Privacy Policy

At 360 Y.E.S. YOUR ENGLISH SOLUTIONS SP. Z O.O. ("us", "we", or "our"), we are committed to protecting your privacy. This Privacy Policy explains how we process personal data on 360yes.eu and app.360yes.eu, including public AntiMethod lesson pages, and when you use an account or other platform services.

Our core promise: We deeply respect your privacy. We do not sell your personal data to any third parties. Your data is used exclusively to provide you with the best possible language learning experience, improve our platform, and keep you informed.

The Data Controller responsible for processing your personal data is: 360 Y.E.S. YOUR ENGLISH SOLUTIONS SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ

Address: ul. Sucha 2/4 / U1, 92-331 Łódź, Poland

NIP: 7282796797

Email: office@360yes.eu

A. Account Registration & Authentication - Public lesson pages can be used without creating an account. When you register for account-based services, we process the registration details you provide, such as your email address, phone number where requested, and authentication information. If you use Google sign-in, we receive the basic profile information provided by that service, such as your name and email address. We process these data to create and manage the account and provide the requested service (Article 6(1)(b) GDPR).

B. Service Usage & E-Learning Data - What we collect: When you use app.360yes.eu, we process your interactions with the platform (progress in courses, test scores, exercise completions, dictionary searches, and AI chat interactions). Why we process it: Essential for tracking progress, customizing AI responses, and providing feedback (Article 6(1)(b) GDPR).

C. Payments and Subscriptions - What we collect: If you purchase a premium subscription, we collect billing details. Payment processing is handled securely by third-party gateways; we do not store full credit card details. Why we process it: To process transactions and comply with tax regulations (Article 6(1)(c) GDPR).

D. Optional Analytics and Lesson Improvement - On public lesson pages, we use Mixpanel, Inc. to measure engagement and improve lessons, navigation and sharing. This optional processing starts only after you accept analytics and session recording in the cookie notice, on the basis of consent (Article 6(1)(a) GDPR). Refusing or withdrawing this consent does not prevent access to the public lesson.

Analytics data include a pseudonymous browser identifier; lesson and page identifiers; visit timestamps; device, browser and operating-system information; approximate location derived from the connection IP address; referring website; valid campaign tags in the link; viewed sections; scroll-depth and engagement-time milestones; clicks; example selections; quiz answers, attempts, correctness and first-attempt scores; completion of the core quiz; expanded explanations; sharing actions; clicks to another lesson or to the beta application; and clicks intended to open an email suggestion. We measure activity, not proof that a person read, understood, sent a message or completed an external registration.

Referrals - When a visitor who accepted analytics generates a sharing link, the link may contain a random referral identifier. If another consenting visitor opens it, we can relate the recorded arrival to the sharing browser. These are separate visitors; the referral identifier does not identify the recipient as the sender. In the present lesson setup, a beta-application click is not a completed signup, and confirmed purchases or customer-account identity are not inferred from that click.

Session replay and heatmaps - For consenting visits, Mixpanel may reconstruct the interaction with the lesson, including scrolling, clicks and visible page changes, and compile click heatmaps. This is a reconstruction of the webpage, not a camera, microphone or whole-device recording. Form inputs and the suggestion form are blocked or masked in replay, email-draft links are blocked, and the analytics code does not send suggestion-message content. Console-log and network-request recording are disabled. Selected public lesson text is visible in replay. The code also removes raw URL query strings and email addresses from analytics-event payloads; do not put personal information in shared URLs or campaign labels.

E. Newsletter and Marketing Communication - What we collect: We collect your email address to send you occasional newsletters, updates about new courses, or promotional offers. Why we process it: We process this data based on our legitimate interest in promoting our services to registered users (Article 6(1)(f) GDPR) or based on your explicit consent (Article 6(1)(a) GDPR). How to opt-out: You can unsubscribe from these communications at any time by clicking the "unsubscribe" link provided in every email or by contacting us directly at office@360yes.eu.

F. Suggestions and External Forms - If you choose to email a suggestion, we receive the message you actually send and process it to respond and consider improvements (Article 6(1)(f) GDPR, our legitimate interest in handling voluntary feedback). Clicking the suggestion button alone does not send the message. The beta application currently opens a Mailchimp-hosted page; if you submit it, the information supplied there is used to handle your application or subscription under the notices and choices shown on that form. The lesson analytics code does not collect the form fields from that external page.

Our platform is intended for users who are at least 18 years old. By registering an account, you declare that you are 18 years of age or older. If you are under 18, you may only use our platform with the explicit consent and supervision of a parent or legal guardian. We do not knowingly collect personal data from children without verified parental consent. If we become aware that we have collected data from a child without such consent, we will take steps to delete that information promptly.

Our platform features an interactive AI chat. The contents of your conversations are processed to generate responses and assist with language learning. We do not use conversational data to identify you outside the platform. Please do not share sensitive personal or financial information within the AI chat.

We use service providers for hosting, delivery and security, authentication, communications and analytics. On the public lessons described here, Mixpanel, Inc. processes the optional behavioral analytics, session-replay and heatmap data on our behalf. Google authentication and Mailchimp-hosted application or newsletter forms may be used when you choose the relevant service. Cloudflare may provide page delivery, security and operational measurement where deployed on the website. The lesson cookie control described in Section 6 governs this Mixpanel integration; it does not grant consent for unrelated advertising services.

The current lesson Mixpanel project is configured for EU data residency. This does not constitute a promise that every provider support or subprocessor operation takes place only in the EEA. Where personal data are transferred outside the EEA, the applicable transfer mechanism and safeguards must apply, such as an applicable adequacy decision, the EU-US Data Privacy Framework or Standard Contractual Clauses. Mixpanel describes its processing and transfer arrangements at https://mixpanel.com/legal/dpa/. Contact office@360yes.eu for information about relevant recipients and safeguards.

References to a service do not mean that it is activated on every page. Any additional advertising or analytics integrations, including Google Analytics or Meta Pixel if introduced, must be disclosed and subject to the applicable choices before activation.

Necessary storage - We store your cookie/analytics choice in first-party browser storage so the lesson can remember and apply that choice. This preference is configured to expire after 180 days. Necessary account, security or functional storage may also be used when you use the corresponding platform services.

Optional Mixpanel storage - After acceptance, Mixpanel uses a first-party cookie containing a browser identifier and related analytics information. Its configured lifetime is 180 days; it may be renewed during use. We also use first-party local storage for repeat-visit markers and a random sharing/referral identifier. These separate local-storage entries do not currently have their own automatic expiry. They are removed by the lesson withdrawal control or when you clear the relevant browser storage.

Your choice - You can accept or reject optional analytics and session recording in the notice. Reopen it at any time using "Ustawienia cookies" in the lesson footer. Withdrawing consent stops future Mixpanel collection and session recording from this integration and removes the local repeat-visit/referral entries. Withdrawal does not invalidate earlier lawful processing or automatically erase records already sent to Mixpanel; see Section 8 to request deletion. Clearing browser storage may cause the notice to appear again. Consent on one origin is not automatically transferred to unrelated websites or devices.

We retain your personal data for as long as your account remains active or as required by legal obligations.

Account Deletion: You have the right to request the deletion of your account and associated personal data at any time. To do so, please send an email request to office@360yes.eu.

Inactive Accounts: Under GDPR principles (data minimization and storage limitation), personal data should not be kept longer than necessary. While we do not automatically delete inactive accounts at this time, we periodically review our databases and reserve the right to delete accounts that have been entirely inactive for an extended period (e.g., several years), notifying you beforehand where possible.

Lesson analytics - Cookie and preference lifetimes are described in Section 6. They are different from the retention of records already sent to Mixpanel. Mixpanel session replays are kept for the service's default period of 30 days from ingestion under the current standard replay configuration. Analytics events are separate records; their retention is governed by our project settings and the purpose-based criteria below, rather than automatically ending when a browser cookie expires.

We retain browser-level analytics only for as long as needed to compare lesson performance over relevant reporting periods, assess referral and campaign performance and investigate usability issues. Once individual-level records are no longer necessary for those purposes, they should be deleted or de-identified; non-identifying aggregate statistics may be kept for longer. Any legal requirement to preserve specific records is assessed separately. You can ask office@360yes.eu about applicable retention or request deletion. No automatic fixed deletion period for analytics events is established by the lesson HTML itself.

As a user in the EEA, you have the right to: Access, Rectification, Erasure ("Right to be Forgotten"), Restrict Processing, Data Portability, Object, and Withdraw Consent. To exercise these rights, email us at office@360yes.eu. You also have the right to lodge a complaint with the Polish President of the Personal Data Protection Office (PUODO).

You do not need to create an account to withdraw lesson analytics consent. For access or deletion requests relating to a pseudonymous visit, tell us the lesson and approximate visit time and, if available, the browser identifier. We may request proportionate information to locate the relevant record and verify the request; do not send passwords or full payment-card details.

We implement technical and organizational security measures (HTTPS encryption, secure hashing, restricted access) to protect your data from unauthorized access or loss.

We may update this policy to reflect changes. We will notify you of significant changes via email.

If you have any questions, complaints, or requests regarding this Privacy Policy or your personal data, please contact us at:

360 Y.E.S. YOUR ENGLISH SOLUTIONS SP. Z O.O.

ul. Sucha 2/4 / U1, 92-331 Łódź, Poland

NIP: 7282796797

Email: office@360yes.eu