PRIVACY POLICY

Last updated: September 6, 2026
This Privacy Policy sets out how Top English collects, uses, stores, and protects the personal data of users of its website.
By using the website, completing contact forms, or providing personal data, the user confirms that they have read and understood this Privacy Policy.

1. Personal Data ControllerThe personal data controller is:
SC GlobalConect SRL
Registered address: MD-2012, 45 Mitropolit Gavriil Bănulescu-Bodoni Street, Chișinău, Moldova
Email: t_russu@topenglish.md
For the purposes of this Policy, GlobalConect SRL is hereinafter referred to as the “Controller”.

2. What Data We May CollectDepending on how users interact with the website, we may process the following data:
  • First and last name;
  • Phone number;
  • Email address;
  • Other information voluntarily provided by the user in a message or form;
  • Technical data relating to website visits, including IP address, device type, browser, operating system, referral source, and information about interactions with the website;
  • Website usage data, including pages viewed and user actions.
We do not request special categories of personal data through the website unless expressly required by law.

3. Purposes of Personal Data ProcessingPersonal data may be used for the following purposes:
  • Processing user applications and inquiries;
  • Contacting users regarding the educational programs they are interested in;
  • Providing information about English language courses;
  • Scheduling consultations or enrolling users in courses;
  • Responding to user questions;
  • Facilitating further communication via WhatsApp;
  • Ensuring the proper functioning and security of the website;
  • Analyzing website traffic and performance;
  • Improving the website’s content, structure, and functionality;
  • Evaluating the effectiveness of advertising campaigns.
Personal data will not be used for purposes incompatible with those listed above without an appropriate legal basis.

4. Processing Inquiries Through WhatsAppThe website may contain buttons and forms that allow users to contact Top English through WhatsApp.
When users access WhatsApp, they leave the Top English website. Any subsequent processing of their data is carried out in accordance with the terms and privacy policy of the respective service.
Top English does not control the processing of data carried out by WhatsApp after users access that service.

5. Analytics and Advertising ToolsThird-party services may be used to analyze website traffic and evaluate the effectiveness of advertising campaigns, including:
  • Google Analytics;
  • Meta Pixel and other Meta tools.
These services may collect technical information about website visits, user actions, and interactions with advertising materials.
Such information may be used for statistical analysis, website optimization, advertising performance measurement, and the creation of advertising audiences, in accordance with the settings of the respective services and applicable law.

6. CookiesThe website may use cookies and similar technologies for the following purposes:
  • Ensuring the proper functioning of the website;
  • Saving technical settings;
  • Analyzing website traffic;
  • Evaluating the effectiveness of advertising campaigns;
  • Improving the user experience.
Users can change their cookie settings in their browsers.
Optional cookies and analytics or advertising technologies are used in compliance with applicable legal requirements.

7. Link to a Third-Party Website for Taking a TestThe Top English website may contain a “Find Out Your Level” button that redirects users to a third-party website.
After users are redirected to the third-party website, their personal data is processed by the operator of that website in accordance with its own rules and privacy policy.
Top English is not responsible for the processing of personal data by third-party websites after users are redirected to them.
Before providing personal data on a third-party website, we recommend reviewing its privacy policy.

8. Legal Bases for ProcessingPersonal data is processed on an applicable legal basis established by the legislation of the Republic of Moldova, depending on the specific purpose of processing.
In particular, processing may be carried out:
  • On the basis of the user's consent;
  • To take steps requested by the user before entering into a contract;
  • To fulfill contractual obligations;
  • To comply with legal obligations;
  • On the basis of the Controller's legitimate interests, provided that these do not override the user's rights and freedoms.

9. Disclosure of Personal Data to Third PartiesThe Controller does not sell users' personal data.
Personal data may be disclosed to third parties only when necessary for the operation of the website, processing inquiries, providing relevant services, using integrated services, or complying with legal requirements.
Such third parties may include providers of technical, analytics, advertising, and communication services used by Top English.
These parties receive only the data necessary to perform their respective functions.

10. International Data TransfersSome third-party services used on the website may process data in other countries.
Where personal data is transferred internationally, the Controller takes the measures required under applicable data protection legislation.

11. Data Retention PeriodPersonal data is retained for no longer than necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by law.
The retention period may depend on the nature of the inquiry, the existence of contractual relationships, and legal requirements.

12. Personal Data ProtectionThe Controller implements reasonable technical and organizational measures to protect personal data against:
  • Unauthorized access;
  • Loss;
  • Alteration;
  • Disclosure;
  • Destruction;
  • Other forms of unlawful use.
However, no method of transmitting or storing data over the internet can guarantee absolute security.

13. User RightsUnder applicable legislation, users have the following rights, where provided by law:
  • To obtain information about the processing of their personal data;
  • To access their personal data;
  • To request the correction of inaccurate or incomplete data;
  • To request the deletion of their data;
  • To request the restriction of processing;
  • To object to certain types of processing;
  • To withdraw previously given consent where processing is based on consent;
  • To exercise other rights provided by law.
To exercise their rights, users may contact the Controller at:
**t_russu@topenglish.md**
When submitting a request, users are encouraged to provide their name, contact details, and the subject of their request.

14. Children and MinorsThe Top English website may contain information about educational programs for children and teenagers.
Where the provision of a particular service involves processing the personal data of a minor, such processing is carried out in compliance with the requirements of the legislation of the Republic of Moldova.

15. Changes to the Privacy PolicyThe Controller reserves the right to amend this Privacy Policy in response to changes in legislation, technologies used, or the operation of the website.
The current version of the Policy is always published on this page.
The date of the latest update is indicated at the beginning of the document.

16. Contact DetailsFor questions regarding the processing of personal data, this Privacy Policy, or the exercise of user rights, please contact:
SC GlobalConect SRL
MD-2012, 45 Mitropolit Gavriil Bănulescu-Bodoni Street, Chișinău, Moldova
Email: t_russu@topenglish.md
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