Privacy Policy

Introduction
Welcome to keelekool.ee («we,» «us,» «our»). We are committed to protecting your privacy and ensuring your personal data is handled responsibly. This Privacy Policy explains how we collect, use, store, and protect your data when you visit our website at https://www.keelekool.ee and interact with our AI-powered chatbot.

Our practices comply with the General Data Protection Regulation (GDPR) and the EU Artificial Intelligence Act (EU AI Act), ensuring transparency, security, and respect for your rights. We process data only for necessary purposes, minimize collection, and provide clear mechanisms for consent and rights exercise.

Who We Are
Our website address is: https://www.keelekool.ee. We operate this site and provide services, including an AI chatbot that assists customers with inquiries about language courses, registration, and support.

For privacy-related questions, please contact us at:

• Email: info@keelekool.ee
• Website: https://www.keelekool.ee/contact

Information We Collect
We collect the following types of personal data:

• User-Provided Data:
  o Information you submit through forms, comments, or user accounts (e.g., name, email address, profile details).
  o Messages and queries you send to our AI chatbot, including any personal details shared during conversations.
• Automatically Collected Data:
  o IP address, browser type, device information, and usage data via cookies or similar technologies.
  o Metadata from chatbot interactions (e.g., timestamps, session identifiers).
• Media Data:
  o If you upload photos or other media, we may process metadata (e.g., EXIF data) unless removed prior to upload.

We minimize data collection to what is essential for service provision, and anonymize where possible.

How We Collect Information
We collect your data through:

• Website Interactions: Forms, comments, user account creation, and media uploads.
• AI Chatbot: Your conversations with our chatbot, which is clearly identified as an AI system at the start of each interaction.
• Cookies and Tracking: Technologies that track usage and preferences (see Section 8 for details).

Purpose of Data Collection
We process your personal data to:

• Provide and improve our services, including website functionality and chatbot responses.
• Respond to your inquiries and offer customer support.
• Analyze usage to enhance user experience (e.g., via analytics).
• Comply with legal obligations and ensure security.

Data from chatbot interactions is used solely for responding to queries and, with your consent, for improving the AI system (e.g., bias mitigation and performance monitoring).

Use of Data
Your data is processed by us and, where applicable, by third-party providers under strict Data Processing Agreements (DPAs). For example:

• Our AI chatbot is powered by OpenAI, which processes interaction data per their privacy policy https://openai.com/policies/row-privacy-policy/
• We minimize data use and anonymize where possible, ensuring compliance with GDPR and the EU AI Act.

The chatbot’s data may also be used to improve its performance, but only with your consent where required. We implement human oversight for escalated queries and regularly audit for biases in datasets and responses.

Data Storage and Protection

• Storage: Data is stored on secure servers within the European Union.
• Security: We use encryption (e.g., HTTPS, AES-256), role-based access controls, and regular audits to protect your data.
• Retention:
  o Chatbot logs are retained for 30 days for quality assurance, then deleted.
  o User account data is kept until you request deletion or after 2 years of inactivity.
  o Comments and metadata are stored indefinitely unless you request removal.

If a data breach occurs, we will notify you and authorities within 72 hours, as required by GDPR.

Cookies and Tracking Technologies
We use cookies to improve your experience:

• Essential Cookies: Enable core functionality (e.g., login support).
• Functional Cookies: Save your preferences (e.g., name, email for comments, stored for 1 year).
• Analytics Cookies: Track site usage anonymously.
• Login Cookies: If you log in, we set temporary cookies (deleted on browser close) and persistent cookies (2 days, or 2 weeks with “Remember Me”).
• Editing Cookies: For article edits, a cookie with the post ID is stored for 1 day.

You can manage preferences via your browser or our cookie consent tool.

Third-Party Services
We share data with:

• OpenAI: For chatbot functionality (see their privacy policy: https://openai.com/policies/row-privacy-policy/).
• Gravatar: If you comment, your email hash may be shared to display your avatar (see: https://automattic.com/privacy/).
• Spam Detection: Comments may be checked by an automated service.

All third parties comply with GDPR via DPAs.

Embedded Content from Other Websites
Our site may include embedded content (e.g., videos, images). These third-party sites may collect data, use cookies, or track you, especially if logged into their services. Review their privacy policies for details.

User Rights (Under GDPR)
You have the following rights:

• Access: Request a copy of your data.
• Rectification: Correct inaccurate data.
• Erasure: Delete your data (subject to legal exceptions).
• Restrict Processing: Limit how we use your data.
• Data Portability: Receive your data in a machine-readable format.
• Object: Oppose processing for legitimate interests.

To exercise these rights, email us at info@keelekool.ee. We’ll respond within 1 month. You can also request data exports or deletion directly via the chatbot command “Download my data” or “Delete my data”.

AI Chatbot Interactions
Our AI chatbot assists with customer inquiries. We:

• Clearly disclose it’s an AI system.
• Collect your messages and metadata (e.g., timestamps).
• Use this data to respond and improve the chatbot (with consent where needed).

You can withdraw consent or opt out of data use via the chatbot command “Stop data use”. We mitigate biases and ensure accuracy per the EU AI Act.

Data Sharing and Transfers

• We don’t sell your data.
• If data is transferred outside the EU (e.g., to a third-party AI provider), we use Standard Contractual Clauses (SCCs) to ensure GDPR compliance.

Changes to This Privacy Policy
We may update this policy. Changes will be posted here, and we’ll notify you via email or a website notice. Review periodically for updates.

Contact Us
For questions or concerns:

Website: https://www.keelekool.ee/contact

Email: info@keelekool.ee