Privacy Policy

Your privacy is important to us. We have a few fundamental principles which we reflect in our policies and processes:

  • We are thoughtful about the personal data we ask you to provide and the personal information that we collect about you through the operation of our services.
  • We store personal information for no longer we really need to keep it or when it is required by law.
  • We aim to make it as simple as possible for you to control what information on this website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
  • We aim for full transparency on how we gather, use, and share your personal information.

Below is integrito.ai‘s Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Privacy Policy Covers

Hi there! We are the folks behind this website. We are the company Teaching Writing Online Limited.

This Privacy Policy applies to information that we collect about you when you use our website – https://integrito.ai and/or via any LMS (Learning Management System) which you may use along with our Services.

Throughout this Privacy Policy, we’ll refer to our website, mobile applications, API, and other products and services, associated with https://integrito.ai, collectively as “Services.”

We are committed to protect and respect your privacy. This Privacy Policy sets out how we may use, process and store your personal information. If such personal information can directly or indirectly refer to you as a natural person, such information consists of your “Personal Data” and shall be protected by us with strict accuracy. Below we explain how we collect, use, and share information about you, along with the choices that you have concerning that information.

If you have any questions about this Privacy Policy, please contact us.

Are we a Controller?

We process personal information both as a Processor and as a Controller, as defined in the GDPR:

  • when you are an individual user, buying our Services via Website, we will in most cases be a Controller;
  • In cases where your information is provided to us only through your institution, we will be the Processor, and will only delete records per the institution’s specific instructions and will request that you make any requests for access, correction or deletion of personal information through the institution. We will respond to such requests when received from the institution.

How We Can Receive Your Information

We may get that information from you if you are an individual user via website registration or our partners (LMS, educational institution, etc.), through contracts or other legal arrangements you have with us or our partners, to deliver contractual/legal obligations. Your permission and consent (if we rely on it) can be collected by us directly, or we may receive your personal information from third parties whom you have given consent to pass this information on to us.

Information we collect about you

If you visit our website or member communities, we may automatically collect information about you, for example:

  • Technical information (such as operating system, browser type)
  • IP addresses
  • Information about what type of device you used to connect to our website
  • How you interact with our website.

For more information read our Cookie Policy.

Here you can find the types of Personal Data we collect and the purposes of its processing.

Personal information typesPurposes we collect your information for
User’s Country
  • verification of the User
  • prevention of fraudulent use and resale of User’s accounts
  • tax implications, VAT purposes
User’s email
  • the main contact of communication with User
  • to provide you with marketing and promotional materials about our Services
  • to verify User in LMS
User’s Name and Surname
  • verification of the User
  • for invoices, billing, and taxation
  • prevention of fraudulent use and resale of User’s accounts
Phone Number
  • Customer support
City/state/ZIP code/address
  • billing information for invoices

Social Networking Services

You may register to join the Website by logging into your accounts with a third party social networking service (e.g., Facebook, Google account, and other third-party services that may be added to the Website). If you choose to register via Social Network, or to later link your account to Social Network, we will use the Personal Data you have provided to the Social Network (such as your name, email address, gender and other information the user makes publicly available via the Social Network) to create the user’s account. Note that the information we collect from and through the Social Network may depend on the privacy settings you have set with the Social Network and the permissions you grant to us in connection with linking your account on our Website to Your account in Social Network.

If You choose to “like” or “share” content, or to otherwise share information from or via Website with a third-party site or service, that information may be publicly displayed, and the third party may have access to information about you and your use of the Website.

Your interactions with third parties through Social Networks or similar features are governed by the respective privacy policies of those third parties. Please note that your relationship with any Social Network is governed solely by your agreement(s) with such Social Network.

Why do we collect Personal Data?

We collect information for the same or all of the following reasons:

  • To provide Services to you after you have ordered one of our services through the website OR in relation to contractual obligations with educational institution;
  • To provide information about products or services you have shown interest in purchasing within a reasonable time afterward if you are already an existing customer;
  • To provide information to you about products or services you have purchased from us, or related products or services (no third-party services are advertised);
  • To provide services to you under a contract;
  • If we are obliged to do so by the legislation;

Grounds of collecting information from you

We primarily rely upon the following:

  1. Article 6(1)(b) of the GDPR – contractual obligations. Pursuant to this provision of GDPR, we are obliged to process your personal data to provide you with our Services because we have entered into commercial contract. This mostly applies to individual customers.
  2. Article 6(1)(f) of the GDPR, which means that we rely upon the official authority of the Data Controller (meaning the institution that is our customer) to process its students data in such a way that anti-plagiarism checks may be made to prove the ownership of the texts.

Though we do not rely on consent as the primary basis for data processing we still gather and log it to make sure the transparency is achieved and our users had a possibility to read this Policy.

Information we receive from other sources

We work with third parties (including, for example, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, background checking agencies) and may receive information about you from them as part of the service we provide you, or for other legal reasons.

Files

We may collect and store the files you upload, download, or access with the Website. Please do not share with us the files you are not permitted to use. Please do not upload or share with us the files that contain your personal information or personal information of third parties without permission. We may not guarantee that such personal information will be secured, although we use all precautions and best practices to data storage.

Whom might we share your information with?

We may share your personal data with third parties. For example, we may share your personal information with:

  • Our group companies, which means our subsidiaries, or our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
  • Subcontractors and third parties for the purpose of the performance of a contract that we hold with them or that we hold with you. In such cases data is limited for the purposes;
  • With third parties who provide us services. The list is below.

Disclosure on AI tools. Please note that we do not share your textual content with external AI tools or algorithms.

Other reasons we may share your personal information with a third party

If Teaching Writing Online Limited or substantially all its assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets of the company.

Besides, we will share your personal data with third parties for the following reasons:

  • If we must comply with a legal obligation;
  • If it is legally requested by a government agency;
  • To enforce or apply our Website Terms of Use or other agreements;
  • To protect the rights, property, or safety of Teaching Writing Online Limited, our customers, or others;
  • If exchange information with third parties aimed to prevent fraud or to reduce our credit risks.

Aggregated or anonymized data

We may, from time to time, provide third parties with data that has been aggregated or anonymized.

This means that your personal information that could be used to identify you have been removed from the data. Data provided to third parties in this way is not personal data and is only statistics or similar anonymized data; however, you do keep your right to object.

Where we store and process your personal data

We primarily store and process your personal data in the EU/European Economic Area or USA (“EEA”). For data transfers outside the EEA we use the Standard Contractual Clauses (EU Directive 95/46/EC), which meet the adequate mechanism requirements of all EU members.

Anyway, we put in place appropriate technical and organizational measures to protect personal data.

Transmission and storage of your personal data

We shall use best practice to ensure your data is encrypted to the standard required in the GDPR to protect your personal data.

How long will we keep your personal data? Data retention

We will not retain your Personal Data for longer than required.

We will keep your personal information:

  • For as long as required by law (e.g. for the individual users it is the accounting records retention period which is 6 years in UK);
  • Until we no longer have a valid reason for keeping it (e.g. the contract with institution was terminated, or you didn’t use your account for a significant period);
  • Until you request us to stop using it or delete it prior to the retention period end.

We may keep just enough of your Personal Data to ensure that we comply with your requests not to use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until such time as you are no longer our customer, or for tax purposes etc.

If you have questions about our Data Retention Policy, we can provide you a copy. Please contact: [email protected].

If you chose not to give your personal information to us

If the Personal Data is necessary in order to provide Services to you under a contract between you and Teaching Writing Online Limited, we will have to refuse entering into that contract or providing the Services before you give us your personal information which is essential for us to be able to provide them.

Your Rights

We will respect your legal rights to your Personal Data.

Below are the rights that you have under law, and what we do to protect those rights:

Legal rightWhat we do to protect your rights
The right to be informedWe are publishing this Privacy Policy to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data. Furthermore, we will also answer all your questions regarding this Policy sent to the [email protected]
The right to accessYou have the right to access your information. Please contact our Data Protection Officer at [email protected]. if you wish to access the personal information we hold about you. In cases when your institution registered you with us, please contact us via your institution.
The right to rectificationIf the information we hold about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact our Data Protection Officer if you need us to rectify your information: [email protected]. In cases when your institution registered you with us, please contact us via your institution.
The right to erasureThis is sometimes called ‘the right to be forgotten’. If you want us to erase all your personal data, and we do not have any legal reason to continue to process and hold it, please contact our Data Protection Officer: [email protected]. In cases when your institution registered you with us, please contact us via your institution.
The right to restrict processingYou have the right to ask us to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. If you want us to restrict processing of your data, please contact our Data Protection Office: [email protected]. In cases when your institution registered you with us, please contact us via your institution.
The right to data portabilityWe must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without affecting the usability of your data. Please contact our Data Protection Officer if you want information on how to port your data elsewhere: [email protected]. This right only applies to personal data that you have provided to us as the Data Controller. The data must be held by us by consent or for the performance of a contract.
The right to objectYou have the right to object to us processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purposeless statistics. If you wish to object, please contact our Data Protection Officer: [email protected]. In cases when your institution registered you with us, please contact us via your institution.
The right to withdraw consentIf we rely on consent to process your data, but you have changed your mind later, you have the right to withdraw your consent at any time, and we must stop processing your data. If you want to withdraw your consent, please contact our Data Protection Officer: [email protected].
The right to appeal to a Supervisory AuthorityYou have the right to appeal to the ICO if you feel that we have not responded to your requests to solve a problem. You can find their contact details here: https://ico.org.uk/concerns/

California Consumer Privacy Act

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the “Information we collect about you” section above. We collect this information for the business and commercial purposes described in the “Why do we collect Personal Data?” section above. We share this information with the categories of third parties described in the “Third Parties” section.

Do Not Sell: We do not sell (as such a term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for the purposes as further described in our Cookie Policy

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected]. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Age Limitations, COPPA compliance

We do not knowingly collect any information from children under the age of 13 in the United States or other countries unless and until the relevant institution has provided consent and authorization for a student under 13 to use the products and services and for us to collect information from such students. Where a client institution instructs us to collect personal information from children under the age of 13, we collect, use, process and retain such information solely to provide the educational services on behalf of the client and for the purposes set forth in our agreement with the client. We collect only as much information as is necessary to provide the Services and the client may access, delete or withdraw consent for continued processing of the child’s information at any time. If you have any questions about reviewing, modifying, or deleting personal information of a child under the age of 13, please contact your educational institution directly.

Please contact us at [email protected] if you believe we have inadvertently collected personal information from a child under 13 without proper consent. This will allow us to delete such information as soon as possible.

COPPA: We rely on FTC’s explanations that COPPA’s requirements do not apply to sites that contract with schools to offer online programs for the benefit of the schools and their students, and collect personal information only for these purposes (FTC FAQ). We do not collect any information for purposes other than educational.

Links to Other Websites

From time to time, our website may contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites may have their own privacy notices and that we do not accept any responsibility or liability for any such notices. Please check these notices, where available, before you submit any personal data to these websites.

Third Parties

We do use some third-party services and products on which you may find information in this List of Subprocessors, including what data we share with them, or they provide to us, the service they provide to us and links to their respective privacy policies.

This list may change over time, and we’ll work hard to keep it up-to-date. If you have any questions, please get in touch with us.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review them to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Website. If you disagree with the changes to this Privacy Policy, you should deactivate your account.

The Laws and Regulations

Personal data protection laws that we follow:

  • The Data Protection Act 2018 (UK)
  • REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing General Data Protection Regulation (“GDPR”).
  • Children’s Online Privacy Protection Act (“COPPA”) US
  • California Consumer Privacy Act (“CCPA”) US

How to delete your account

If you wish to permanently delete your account, you may do so in your Profile section, or please contact [email protected]. We will review your request in accordance with your and our rights (such as the right to keep information for protection from legal claims) and obligations (such as the duty to store information for tax purposes) under the applicable laws, notify you of the results of this review, and act accordingly. We may, however, not be able to continue to serve you.

To delete the content you submitted, please go to My Documents section.

How can you reach us?

This is our registered address, company number and contact information:

Teaching Writing Online Limited
Dixcart House Addlestone Road,
Bourne Business Park, Addlestone,
Surrey, United Kingdom, KT15 2LE
Email: [email protected].