Privacy Policy

Last modified Sep 30, 2025. See what changed.

Master English Ltd. (hereinafter “Master English”, "Company", "We", “Us” or “Controller”) respects your privacy and committed to protecting it in accordance with applicable laws and this Privacy Policy (the “Policy”).

We collect and process your Personal Data when you (the “User”, “Customer”, “You” or “Data Subject”) visit our website (www.masterenglish.com), use our Master English App (the “App”), sign up for our newsletter or request more information about or purchase our Service. This Policy contains information about our data processing (including but not limited to, what type of data we collect, how we protect your data, how long do we store your data, legal basis for processing of your Personal Data and rights that you have under the applicable law).

For the purposes of this Privacy Policy Master English Ltd. acts as a “Controller” of your Personal Data.

1. Controller’s details and contact information.

Master English Ltd.
Verstaankatu 1
33100 Tampere, Finland
privacy@masterenglish.com
Data Protection Officer - Atte Hynninen.

What type of data we collect?

To use Master English Service, you have to create an account with us. In order to create the account, you have to provide us with your valid email address and your name. You could provide either your first name or a full name (if you chose to do so). It is important that you provide us with a valid email address, as we need that for setting up of your account, resetting password (in case you forget your password), accessing the account and for verification/validation of user in case of data subject’s requests.

Additionally, we process other kinds of Personal Data about you such as:

Identity Data (includes first name, last name (where a user has decided to provide it), username or similar identifier)
Contact Data (includes mainly an email address and in some rare cases a phone number)
Financial Data (this data is not processed by Master English, but by the external payment providers listed in our Terms of Use).
Transaction Data (includes details about your subscription status, details of Service you have purchased from us).
Technical Data (includes internet protocol (IP) address, your login data, browser type and version, time zone setting and country location, browser plug-in types and versions, operating system and platform, device attributes, device ID and other technology on the devices you use to access website or Service).
Profile Data (includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses (where applicable)).
Usage Data (includes information about how you interact with and use our website, App and our Service). For Artificial Intelligence (AI) Usage Data, please see section 4.
Marketing and Communications Data (includes your preferences in receiving marketing from us and our third parties and your communication preferences).

We also process aggregated data such as statistical data, which is not Personal Data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website or App feature, in order to analyze general trends in how users are interacting with our website or App, to help improve the website and our App Service offering.

3. How is your Personal Data collected?

Master English uses different methods to collect data from and about you through:

Registration and communication with us. We collect your Identity Data and Contact Data when you register your account with us. You may also provide us with your Personal Data by corresponding with us via email, chat or via phone (in some cases).
Cookies. We use cookies (small files placed on your device) and other tracking technologies on the App and website to improve your experience and our development of the App and our Service. A detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies please see the Cookie Banner.
Information you generate when using our App and Service. Each time you access and use our App and Service we collect Content, Device, Cookies, Personalization and Usage Data. We collect Content Data where you upload it to the App or interact with the content available on the App, such as written or recorded answers, audio recordings (for pronunciation practices) or notes added manually by customer service or R&D. We collect Device, Cookies, Personalization and Usage Data and using cookies and other similar technologies to provide you with your learning and statistics progress and save your setting and preferences.
Information we collect through monitoring the use of our App, Sites and Service. Each time you access and use our App and Service we collect information about that access and use, being Device, Content, Cookies, and Usage Data.
Direct Marketing. We collect and record Direct Marketing Data when you provide your consent or when it is otherwise permitted for us to add you to our marketing database, or when you interact with our direct marketing communications, or we receive prospect information from our data broker partners.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below, or process your personal data with these third parties:
- Technical Data is collected from the following parties:
  - analytics providers such as Data.ai
  - advertising networks such as Google Analytics, Meta Platforms, LinkedIn Ads, Pinterest Ads. See full list here.
- Financial and Transaction Data is collected from providers of technical and payment services to provide details about the Service purchased and their status. Please note that we do not process your payment information, but rather receive an information from the payment provider regarding the status of the payment for the Service purchased.

4. How we use your Personal Data

We will only use your Personal Data when we have a lawful basis to do so. Our lawful basis for each purpose for which we use your Personal Data is specified below. We will use your personal data in the following circumstances:

Consent. Where you have freely consented before the processing in a specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time using our Cookie Banner or contacting us at soporte@masterenglish.com.

Performance of a contract. Where we need to process your Personal Data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract.

Legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at soporte@masterenglish.com.

Legal obligation. Where we need to use your Personal Data to comply with a legal or regulatory obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order.

We will only use your Personal Data for the purpose for which we collected it, which includes the following:

to register you as a customer
to process and deliver your order
to manage your relationship with us
to perform our obligations to you under the contract
to improve our website, products/services, marketing or customer relationships.

Artificial Intelligence (AI). As part of our Service, we use AI. The purpose of our AI system is to support Customer’s learning process and to emulate the real-life situations, where the Customer needs to engage in the conversation in English. Whenever you interact with our AI system, based on your input, it will evaluate your answers and will produce artificially generated response/materials. For example, we use AI to create a Role Play situations, where you would interact with the AI as you would with a human being. The same applies to the situations where AI evaluates your pronunciation and, in case of mistakes, provides you with the correct pronunciation. Furthermore, we utilize the AI capabilities to enhance your overall learning process. If you make certain types of mistakes, the AI system will evaluate your mistakes, and as part of your learning process, will personalize some lessons, which would specifically tackle your problematic aspects. Depending on your case, the AI system may provide you with pronunciation lessons, grammar or comprehension lessons. You can get your personalized lessons, which will help you to succeed in your learning of English language.

As part of our AI model, we use OpenAI and Anthropic Large Language Models (LLMs). However, no personal data is used to train the AI models, and we do not share or allow others, such as OpenAI or Anthropic, to use your personal data or to train their models. Furthermore, no personal data could be revealed as part of the output generated by our AI system. Our AI model is trained with the input from the Customers, particularly from the Customer’s responses (pronunciation recordings). When our AI models are trained, the training undergoes a human oversight to ensure accuracy and compliance with applicable laws. Our qualified professionals assess the recordings and classify them as being correct or not, and/or specify where the mistake was made, and also recommend the correct answer (pronunciation).

For more detailed information about our AI usage, please refer to our Terms and Conditions.

We could further process your Personal Data beyond that which you have consented to, if such new processing is compatible with the initial processing purpose. If the new intended processing of your Personal Data is incompatible with the initial processing purpose, we would provide you with a new notice and request to obtain a new consent or other legal basis for the new processing purpose.

5. How we disclose/share your personal data

We may share your Personal Data with within our group companies. Where we transfer your Personal Data between our group companies, we ensure your Personal Data is protected by requiring all our group companies to follow the same rules when processing your Personal Data.

We may also share your Personal Data with the following third parties:

Your Appstore Provider and mobile network operator to allow you to install the App.
Service providers, acting as processors based in UK, USA, Finland, Mexico, who provide IT and system administration services, hosting services for our App and website, payment processing, customer service support, email delivery and administration, and data storage and analysis. See the list here.
Marketing and promotional partners and co-operatives acting as processors with whom we share data to enhance our offerings and identify prospective customers. See the list here
Our professional advisors, including lawyers, auditors, insurers, consultants, who provide legal, accounting, insurance services.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the applicable law. We do not authorize our third-party service providers to use your Personal Data for their own purposes and only authorize them to process your Personal Data for specified purposes and in accordance with our instructions.

6. International transfers

In order to fulfil your order and process your payment Master English needs to transfer, store and process your Personal Data internationally, i.e., outside of the country where it was originally collected. Our servers are located in the European Union (Amazon Web Services) and in the United States (Amazon Web Services), while our partner payment providers are located in the United Kingdom and in the United States. Our Customer Success teams are located in Mexico and Finland. For our customers located in European Union, we use servers in European Union. For our customers located in United States or in Latin America, we use servers in United States.

Whenever we transfer your personal data out of the country where it was originally collected to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your Personal Data to countries that have been deemed by your country, or the EU to provide an adequate level of protection for Personal Data, e.g., Adequacy Decisions for Argentina, Uruguay, UK Adequacy Decision, EU-U.S. Data Privacy Framework etc.
In case of absence of adequacy decisions, we may use specific standard contractual clauses/terms approved by your country or approved for use in the EU and/or the UK, which gives the transferred Personal Data the same protection as in your country or in the EU and/or the UK. These for example are International Data Transfer Agreements, The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers etc.

7. Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you in case of breach where we are legally required to do so.

8. Data Retention - for how long we will use your Personal Data

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We will keep the basic information about our customers for two (2) years after they cease being our customers, except for Financial and Transaction Data, which may be retained for longer due for tax or other legal requirements, which we must comply under the law. During the two (2) year period the customer will have a possibility to return (i.e., to become an active customer again) and will have his/her learning progress retained in our system in order to continue studies. Master English is not obliged to retain any data after the two (2) year period has elapsed. After the stipulated period, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, or to develop and improve our Service.

9. Your (Data Subject’s) Legal Rights

You have a number of rights under data protection laws in relation to your Personal Data.

You have the right to:

Access. This enables you to know what type of Personal Data we have about you and to check that we are lawfully processing it.
Correction. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Deletion/Erasure. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with the local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Objection. This is for cases where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
Restriction. This is for situations where there is a request that we should restrict or suspend our processing of your Personal Data:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful, but you do not want us to erase it;
- where we no longer require it, but you need us to hold onto it to establish, exercise or defend legal claims; or
- you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Data portability. This enables you to request that we transfer certain of your Personal Data to you or your chosen third party in a structured, commonly used, machine-readable format.
Withdraw consent. This enables you to withdraw your consent at any time where we are relying on consent to process your Personal Data. Please note that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Not be subject to automated decision-making. You have a right not to be subject to a decision based solely on automated data processing, including profiling, where the decision has a legal or other significant affect, except where:
- you provide explicit consent;
- the automated data processing and decision-making is necessary for the performance of a contract with you (the data subject);
- an applicable law that also required measures to protect your rights authorizes the automated data processing and decision-making.
Be notified of a data security breach. In case of a Personal Data breach, which is likely to result in a high risk to your rights, we will notify you of the breach without undue delay.
Complain to data protection regulator. If you are unhappy with how we process your Personal Data, we ask that you contact us first using the details below so that we have the chance to put it right. However, you also have the right at any time to make a complaint directly to a local Data Protection Authority* (where applicable), court or other administrative body entrusted with enforcement of data rights; Finnish Data Protection Authority, or Information Commissioner’s Office (ICO) in the United Kingdom.

You can exercise any of these rights at any time by contacting us at support@masterenglish.com. You can also use the Cookie Banner to give or withdraw your consent to or disable our processing of your Cookie Data.

We respond to all legitimate requests within one (1) month or less where such is specifically prescribed by the applicable law**. Occasionally it could take us longer than a month or other period prescribed by the applicable law** if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Changes to Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated on May 22, 2025. It may change and, if it does, those changes will be posted on this page and notified to you either by push notification, or via email, or when you next start the App or log into your account. The new notice may be displayed on-screen, and you may be required to read and acknowledge the changes to continue your use of the App or the Service.

11. For California residents

Personal Data is collected and used as specified in sections 2, 3, 4 and 5. Sections 2, 3, 4 and 5 explain what type of Personal Data we collect, how we collect it, how we use your Personal Data, and with which third parties we disclose your Personal Data. Master English does not "sell" your Personal Data to third parties in the conventional sense of the term. However, we may share your advertising ID and hashed email address (in an encrypted way) with our third-party advertising platforms to deliver targeted and personalized advertising and to monitor advertising effectiveness. Visiting users have the right to deny this advertising based on their profile or to withdraw consent by disabling "Preference/Customize Cookies" in the website's Cookie Banner settings. Registered customers can manage their advertising settings directly in the social media services they use. Customers may also limit advertising tracking on their device by resetting their advertising identifiers and opting out of interest-based ads (Android) or enabling Limit Ad Tracking (iOS).

* List of local Data Protection Authorities (where applicable) here.

** The response time to legitimate requests in Mexico is twenty (20) days. In Brazil is fifteen (15) days. In Chile is two (2) business days. In Costa Rica, Uruguay, Argentina is five (5) business days.

Updates

2025-09-30:

Updated the list of marketing providers, service providers and privacy contact email.