General

1. Lstn Ltd (company number 10451644) which operates and manages BeyondWords.io (“we or “us”) takes the privacy of your information very seriously. This Privacy Policy (“Policy”) is designed to tell you (the user of our Services or visitors to our Site) about our practices regarding the collection, use and disclosure of personal data which may be provided to us via our websites, associated apps and other digital products we provide or collected through other means such as online forms, email, or telephone communication.
2. We are the controller and are responsible for your personal data, other than in relation to the payment information referred to in Section 6.1 (‘Sharing your information’).
3. This Policy applies to personal data provided by our users, whether they are a customer of our services or otherwise. In this Policy “you refers to any individual whose personal data we hold or process (other than our staff).
4. In this Policy references to the “Site” are references to any website, app or other means by which you provide personal data to us us or access our services.
5. When we refer to “Applicable Data Protection Law” in this Policy, we mean:
   1. to the extent UK GDPR applies to our processing of your personal data, the law of the United Kingdom or a part of the United Kingdom; and
   2. to the extent EU GDPR applies to our processing of your personal data, the law of the European Union or any member state of the European Union to which we are subject,

which in either case relates to the protection of personal data. (“EU GDPR” means the General Data Protection Regulation ((EU) 2016/679) and “UK GDPR” has the meaning given in the UK Data Protection Act 2018.)

Personal data we collect

1. We may collect and process the following types of personal data (information that can be uniquely identified with you) about you:

   #	Type of Personal Data	Description
   1.	Service Information	Information you provide when seeking information about our services (e.g. through a web chat or online form), information provided when signing up to our services (including log-in details and personal contact information) and other information we require in order to provide our services
   2.	Payment Information	Information provided relating to payment, but please note that credit or debit card information may be supplied directly to a third party payment processor who will process the data in accordance with their own privacy notices or policies (see below)
   3.	Communication Information	A record and details of any correspondence or communication between you and us or relating to any complaint submitted to us
   4.	Technical Information	Details of your visits to the Site, the resources and pages that you access (including listening and analytics data generated through the use of our player on our customers’ websites) and any searches you make
   5.	Marketing Information	Information you provide when you sign-up to our newsletter or ask or agree to receive information relating to our products and services such as your name, telephone number, email address, date of birth and service or product preferences
   6.	Voice Data	In some cases, our customers use our products and services to create custom voices. In these situations, we collect and process personal data of voice actors (e.g. a sound recording of the voice actor’s voice) to create the custom voice.

2. We will not collect any sensitive personal data without your prior consent. By sensitive personal data we mean data which falls within certain ‘special categories’ which are defined in the GDPR (e.g. health data) and which require additional protection and consent measures.
3. Generally we will collect personal data directly, but we may obtain data from third parties from time to time. If we do obtain your personal data from a third party your privacy rights under this Policy are not affected and you are still able to exercise the rights contained within this Policy.
4. You do not have to supply any personal information to us but our services may not be operable without providing data to us.
5. You may withdraw our authority to process your personal data (or request that we restrict our processing – see Section 9 (‘Your privacy rights’)) at any time but we may need to withhold some personal data for legal or other reasons (see below).

Cookies and IP Address

1. A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our Site.
2. On our Site, we use cookies to track users progress, allowing us to make improvements based on usage data. We also use cookies if you log in to one of our online services to enable you to remain logged in to that service. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service.
3. Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browse settings you should go to your advanced preferences.
4. We are required to obtain your consent to use cookies. We will obtain this consent with a toolbar which appears when you first visit the Site.
5. If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Site. However, you will not be able to make full use of our online services.
6. An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.
7. We may also access the IP addresses of end users who engage with the content you produce through your use of our service (e.g. when a button has been embedded on your website using a plug-in provided by BeyondWords, and a visitor to your website clicks on the button in question to listen to the audio).

How we process your personal data and basis of processing

1. Personal data we hold about you will be processed either because:
   1. the processing is necessary in pursuit of a legitimate interest. A “legitimate interest” in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security (“Legitimate Interest”);
   2. you have consented to the processing for the specific purposes described in this Policy (“Consent”); or
   3. the processing is necessary in order for us to comply with our obligations under a contract between you and us (“Necessary for Contract”).
2. The following table maps these bases of processing onto the types of personal data we process. The central column explains how we process those types of personal data.

   #	Type of Personal Data	How we Process the Personal Data	Basis of Processing
   1.	Service Information	When you register or log in to the Site, update your details with us, when you interact with the Site, when you make use of our services and when we need to communicate with you	Necessary for Contract
   2.	Payment Information	When you give us information in order to pay for the use of our services	Necessary for Contract
   3.	Communication Information	When we communicate with you or you communicate with us	Necessary for Contract
   4.	Technical Information	When we administer or protect our business, undertake troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, when we use data analytics to improve the Site, services, marketing, customer relationships and experiences	Legitimate Interests
   5.	Marketing Information	When we promote or market our products or services to you	Consent
   6.	Voice Data	When we provide products and services which include custom voices to our customers.	Consent

Data Retention

1. Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:

   #	Category of personal data	Length of retention
   1.	Records relevant for tax purposes	8 years from the end of the tax year to which the records relate
   2.	Personal data processed in relation to a contract between you and us	7 years from either the end of the contract or the date you last used our services or placed (being the length of time following a breach of contract in which a contract party is entitled to make a legal claim)
   3.	Personal data held on marketing or business development records	3 years from the last date on which you have interacted with us

2. For any category of personal data not specifically defined in this Policy, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data or (if later) the end of the relevant contract, arrangement or interaction with that person.
3. In some circumstances, the retention periods stated in this Policy can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
4. We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
5. If you wish to request that data we hold about you is amended or deleted, please see Section 9 (‘Your privacy rights’) below, which explains your privacy rights.

Sharing your information

1. We do not disclose any personal data you provide to any third parties other than as follows:
   1. we may provide credit and debit card information to our payment processing partner. If we take payment through a payment processing partner (as opposed to direct bank transfer), this information will be supplied to our payment processing partner directly, even if you provide the information while on our Site. Our payment processing partner will be the controller for credit and debit card information.
   2. we may host personal data with third party hosting partners;
   3. we will provide certain personal information to third party service providers that assist us in managing, storing, collecting and analysing the provision and use of our services;
   4. where we use certain third party suppliers including IT technical support providers, website developers, marketing and business development service providers, they may have access to personal data;
   5. where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal data itself) may be transferred to interested third parties;
   6. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
   7. when we need to enforce any terms and conditions or agreements for our services that may apply;
   8. we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected; and
   9. when we need to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
2. Our payment processing partner and other third parties to whom we provide your personal data will have their own privacy policies and notices, but we will take steps to ensure that they are compliant with applicable data protection legislation.
3. Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this Policy.

Email and Other Communications

1. If you have signed up to our services we may from time to time contact you about similar goods or services. We may also contact you with information about our goods and services if you have expressly consented to receive such communications (e.g. by signing up to our newsletter) or if you are a business customer.
2. When we send email and other electronic communications we will comply with Applicable Data Protection Law. In particular we will identify the nature of the message and the sender clearly and you will have an opportunity to opt out of receiving any further communications from us.

Security

1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These measures may include:
   1. protecting our servers by both hardware and software firewalls;
   2. locating our data processing storage facilities in secure locations;
   3. encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
   4. ensuring that all communication with our servers is encrypted through Secure Sockets Layer (SSL), an industry standard encryption method that encrypts data between your computer and our servers so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
   5. when necessary, disposing of or deleting your data so it is done so securely; and
   6. regularly backing up and encrypting all data we hold.
2. We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.
3. As you will be aware, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your data transmitted to the Site. Once we have received your information, we will use the procedures and security features referred to in this Policy to try to prevent unauthorised access.

Your privacy rights

1. Applicable Data Protection Law gives you the following rights in respect of personal data we hold about you:

   #	Right	Description
   1.	The right to be informed	You have a right to know about our personal data protection and data processing activities, details of which are contained in this Policy
   2.	The right of access	You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below
   3.	The right to correction	Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month
   4.	The right to restrict processing	You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data
   5.	The right to data portability	You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible)
   6.	The right to object	Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted. You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing, unless we have overriding legitimate grounds
   7.	Rights with respect to automated decision-making and profiling	You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent
   8.	Right to withdraw consent	If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above)

2. All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to [email protected].
3. We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Data Breaches

1. If personal data we hold about you is subject to a personal data breach or unauthorised disclosure or access, we will report this as required by Applicable Data Protection Law.
2. If a breach is likely to result in a high risk to your rights and freedoms, we will notify you as required by Applicable Data Protection Law.

Other websites

1. Our Site may contain links and references to other websites. Please be aware that our Policy does not apply to those websites.
2. We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
3. In addition, if you came to this Site via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

Transferring your information outside Europe and the UK

1. As part of the services provided to you the information you provide to us may be transferred to, processed and stored at, countries or international organisations outside of the EEA and UK.
2. We have customers who are outside of the EEA and UK and in those circumstances personal data may be transferred outside of the EEA and UK.
3. We will not transfer the personal data of EEA and UK customers in a systematic way outside the EEA and UK but there may be circumstances in which certain personal information is transferred outside of the EEA and UK, in particular:
   1. If you use our Site while you are outside the EEA and UK, your information may be transferred outside the EEA and UK in order to provide you with our services;
   2. We may communicate with individuals or organisations outside of the EEA and UK in providing goods and services, those communications may include personal information (such as contact information) for example you may be outside of the EEA and UK when we communicate with you; and
   3. From time to time your information may be stored in devices which are used by our staff outside of the EEA and UK (but staff will be subject to our cyber-security policies).
4. If we transfer your information outside of the EEA and UK, and the third country or international organisation in question has not been deemed by the EU Commission and the Information Commissioner’s Office (“ICO”) to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this Policy. If you would like to obtain details of the safeguards we have put in place then please contact us at: [email protected].
5. By submitting your personal information to us you agree to the transfer, storing or processing of your information outside the EEA and UK in the manner described above.

Notification of changes to the contents of this policy

1. We will post details of any changes to this Policy on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.

Contact us

1. If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: [email protected].
2. If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the ICO by visiting https://www.ico.org.uk/ for further assistance.