2.1. Personal data collected

Data category	Data items	Usage
Personal data	Name, maiden name, mother’s name, birth place and date, nationality, communication language, ID document name / number / expiry, reason for stay in case of expats, insurance no., mobile, phone, email, official address, temporary address, name and contact information of contact person, work status, education, comments, request for newsletter, how you found us, time of registration.	Student contract Communication Newsletters (after approval)
Course application	Requirements: language to be studied, sponsoring company, course parameters (start, intensity, timetable, type, lesson count, group size) Written placement test: filled-in and evaluated placement test Spoken placement test: when, by which teacher, study goals, spoken level, suggested course level Communication history: which employee was in contact and what has he/she discussed, next to-do, log status	Organize courses Communication
Course data	Course fee, exam fee, joining and exit dates, archived student contract, information to be displayed on student invoice, certificate, student intends to continue studying after the course	Student contract Attendance sheet / certificate of completion Course documentation  (e.g. progress sheet cover page)
Course sessions	Attendees Remarks about student in the progress sheet Video recording of online sessions	Attendance statistics Study costs by students Progress sheet Monitoring
Communication	Course email: sender, recipients, contents, time of sending	Information about courses
Evaluations	Time, archived test, reached score, current level of knowledge, evaluation in words (progress, development needs, motivation)	Measuring progress
Feedback	Filled in feedback form (anonymous by default, optionally by name) about course and teacher	Quality assurance
Certificates	Student certificate numbers, level on certificate, copy of certificate, takeover registration	Certificates
Finance	Student’s name might appear on invoices as the buyer and in the invoiced items together with different IDs assigned to the student Statistics about course fees invoiced Statistics about unpaid invoices	Invoices Managing outstanding receivables

2.2. What do we use the personal data for?

1. Organizing courses (student contract, communication, information, attendance, finance)
2. Monitoring and documenting student development (evaluations, certificates, attendance statistics)
3. Ensuring the quality of the education (course documentation, attendance sheet, progress sheet, group emails)
4. Measuring the quality of our service (attendance sheet, feedback)
5. Collecting and sharing data in order to comply with legal requirements (in case of licensed courses this data includes: application, placement, student contract, progress sheet, attendance sheet, evaluation, feedback and certificate).

2.3. What is the legal basis for collecting the personal data?

We collect student data

1. based on consent by the student or
2. to establish contractual relationship with the student or
3. due to legal obligations or
4. out of legitimate interest.

When students apply for a course, we use the student’s data to assess the level of their knowledge and to organize the courses.

The students’ personal data are necessary for the conclusion of legitimate student contracts. Thus in this case the data are required to establish contractual relationship with the students.

We may share students’ information with our teachers, our school staff, our accountant and subcontractors who are involved in the education in order to be able to provide our service as required by the student contract.

All secondary data processing (as a student feedback request at the end of the course, or advertising courses or creating advertising profiles) is based on the prior consent of the students.

The Adult Education Act defines the extent of the documentation for licensed courses. Therefore, in these courses we have a statutory duty to a) include the statutory data in the student contract, b) it is necessary to conduct a preliminary assessment of the students’ knowledge, c) to ask the students for feedback, d) to send feedback requests, and e) to evaluate the students’ progress and f) to prepare certificates at the end of the course.

2.4. Whom do we share the personal data with?

We share personal data with the school staff to organize courses.

We share the course information with the teachers who teach the course lessons.

In case of company or subsidized courses, we share information about progress and development with the company or the sponsor, including placement results, progress sheets, attendance statistics, evaluations, feedback and video recordings of online sessions.

We share financial data with our accountant.

We might share data with government agencies at their request, if the request is legally valid.

All individuals and organizations who participate in providing our services and have access to personal information stored by us are subject to a strict contract to ensure the protection of personal data and compliance with data protection laws. From time to time we commission an independent auditor to check whether our service providers meet our expectations.

2.5. How long do we store the personal data?

Personal data related to licensed courses are stored for 6 calendar years after the end of the calendar year when the course finished. The same applies to personal data on financial documents.

Personal data related to non-licensed courses are stored for 3 calendar years after the end of the calendar year when the course finished, with the exception of the personal data on financial documents.

Video recordings of online sessions are stored for up to 3 days.

Personal data not related to courses (e.g. CV and diploma copies) are stored for 3 calendar years after the end of the contract concluded with the student.

After that, personal information will be deleted or converted to prevent personalization (anonymization).

3.1. Personal data collected

Data category	Data items	Usage
Personal data	Name, maiden name,  mother’s name, date and place of birth, gender, nationality, communication language, mobile, email, official address, bank account, insurance no., tax no., photo, employment status, seller invoicing teacher’s lessons, base hourly rates for various tasks, languages taught, comments	Teacher contract Communication Payroll / settlement Invoicing
Teacher documents	Archived diploma, profile, copy of contracts Payroll (employees)	HR Finance
Courses	Which course is taught by the teacher using which rate Teacher contract for the course	Attendance sheet Room allocation Teacher invoices Financial reports Teacher contract
Course sessions	Teaching teacher and rate	Teacher invoices Financial reports Time sheet Certificate of completion Calendar (when available, current location) Room allocation Time sheet of business customers On invoices sent to business customers Replacement requests Progress sheets
Student application	Teacher doing spoken placement	Result of spoken placement (by the teacher) Teacher’s calendar Teacher’s settlement, invoices, payroll
Lesson observations	Observing teacher, date, rate Observed teacher, course Observation result: filled-in questionnaire, strength, need for development, objectives Observation date, place	Part of observing and observed teacher’s data Result of observation Appears in observing teacher’s calendar Part of observing teacher’s settlement, invoice, payroll
Feedback	Filled-in questionnaire on course and teacher	Quality assurance
Other tasks	Tasks performed besides teaching: who has done what with which rate (e.g. translation, interpretation)	Might appear in the teacher’s calendar In teacher’s settlement, invoice, payroll
Invoices	Teacher invoice, copy of the original Number of lessons invoiced by course	Bookkeeping Receivables (not issued invoices, still due)
Advanced studies, borrowing books	Study participants Which book was borrowed by whom, when is it due back	Advanced studies Borrowed books

3.2. What do we use the personal data for?

1. Establishing legal relationship with the teacher (employee / subcontractor) and for HR processes and financial settlements (contract, invoicing, receivables, communication, hourly rates)
2. Accounting for business customers and for communication with them (courses are identified on the customers’ invoices by naming the teacher, business customer know the teacher’s contact information)
3. Organizing courses (teacher calendar, rates, room allocation, replacement requests)
4. Ensuring the quality of the education (course documentation, attendance sheet, progress sheet, teacher training)
5. Measuring the quality of our service (attendance sheet, feedback)
6. Collecting and sharing data in order to comply with legal requirements (in case of licensed courses this data includes: teacher contract, CV, copy of diplomas, progress sheet).

3.3. What is the legal basis for collecting the personal data?

We collect teacher data

1. based on consent by the teacher or
2. to establish contractual relationship with the teacher or
3. due to legal obligations or
4. out of legitimate interest.

Teachers will submit their CVs and diplomas to support their experience when they apply for teaching at the school. They hereby contribute to the storage of this data.

The teachers’ personal data are necessary for the conclusion of legitimate teacher contracts. Thus in this case the data are required to establish contractual relationship with the teachers.

We may share teachers’ data with school staff, our accountant and subcontractors who are involved in the education in order to be able to provide our service as required by the teachers’ contract. Their name and contact information will be shared with business customers where they teach to enable direct communication between them (e.g. lesson cancellation).

All secondary data processing (as emails about school events or courses they can apply to) is based on the prior consent of the teacher.

The Adult Education Act defines the extent of the documentation for licensed courses. Therefore, in these courses we have a statutory duty to a) include the statutory data in the teachers’ contract, b) to make and store a copy of the teachers’ CVs and diplomas, c) to run progress and attendance sheets, d) to ask for students’ feedback on teachers, and e) to assess the quality of their work via lesson observations.

3.4. Whom do we share the personal data with?

We share personal data with the school staff to organize courses.

We share course information between teachers who teach the same course together to enable communication between them.

In case of company or subsidized courses, we share the teachers’ contact information and the course administration they run with the company or the sponsor, including placement results, progress sheets, attendance statistics, evaluations and feedback.

We share financial data with our accountant.

We might share data with government agencies at their request, if the request is legally valid.

All individuals and organizations who participate in providing our services and have access to personal information stored by us are subject to a strict contract to ensure the protection of personal data and compliance with data protection laws. From time to time we commission an independent auditor to check whether our service providers meet our expectations.

3.5. How long do we store the personal data?

Personal data related to licensed courses are stored for 6 calendar years after the end of the calendar year when the course finished. The same applies to personal data on financial documents. After that, personal information will be deleted or converted to prevent personalization (anonymization).

Personal data related to non-licensed courses are stored for 3 calendar years after the end of the calendar year when the course finished, with the exception of the personal data on financial documents. After that, personal information will be deleted or converted to prevent personalization (anonymization).

Personal data not related to courses (e.g. contact information, CV and diploma copies) are note deleted automatically, only at the request of the teacher, since the teacher might teach at our school anytime later.

Personal data collected

Data category	Data items	Usage
Personal data	Name, phone, email, communication history	Communication

What do we use the personal data for?

In order to stay in contact with our business customers.

What is the legal basis for collecting the personal data?

We collect the personal data of our customers out of legitimate interest.

Whom do we share the personal data with?

We share the name and contact details of the business contact with other staff members of the language school and with the teachers who teach at the customer where the contact works.

All individuals and organizations who participate in providing our services and have access to personal information stored by us are subject to a strict contract to ensure the protection of personal data and compliance with data protection laws. From time to time we commission an independent auditor to check whether our service providers meet our expectations.

How long do we store the personal data?

We do not delete personal data from our business contacts at our own initiative.

The Internet is not a secure medium, therefore the security of information sent via online communication technology (such as e-mail) can not be guaranteed. However, from the moment when we have received the personal data, it is safe and managed in accordance with data protection regulations.

In order to ensure the safety of the data:

1. All our contracts with individuals (work contract, student contract, company contract) who have access to personal information stored by us state that the individual has to comply with our privacy policy.
2. We minimize the amount of documentation printed during the language courses. Irrelevant documents will be destroyed. Whatever we can we store electronically, paper-based documents are kept locked so that only school staff can access it and only those members who are in charge of it.
3. Office computers are located in a room that can be locked, each computer is password protected. Client computers do not store data, data is only stored on the network. Data stored on the network is backed up daily. Only the school staff have access to these computers, all members have their own user account.
4. The electronic storage and handling of personal data is done in an online cloud-based system that complies with the data protection rules. You will need to sign in to use the system, it uses data encryption while transferring the data, secures your data with a secure software and hardware infrastructure, and makes backups of the data on a daily basis at least.

It is possible to check what personal data we store about you, to modify the data, to limit it or to delete it.

In order to do so:

1. send us a request by post to Babilon Nyelvstúdió Kft., Károly krt. 3/a., 1075 Budapest, Hungary or
2. call us by phone at +36 1 269 5531 or
3. send us an email to privacy@babilon.net with your request.

If you are not satisfied with how your request is handled, you have the right to file a complaint at the following address:
Nemzeti Adatvédelmi és Információszabadság Hatóság
http://naih.hu/uegyfelszolgalat,–kapcsolat.html

Should there be changes in our privacy practices you will find a new version of this statement at http://www.babilon-nyelvstudio.hu/dataprivacy/ and we will highlight the changes. We will also ask for your approval for the changes if that is required by the law.

Change log:

2020-10-13 Regulations related to video recording of online sessions