PRIVACY POLICY
Last Updated March 12, 2025
1 Who we are
1.1 Voxy EnGen PBC (EnGen, we, or us) welcomes you to www.getengen.com and any and all platforms, applications or mobile applications offered by Voxy EnGen PBC (the Site). This Privacy Policy describes how EnGen collects and receives information about you through the Site and when contracting with corporate customers or providing our English language training and teaching services to end users (the Services) and through EnGen’s businesses, including offline and how we use and share your personal data.
1.2 EnGen is committed to protecting your privacy. We want to maintain a transparent relationship with you, and let you know how we collect and securely process any personal data we collect or that you may provide us with. We will process your personal data in accordance with applicable personal data protection laws.
1.3 In this Privacy Policy we refer to employees of corporate customers who we liaise with in relation to the corporate contract as B2B Contacts and individuals who utilize the Services or access the Site as Users. Unless otherwise stated, all sections of this Privacy Policy are applicable to B2B Contacts and Users.
1.4 This Privacy Policy exists in English and other translations. In the event of inconsistencies between versions, the English version will prevail.
1.5 This Privacy Policy covers our use of your personal data when:
1.5.1 you enquire about and/or you (or your employer) enters into a corporate contract with us for the Services if you are a B2B Contact;
1.5.2 you register for an account with us and use our Site and Services if you are a User;
1.5.3 when you get in touch with us including via our Site contact form, by email, social media or by phone (if you are a B2B Contact or User);
1.5.4 you provide your personal data to EnGen offline. EnGen also may provide paper copies of the Privacy Policy when it collects information from you offline; and
1.5.5 we collect personal data through cookies and similar technologies when you browse the Site.
1.6 Please also see:
1.6.1 Your Terms of Use (if you are a User) for information relating to the contractual relationship between you and us in respect of your use of the Services and/or Site;
1.6.2 Your corporate agreement (if you are a B2B Contact) for information relating to the contractual relationship between our corporate customer and EnGen in respect of the Services; and
1.6.3 Our Cookie Policy for information relating to our use of cookies and similar technologies on this Site.
2 What We Collect and How We Use Personal Data
2.1 We will collect and use your personal data when you enquire about and/or enter into a corporate contract with us, register for an account with us and use our Site and Services, and when you get in touch with us including via our Site contact form, by email, social media or by phone and from cookies as described in the Cookie Policy.
2.2 If you are a User, EnGen may also be provided with your personal data by our corporate customers when they sign up to our Services (or personal data may be provided by our channel partners) in order to enable you to register an account and use our Services. Our corporate customers and channel partners will only share your personal data with us if they have previously informed you about this data sharing (e.g. your employer will inform you they will share certain personal data with us (such as name, email address, role) to enable you to register and sign up to use the Services).
2.3 The table below sets out how we collect your personal data, the types of personal data and how this personal data is used.
If personal data is required to enter into a contract with you or otherwise provide Services to you we may be unable to enter the contract or provide Services if you fail to provide the requested personal data. We will inform you if this is the case.
EnGen may automatically receive and record non-personal information on our server logs from your browser as well as through other analysis of the Site.
3 Our legal basis for using your personal data
3.1 We rely on the following lawful bases under data protection law (where applicable) for our use of your personal data:
3.1.1 Consent: you have given your consent to the processing;
3.1.2 Performance of a contract: it is necessary for the performance of and compliance with your contract with us or in order to take steps prior to entering into that contract;
3.1.3 Legal or Regulatory Obligation: we need to process your personal data in order to comply with a legal or regulatory obligation; or
3.1.4 Legitimate Interests: it is necessary for our legitimate interests (or those of a third party). Please see section When do we have legitimate interests? below for more information.
3.2 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4 When do we have legitimate interests?
4.1 We use your personal data where this is necessary for our legitimate interests (or those of a third party). This includes where use of your personal data is necessary to:
4.1.1 Ensure effective administration and management of our Site;
4.1.2 Administer our operations and business in an efficient and effective way;
4.1.3 Manage and administer our Services, Site, content, activities and corporate customer arrangements;
4.1.4 Provide and administer accounts on our Site for Users;
4.1.5 Understand how individuals use our Site and Services;
4.1.6 Understand and respond to queries, complaints and feedback;
4.1.7 Research and analyse the Services our Users and corporate customers want;
4.1.8 Send direct marketing to B2B Contacts and Users;
4.1.9 Improve and develop our Services;
4.1.10 Maintain a public profile;
4.1.11 Transfer personal data in relation to an actual or proposed sale, transfer or re-organisation of all or part of our business and the acquisition of the business;
4.1.12 Ensure network and information security; and
4.1.13 Enforce our legal rights and manage any dispute and legal claims and take legal or other professional advice.
5 Legal requirements
5.1 Your personal data may be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim. We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
6 Where your information will be held
6.1 Personal data collected by EnGen will be stored and processed in the United States in accordance with the laws of the United States. If you submit your personal data directly to EnGen online or offline (e.g. when signing up for an account if you are a User), you acknowledge that you are providing your personal data to EnGen in the United States.
6.2 Depending on a B2B Contact or User’s location, data transfers may involve transferring personal data outside of that B2B Contact or User’s location.
6.3 If you are located in the UK or European Economic Area, we may transfer your personal data to locations outside of the UK and European Economic area. However, to ensure your personal data is protected in accordance with EU and UK data protection law we will only transfer data outside the UK and European Economic Area where appropriate safeguards as required by applicable data protection law are in place. This includes where a jurisdiction has been deemed adequate by the EU Commission or, where there is no adequacy decision, by putting in place Standard Contractual Clauses. Please contact us at support@getengen.com if you would like further information on the specific safeguards used by us when transferring your personal data.
7 The Rights of Users
7.1 Users may exercise certain rights regarding their personal data under applicable data protection law. In particular, Users may have the following rights:
7.1.1 Withdraw consent at any time. The right to withdraw consent where you have previously given their consent to the processing of personal data.
7.1.2 Object to processing of personal data. The right to object to the processing of personal data if the processing is carried out on a legal basis other than consent.
7.1.3 Access Personal Data. The right to learn if personal data is being processed, obtain disclosure regarding certain aspects of the processing and obtain a copy of the personal data undergoing processing.
7.1.4 Verify and seek rectification. The right to verify the accuracy of personal data and ask for it to be updated or corrected.
7.1.5 Restrict the processing of personal data. The right, under certain circumstances, to restrict the processing of personal data.
7.1.6 Have Personal Data deleted or otherwise removed. The right, under certain circumstances, to obtain the erasure of their personal data.
7.1.7 Portability. The right to receive personal data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the personal data is processed by automated means and that the processing is based on consent, on a contract which the User is part of or on pre-contractual obligations thereof.
7.1.8 Lodge a complaint. You may also have a right to lodge a complaint with a supervisory or regulatory authority. In particular if you are an EEA or UK resident you may lodge a complaint with the supervisory authority in the UK or Member State in the European Union where you are habitually resident, where you work or where an alleged infringement of data protection legislation has taken place.
7.2 Please contact us at support@getengen.com if you would like to exercise any of the above rights.
8 Retention of personal data
8.1 Personal data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
8.1.1 Personal data collected for purposes related to the performance of a contract shall be retained until such contract has been fully performed and for the relevant statutory limitation period following the end of that contract.
8.1.2 Personal data collected for the purposes of legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this Privacy Policy.
8.2 The criteria we use to determine the retention period is as follows:
8.2.1 the length of time that you are a User of the Site and Services;
8.2.2 the duration of your contract with us;
8.2.3 whether there are contractual or legal obligations that exist that require us to retain the data for a period of time;
8.2.4 whether there is an ongoing legal claim that relates to your relationship with us; and
8.2.5 whether any applicable law, statute, or regulation allows for a specific retention period.
8.3 We may use personal data to generate aggregated and anonymised information to assist in our planning, development and improvement of products and Services. This information will cease to be personal data once it is made anonymous and aggregated and may be retained for longer than the retention periods set out above.
9 Direct Marketing
9.1 If you are a B2B Contact, EnGen may send direct marketing to you (in relation to marketing aimed at your employer) by email. B2B Contacts can opt-out of receiving these communications at any time.
9.2 If you are a User, EnGen may send direct marketing:
9.2.1 relating to EnGen products and services; and/or
9.2.2 relating to identified third party products or services that may be of interest.
9.3 If you do not want us to use your personal data for the purposes of direct marketing you can withdraw your consent at any time by contacting support@getengen.com. Please note that such requests may take up to ten (10) days to become effective.
9.4 Please note that if you choose not to consent to direct marketing or withdraw your consent to direct marketing we will still communicate with you in relation to any contract you have with us and other Service related messages. For example, messages relating to Service downtime or confirmation of training bookings and communications relating to your contract with us, or messages regarding activation, reset password and login access. You may not opt out of receiving communications regarding your dealings with EnGen or the Site, content, Services or technical information about the Site.
10 Information Sharing with Third Parties
10.1 Your personal data will be processed by our employees and contractors.
10.2 There are also certain circumstances where we will transfer your personal data to third parties. These include:
10.2.1 Group companies – so we can provide the best service across our group. We also share your personal data within our group for management forecasting and financial planning purposes – although this would generally be aggregated data where no individual is identifiable.
10.2.2 Corporate customers – EnGen will share your personal data including name and details of training attended and certifications completed with the corporate customer that enabled your account. This is the corporate customer whose activation code you used when signing up for an account on our Site to use our Services and would generally be your employer or the university or other educational institution you attend. The information shared with corporate customers includes information about how many Users have signed up for our Services on the corporate account and usage/activity of those Users. Corporate customers (e.g. your employer or your university) will act as an independent data controller – please see the relevant corporate customer’s privacy policy for details on how they will use and process your personal data;
10.2.3 Channel Partners – EnGen will share your personal data with the relevant Channel Partner. Our Channel Partners act as an intermediary with some of our corporate customers. We will share personal data with the relevant Channel Partners to enable that Channel Partner to administer the arrangement with a specific corporate customer. This includes your personal data collected through use of the Site and Services.
10.2.4 Service providers – Third parties may process your personal data on our instructions. These include IT suppliers (including website hosting, software and app providers), cloud hosting providers, order fulfilment, payment processing, customer service, data analytics providers, debt agencies, professional advisors, marketing agencies, database providers, backup and disaster recovery specialists and email providers.
Our suppliers and service providers will be required to meet appropriate standards on processing information and security when processing your personal data. The information we provide them, including your information, will only be processed in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this Privacy Policy.
Please see the table below for details of some of our key service providers.
10.3 Your personal data may be transferred to other third party organisations in certain scenarios, such as:
10.3.1 If we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
10.3.2 If we are reorganised or sold, or in the event of a merger, joint venture, assignment, transfer or disposition of all or any portion of EnGen’s business or operations (including without limitation in connection with bankruptcy or any similar proceedings) information may be transferred to a buyer who can continue to provide services to you;
10.3.3 If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police e.g. in order to assist fraud protection and minimise credit risk;
10.3.4 In response to a subpoena, legal order or official request, when we believe you have acted in violation of our contract with you, to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats, or when we believe that doing so may protect your safety or the safety of EnGen or others, or as otherwise permitted or required by law; or
10.3.5 If we are exercising or defending a legal claim your information may be transferred as required in connection with defending such claim.
10.4 Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data. For example, we may take personally identifiable information and de-identify it and share it in a de-identified or aggregated form with advertisers, business partners, and/or third parties in order to analyse Site usage, perform services on our Site or others’ Site, improve our services, improve our user experience, or for similar purposes. We will not re-identify such data and we will ask our contracting parties to agree to keep the data in its de-identified form.
11 Children
11.1 Our Site is not directed towards children and we do not knowingly collect personal information from children. Please do not use our Services, register for emails or direct marketing or otherwise submit any personal information to us:
(a) if you are a resident of Malaysia, if you are younger than 13 years old; or
(b) if you are a resident of any other country, if you are younger than 15 years old.
11.2 If you are a minor in your place of residence, when you visit, browse, use, or submit personal information to the Site, you represent that you have the permission of a parent or guardian to do so and who agrees to these Terms on your behalf. If you are a parent or guardian and believe EnGen may have inadvertently collected personal information from your child, please notify EnGen immediately by sending a message detailing the basis of your belief and your request to: Voxy EnGen PBC 7200 Wisconsin Avenue Suite 500, Bethesda, MD 20814 or support@getengen.com.
12 Protection of Personal Information
12.1 EnGen uses reasonable administrative, physical and electronic security measures to protect against the loss, misuse and alteration of personal information. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of EnGen to intercept or access transmissions or private communications unlawfully. While we strive to protect personal information, neither EnGen nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk.
13 Updating your Information
13.1 You are responsible for keeping your information current. You may update your information by contacting us at support@getengen.com or editing your account information. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to EnGen’s internal reporting, processing and retention policies and all applicable legal obligations.
14 Links
14.1 You may have the opportunity to follow links on the Site to other sites that may be of interest to you. EnGen endeavors to only link to reputable organizations. Because other sites may not be hosted or controlled by EnGen, we are not responsible for the privacy practices of those sites or the content provided thereon. Therefore, the privacy policies with respect to other sites may differ from those applicable to the Site. We encourage you to review the privacy policies of each other site. This Privacy Policy only applies to information collected and maintained by EnGen.
15 Changes to the Privacy Policy
15.1 Should the Privacy Policy be revised, EnGen will post the changes on the Site which will be effective immediately upon posting. You can determine when the Privacy Policy was last revised by referring to the “Last Revised” legend at the top of this page.
15.2 If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why we use personal data, we will notify you by way of a prominent notice on our website or, if we have your email address, by email. Where required by applicable law, any material changes to the terms of the Privacy Policy will apply only to information collected thereafter, unless you provide consent.
16 Questions?
16.1 If you have any questions or concerns regarding this Privacy Policy, please contact us at:
16.1.1 Voxy EnGen PBC 7200 Wisconsin Ave Suite 500, Bethesda, MD, 20814
16.1.2 support@getengen.com
17 Notice of Privacy Rights of California Residents
17.1 We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. Due to EnGen’s size/data collection, EnGen is not currently required to comply with the CCPA, but we do make an effort to do so.
17.2 If you are a California resident and have provided personal information to EnGen, you are entitled by law to request certain information regarding any disclosure that may have been made by EnGen to third parties of personal information for their direct marketing purposes. To make such a request, send a message to support@getengen.com.
17.3 The message should specify that you seek your “California Customer Choice Privacy Notice.” Please allow thirty (30) days for a response. EnGen is required to respond to only one request per customer each year, and is not required to respond to requests made by means other than through the above e-mail address.
17.4 We will not share your personal information with third parties for their direct marketing purposes if you request that we do not do so. You may make such a request by sending us a message at support@getengen.com.
17.5 When contacting us, please indicate your name, address, email address, and what personal information you do not want us to share with third parties for their direct marketing purposes. Please note that there is no charge for controlling the sharing of your personal information or for processing this request.
17.6 Non-discrimination
17.6.1 We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
(a) Deny you goods or services.
(b) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
(c) Provide you a different level or quality of goods or services.
(d) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
17.6.2 However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. EnGen does not currently offer any incentive programs related to personal information.
18 Data Privacy Framework Policy Statement of Voxy EnGen PBC
Voxy EnGen PBC (“EnGen”), and its wholly-owned subsidiaries, complies with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF), including the Supplemental Principles, as set forth by the U.S. Department of Commerce (collectively, the “Principles”). EnGen has certified that it adheres to the Principles with respect to its services and the collection, use, and retention of certain Personal Data (as defined below) transferred from the European Union (“EU”), the UK, and Switzerland to EnGen in the United States (“US”). This Policy sets forth the standards under which EnGen will treat such Personal Data. To learn more about the Principles and to view EnGen ’s certifications, please visit: www.dataprivacyframework.gov.
U.S. Federal Trade Commission Jurisdiction
EnGen ’s commitments under the Principles are subject to the jurisdiction and enforcement and investigatory authority of the United States Federal Trade Commission.
Required Disclosure
EnGen may be required to disclose Personal Data to the extent required to meet a legal obligation, including national security or law enforcement obligations and applicable law, rule, order, or regulation.
Definitions
“Data Subject” means the individual to whom any given Personal Data covered by this Policy refers.
“Personal Data” means information relating to an identified or identifiable natural person residing in the EU or Switzerland. If the information has been irreversibly stripped of all identifiers such that an individual cannot be identified or re-identified, it is not Personal Data.
“Sensitive Personal Data” means Personal Data regarding any of the following:
● Racial or ethnic origin;
● Political opinions;
● Religious or philosophical beliefs;
● Trade union membership;
● Genetic data, biometric data processed for the purpose of uniquely identifying a natural person;
● Health or medical condition; or
● Sex life or sexual orientation.
EnGen does not collect any Sensitive Personal Data.
Scope
EnGen provides digital language and teaching services.
Our compliance with the Data Privacy Framework applies to Personal Data that we process as a data controller as described in our privacy policy.
This Policy applies to the collection, use, and disclosure in the U.S. of Personal Data transferred from the EU, the UK, or Switzerland to EnGen in the U.S. of: (i) internet end users who visit our websites, applications, and services (with respect to which EnGen generally serves as a language learning platform, (ii) internet end users of EnGen ’s own websites and applications
Data Processed
EnGen collects, uses, and discloses Personal Data of users of EnGen’s own websites and applications, as well as contact information associated with our business customers — such data is processed in accordance with EnGen ‘s Privacy Statement
Purposes of Data Processing; Disclosure to Third Parties
EnGen processes data that is transferred from the EU, the UK, or Switzerland to EnGen in the U.S. for purposes of: providing, maintaining, protecting, developing, and improving the solutions it offers to its customers and supporting EnGen ’s internal business operations (e.g. billing).
EnGen may use from time to time a limited number of third-party service providers, contractors, and other businesses to assist EnGen in providing its solutions to customers or in meeting internal business operation needs. These third-parties may access, process, or store Personal Data in the course of performing their duties to EnGen EnGen maintains contracts with these providers restricting their access, use and disclosure of Personal Data in compliance with our obligations under the Principles.
Accountability for Onward Transfer
In the event EnGen discloses Personal Data covered by this Policy to a non-agent third party, it will do so consistent with any notice provided to Data Subjects and any choice they have exercised regarding processing and disclosure. EnGen will only disclose Personal Data to third parties that have given us contractual assurances that they will provide at least the same level of privacy protection as is required by this Policy and the Principles and that they will process Personal Data for limited and specific purposes consistent with any consent provided by the individual. If EnGen has knowledge that a third party to which it has disclosed Personal Data covered by this Policy is processing such Personal Data in a way that is contrary to this Policy and/or the Principles, EnGen will take steps to prevent or stop such processing. EnGen complies with the Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
Security
EnGen has put in place technical and organizational measures to protect Personal Data covered by this Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. These measures take into account the risks involved in the processing, the nature of the Personal Data, and the state of the art and best practices in the industry for security and data protection.
Data Integrity and Purpose Limitation
EnGen will only collect Personal Data covered by this Policy that is relevant for the purposes for which it is to be used, and only use such Personal Data in a way that is compatible with the purposes for which it was collected or subsequently authorized. EnGen will take reasonable steps to ensure that such Personal Data is accurate, complete, current and reliable for its intended use.
Access
Data Subjects have the right to access Personal Data about them that is covered by this Policy and to correct, amend, or delete such Personal Data if they can demonstrate that it is inaccurate or incomplete (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Data Subjects may also provide instructions, including withdrawal of consent they may have given, regarding the processing or disclosure of such data.
Data Subjects should note that before EnGen is able to provide them with any access to information, correct any inaccuracies, or delete your personal data, EnGen may ask the Data Subject to verify the identity and to provide other details to help EnGen to respond to the request. EnGen will contact a Data Subject within 30 days of a request to support@getengen.com
Enforcement; Recourse
Inquiries and complaints relating to EnGen ’s treatment of Personal Data and its compliance with the Principles may be directed to:
support@getengen.com
or
Voxy EnGen PBC
7200 Wisconsin Avenue Suite 500
Bethesda, MD 20814
(929) 565-5358
Attention: Chief Executive Officer
EnGen will respond to any such inquiries or complaints within forty-five (45) days. In the event that EnGen fails to respond or its response is insufficient or does not address the concern, EnGen has registered with American Arbitration Association/International Centre for Dispute Resolution (AAA/ICDP) to provide independent third party dispute resolution at no cost to the complaining party. To contact AAA/ICDP and/or learn more about the company’s dispute resolution services, including instructions for submitting a complaint, please visit: https://go.adr.org/dpf_irm.html
Complaining parties may also, in absence of a resolution by EnGen and AAA/ICDP, seek to engage in binding arbitration through the DPF channel.
EnGen also commits to periodically reviewing and verifying the accuracy of this Policy and the company’s compliance with the Principles, and remedying issues identified. All employees of EnGen that have access to Personal Data covered by this Policy in the U.S. are responsible for conducting themselves in accordance with this Policy. Failure of an EnGen employee to comply with this Policy may result in disciplinary action up to and including termination.