Privacy Policy

Fully Spoken Ltd

Effective Date: 1st February 2026

1. Introduction

This Privacy Policy explains how Fully Spoken Ltd (“we”, “us”, “our”) collects, uses, stores, and protects personal data when you interact with our website www.fullyspoken.com, our services, or communicate with us.

Fully Spoken Ltd is the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Contact details:
Email: info@fullyspoken.com
Address: 3rd Floor, 86–90 Paul Street, London, EC2A 4NE

This Privacy Policy should be read alongside our Website Terms and Conditions, Client / Service Terms and Conditions, and Refund Policy.

2. Scope of This Policy

This Privacy Policy applies to personal data collected:

Through our website
When you contact us or make an enquiry
When you engage our services as an individual or organisational client
When tutors deliver services on our behalf

It does not apply to third-party websites or platforms linked from our website.

3. Legal Basis for Processing

We process personal data only where a lawful basis applies under Article 6 of the UK GDPR. These include:

Contractual necessity: To take steps prior to entering into a contract or to perform our contractual obligations
Legitimate interests: To operate, manage, and improve our services, communicate with clients, ensure safeguarding, and run our business responsibly
Consent: Where required for marketing communications or session recordings
Legal obligation: To comply with legal and regulatory requirements

Where we rely on legitimate interests, we balance our interests against your rights and freedoms and apply appropriate safeguards.

4. Personal Data We Collect

Data Collected Automatically

When you visit our website, we may collect limited technical data, including:

IP address
Device and browser information
Pages visited and interactions
Further information about our use of cookies can be found in our Cookie Policy.

This data is used for website functionality, security, and analytics.

Data Collected Directly

Depending on your interaction with us, we may collect:

Name
Email address
Telephone number
Address (where required)
Organisation name and role (for B2B clients)
Payment and invoicing information
Information relevant to delivering language services

We only collect data that is necessary for the stated purpose.

5. How We Use Personal Data

We use personal data to:

Respond to enquiries and communications
Deliver and administer services
Arrange and manage tutoring sessions
Process payments and issue invoices
Match learners with suitable tutors
Improve our website and services
Meet safeguarding and legal obligations

We do not use personal data for unrelated purposes.

6. Marketing Communications

We may send service-related communications where necessary to administer services or respond to enquiries.

Where consent is required, we will obtain it before sending marketing communications.You may opt out of marketing at any time by using the unsubscribe link or contacting us directly.

7. Sharing Personal Data

We may share personal data with trusted third parties where necessary, including:

Tutors engaged to deliver services
Payment processors
IT and website service providers
Video conferencing platforms used for session delivery
Professional advisers and regulators where required by law

Tutors receive only the information necessary to deliver services and are bound by confidentiality and data protection obligations.

Some third-party providers may process limited technical data such as IP addresses or usage data to support website analytics or service delivery.

We do not sell personal data.

8. Third-Party Platforms

Where services are delivered via third-party video conferencing platforms, those platforms may process personal data in accordance with their own privacy policies.

We encourage users to review the privacy policies of those platforms. Fully Spoken Ltd is not responsible for the data practices of third-party providers.

9. Session Recordings

Sessions are recorded only where all participants have given explicit consent.

Recordings may be used for:

Quality assurance
Training and service improvement
Safeguarding or dispute resolution

Recordings are stored securely and retained for no longer than 12 months, unless a longer period is required for legal reasons. You may withdraw consent at any time.

10. Data Retention

We retain personal data only for as long as necessary, including:

Financial records: up to 6 years
Service-related data: for the duration of the service and a reasonable period afterwards
Marketing data: until you opt out

11. Data Security

We implement appropriate technical and organisational measures to protect personal data, including encryption, access controls, and secure systems.

While we take reasonable steps to protect data, no online system can be guaranteed to be completely secure.

12. International Data Transfers

Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements.

13. Your Rights

Under UK GDPR, you have the right to:

Access your personal data
Request correction or deletion
Restrict or object to processing
Request data portability
Withdraw consent where applicable

Requests can be made by contacting info@fullyspoken.com.

14. Children and Young People

Our services are intended for users aged 16 and over.

Where services involve individuals under 16, parental or guardian consent is required, and additional safeguards apply.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Any material changes will be communicated appropriately, and the updated policy will be published on our website.

16. Complaints

If you have concerns about how we handle personal data, please contact us first so we can try to resolve the issue.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
www.ico.org.uk