Cookies hold information that assists in making websites function properly. Only our website can access the cookies created by us. Users have the ability to control cookies at the browser level. However, disabling cookies can potentially impede the usage of certain website features.

Cookies

We employ cookies for the following reasons

  • Necessary cookies – These cookies are essential for accessing important features on our website, such as logging in. No personal information is collected by these cookies.
  • Functionality cookies – These cookies enable our service to be more convenient and allow for the provision of personalized features. For instance, they may recall your name and email in comment sections, so you do not have to re-enter the information when commenting again.
  • Analytics cookies – These cookies aid in monitoring the usage and performance of our website and services.
  • Advertising cookies – These cookies are employed to present advertisements that pertain to your preferences and interests. They also help limit the frequency at which you see an advertisement. Generally, these cookies are placed on the website by advertising networks with the permission of the website operator. The cookies remember that you have visited a particular website, and this information is shared with other organizations, such as advertisers. Often, targeting or advertising cookies are connected to the site functionality provided by another organization.

Here are the cookies we use:

  • Google Analytics – persistent cookie – 2-year duration – Our website utilizes Google Analytics to enhance user experience (you can opt out here)
  • Popup cookie – persistent cookie – 30-day duration – We provide you with the opportunity to be informed about new content and marketing materials.
  • YouTube – persistent cookie – 30-day duration – We integrate YouTube videos on our site to offer you supplementary educational content.

Cookies can be removed from your computer through your browser settings. Alternatively, you can manage some third-party cookies by using privacy-enhancing platforms such as optout.aboutads.info or youronlinechoices.com. For more information on cookies, visit allaboutcookies.org.

We use Google Analytics to gauge traffic on our website. Google has its own Privacy Policy, which you can review here. If you prefer to opt out of tracking by Google Analytics, please visit the Google Analytics opt-out page.

Our Approach to “Do Not Track” Requests

As required by California and Delaware laws, we inform you about our stance on web browser Do Not Track (DNT) signals. Presently, there is no established industry or legal guideline for acknowledging or respecting browser DNT signals. Consequently, we neither monitor nor respond to such requests at this time.

Fair Information Practices

The fundamental principles of privacy law in the United States are founded on Fair Information Practices. These concepts have greatly impacted data protection laws worldwide. Comprehending these principles and their execution is essential to ensure compliance with privacy laws safeguarding personal data.

Should a data breach occur, we will take the following measures to align with Fair Information Practices:

  • Notify users via email within 7 business days
  • Notify users through in-site notifications within 7 business days

Additionally, we uphold the Individual Redress Principle, which mandates individuals possess the right to seek legal enforceable rights against data collectors and processors that do not adhere to the law. This principle guarantees not only enforceable rights for individuals against data users but also access to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

Can Spam Act

As a company, we adhere to the CAN-SPAM Act, which governs the rules and requirements for sending commercial emails. Our commitment to the CAN-SPAM Act ensures the appropriate use of email communication with our clients.

We collect your email address to:

  • Share information, answer queries, and address any requests or concerns.
  • Stay connected with our mailing list and maintain contact with clients after the initial engagement.

In compliance with the CAN-SPAM Act, we pledge to:

  • Avoid using deceptive or misleading subjects or email addresses.
  • Clearly identify our emails as advertisements, as required.
  • Provide our physical business or site headquarters’ address.
  • Supervise third-party email marketing services for adherence to rules if we employ their services.
  • Swiftly honor opt-out/unsubscribe requests.
  • Enable unsubscribe options through a link available at the bottom of each email.

Should you wish to stop receiving future emails, kindly follow the instructions at the bottom of each email, or contact us through email. Rest assured, we will swiftly remove you from any further correspondence.

Mediavine Programmatic Advertising (Ver 1.1)

The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.

The Website collects the following data using a cookie when serving personalized ads:

  • IP Address
  • Operating System type
  • Operating System version
  • Device Type
  • Language of the website
  • Web browser type
  • Email (in hashed form)

Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.

If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.

Arbitration

In the event of any disagreements, claims, or disputes that arise from or relate to this Privacy Policy, including its breach, termination, enforcement, interpretation, or validity, these matters will be resolved through final and binding individual arbitration in Detroit, Michigan. The arbitration process will not involve class, representative, or collective actions. The arbitration will be conducted under the rules set forth by the Michigan Arbitration & Mediation Service or an alternative agreed upon by the parties.

The arbitration fees will be shared equally between the parties according to the pertaining Rules of Arbitration. If one party refuses to participate in arbitration, challenges the arbitrator’s decision unsuccessfully, or disregards the arbitrator’s decision, the other party may claim costs incurred in the legal process, such as a reasonable attorney’s fee, to enforce their participation or uphold the arbitrator’s decision.

It is essential to note that contracts containing arbitration clauses, especially those concerning employment relationships, must include the following statement in bold print above the signature lines:

THIS CONTRACT CONTAINS A BINDING ARBITRATION PROVISION THAT AFFECTS YOUR LEGAL RIGHTS AND MAY BE ENFORCED BY THE PARTIES.

Reaching Out to Us

Should any inquiries arise about this privacy policy, we welcome you to reach us through the following:

Email: contact (at) 7esl.com or contact (at) thinklab.media

Last modified: 2023-11-10