Privacy Policy

UpGrade English On The Go

Last Updated: 24 June 2026

1. Data Controller

The Data Controller is:

Gabriella Danovaro
Piazza Goffredo Villa 28/4
Email: upgradegenova@gmail.com

This Privacy Policy explains how UpGrade English On The Go ("we", "us", "our") collects, uses, stores, and protects personal information in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), Italian privacy laws, and other applicable regulations.

2. Scope

This Privacy Policy applies to:

• The UpGrade English On The Go mobile application

• Related websites and web applications

• Educational services provided through the platform

• Video lessons, tutoring services, and learning tools

The service is available internationally, although it is primarily intended for users in Italy.

3. Information We Collect

Account Information

We may collect:

• First name and surname

• Email address

• Telephone number

• Username or account identifier

• Profile image or avatar selection

• Parent account information where applicable

Educational Information

We may collect:

• Lesson participation records

• Attendance information

• Learning progress

• Pronunciation assessments

• Tutor notes

• Educational performance information

• Homework and learning materials

User Content

Users may voluntarily upload:

• Text

• Images

• Audio recordings

• PDF documents

• Educational documents

• Contracts and administrative documents

Audio and Speech Data

The application may process audio recordings to provide:

• Speech transcription

• Pronunciation analysis

• Speaking practice

• AI-assisted language learning features

Audio recordings may be uploaded and processed through authorized service providers to provide these functions.

Video Communication Data

The platform supports live video lessons and tutoring sessions.

We may collect:

• Session participation data

• Call duration

• Attendance records

• Session timestamps

Video and audio calls are not recorded by the application unless explicitly stated and consented to in future updates. Video and audio calls are subject to parental approval before being accessible to minors.

Health Information

Parents or students may voluntarily provide information regarding medical conditions, allergies, disabilities, or other health-related circumstances that may require assistance during in-person educational activities.

This information is collected solely to protect the health, safety, and well-being of students and is processed only when voluntarily provided, and should not be submitted by online users; we only collect it for in person classes, and only use it in case of emergencies. We store it exclusively to be able to assist our students at the best of our capabilities in case of medical emergencies, and for no other reason. This information will never be shared with anyone other than directly interested personnel and staff (the student's teachers and/or on site staff) and medical personnel who should intervene in case of an emergency.

Payment Information

Payments are processed through Stripe or other authorized payment processors.

We do not store complete credit card information.

Technical Information

We may automatically collect:

• IP address

• Device type

• Operating system

• Browser type

• Language settings

• Application diagnostics

• Error reports

• Performance information

4. Children's Privacy

The platform supports children under the age of 13 through parent-managed accounts.

Where required by law:

• Parents or legal guardians must create and manage accounts for children.

• Parental consent is required before personal information is collected from children.

• Parents may request access, correction, or deletion of a child's personal information at any time.

We take additional measures to protect children's privacy and limit data collection to what is necessary to provide educational services. Children's access to live video calls and chats is subjugated to parental approval via pin. 

5. AI and Automated Processing

The platform uses artificial intelligence services provided by third-party providers, including OpenAI and Google technologies.

These services may process:

• User prompts

• Text inputs

• Images

• Audio recordings

AI-generated outputs may be stored within the application to provide educational functionality and continuity of service.

User data submitted through AI features is not used by us to train proprietary machine learning models.

6. Purposes of Processing

We process personal information to:

• Create and manage accounts

• Deliver educational services

• Schedule and manage lessons

• Facilitate communication between students, parents, and teachers

• Enable video lessons and tutoring sessions

• Process payments

• Improve learning experiences

• Provide speech recognition and pronunciation assistance

• Ensure safety during educational activities

• Maintain records and attendance information

• Provide technical support

• Comply with legal obligations

• Protect against fraud, abuse, or misuse

7. Legal Bases for Processing

We process personal data under one or more of the following legal bases:

• Performance of a contract

• Consent

• Legitimate interests

• Compliance with legal obligations

Health-related information is processed only with explicit consent or where necessary to protect vital interests.

8. Third-Party Service Providers

We may share information with trusted service providers, including:

• Base44 (application infrastructure and storage)

• OpenAI (AI services)

• Google services (AI and cloud technologies)

• Stripe (payment processing)

• Jitsi (video communication services)

• Unsplash (image resources)

These providers process information only to provide services on our behalf or as independent service providers under their own privacy policies.

9. International Data Transfers

Because the platform is available worldwide and uses international service providers, personal information may be transferred outside the European Economic Area.

Where required, appropriate safeguards such as Standard Contractual Clauses or equivalent protections are implemented.

10. Data Retention

Personal information is retained only for as long as necessary to:

• Provide educational services

• Maintain educational records

• Fulfill contractual obligations

• Meet legal, tax, and accounting requirements

• Resolve disputes and enforce agreements

Users may request account deletion through the application.

Certain records may be retained where required by law.

11. Security Measures

We implement appropriate technical and organizational measures, including:

• Encrypted communications (TLS)

• Secure hosting infrastructure

• Access controls

• Authentication systems

• Data encryption at rest where supported

• Monitoring and security procedures

No method of transmission or storage can be guaranteed to be completely secure.

12. Cookies and Similar Technologies

The platform uses cookies, local storage, session storage, and similar technologies.

These technologies are used to:

• Maintain login sessions

• Store user preferences

• Support Kids Mode settings

• Remember accessibility and interface preferences

• Maintain application functionality

• Improve performance and reliability

Third-party services such as Stripe and Jitsi may also use cookies necessary for payment processing and communication services.

The platform does not use advertising cookies or cross-site tracking technologies.

Where required by applicable law, users will be provided with cookie consent choices.

13. Notifications

The platform may send service-related notifications, including:

• Lesson reminders

• Schedule updates

• Account notifications

• Security alerts

• Service announcements

We do not send marketing communications unless consent is obtained separately.

14. User Rights

Users have the right to:

• Access their personal information

• Correct inaccurate information

• Request deletion

• Restrict processing

• Object to processing

• Withdraw consent

• Request data portability

• Lodge a complaint with a supervisory authority

Requests may be sent to:

upgradegenova@gmail.com

15. Account Deletion

Users may request deletion directly through the application.

Upon deletion:

• Personal information will be removed or anonymized where possible.

• Certain accounting, legal, or transaction records may be retained where legally required.

16. Contact Information

For privacy-related questions or requests:

Gabriella Danovaro
Piazza Goffredo Villa 28/4
Email: upgradegenova@gmail.com

17. Changes to This Policy

We may update this Privacy Policy from time to time.

Any significant changes will be communicated through the application or by other appropriate means.

Privacy Policy, UK

Privacy Policy

UpGrade English On The Go

Last Updated: [Insert Date]

1. Introduction

This Privacy Policy explains how UpGrade English On The Go ("we", "us", "our") collects, uses, stores, shares, and protects personal information when you use our mobile application, website, educational services, tutoring platform, and related services.

We process personal information in accordance with:

• The UK General Data Protection Regulation ("UK GDPR")

• The Data Protection Act 2018

• The Privacy and Electronic Communications Regulations (PECR), where applicable

• Other applicable UK data protection laws

2. Data Controller

The Data Controller responsible for your personal information is:

Gabriella Danovaro
Piazza Goffredo Villa 28/4
Email: upgradegenova@gmail.com

3. Who We Serve

UpGrade English On The Go provides educational services, language learning tools, tutoring, and online lessons.

The service may be used by:

• Adult learners

• Parents and guardians

• Children under parental supervision

• Teachers and tutors

The service is available internationally, including to users located in the United Kingdom.

4. Information We Collect

Identity and Contact Information

We may collect:

• First name

• Last name

• Email address

• Telephone number

• Username or account identifier

• Profile image or avatar selection

Educational Information

We may collect:

• Course enrolment details

• Attendance records

• Lesson participation

• Learning progress

• Assessment results

• Tutor feedback

• Homework submissions

• Educational achievements

User Content

Users may upload:

• Text

• Images

• Audio recordings

• Documents

• PDFs

• Educational materials

• Administrative documents

Audio and Speech Data

To provide language-learning features, we may process:

• Speech recordings

• Pronunciation exercises

• Audio submissions

• Transcriptions

Audio data may be processed by authorised technology providers solely to provide requested educational features.

Video Lesson Information

The platform provides live video communication between students and teachers.

We may collect:

• Session attendance

• Session duration

• Participant information

• Session timestamps

Video calls are not recorded by the platform unless a future feature specifically requires this and separate notice and consent are provided.

Health Information

Parents, guardians, or students may voluntarily provide health-related information where necessary to protect student welfare during in-person educational activities.

Examples may include:

• Allergies

• Medical conditions

• Emergency care information

• Accessibility requirements

This information is collected only where voluntarily provided and only for safety, safeguarding, and emergency support purposes.

Payment Information

Payments are processed by authorised third-party payment providers.

We do not store complete payment card information.

Technical Information

We may automatically collect:

• IP address

• Device information

• Browser information

• Operating system

• Language settings

• Diagnostic information

• Error logs

• Performance information

5. Children's Privacy

We recognise the importance of protecting children's personal information.

Where users are under 13 years of age:

• Accounts must be created and managed by a parent or legal guardian.

• Parental consent is required before personal information is collected.

• Parents may access, correct, or request deletion of their child's information.

• We limit data collection to what is reasonably necessary to provide educational services.

Teachers and tutors using the platform are expected to comply with applicable safeguarding obligations.

6. How We Use Personal Information

We use personal information to:

• Create and manage accounts

• Deliver educational services

• Facilitate online lessons and tutoring

• Monitor attendance and progress

• Process payments

• Provide customer support

• Enable speech and pronunciation tools

• Improve educational content

• Maintain platform security

• Meet legal obligations

• Protect users and prevent misuse

7. AI Services and Automated Processing

The platform may use artificial intelligence technologies provided by trusted third-party providers.

These services may process:

• User prompts

• Text submissions

• Images

• Audio recordings

AI functionality may be used to:

• Generate educational content

• Assist language learning

• Support pronunciation analysis

• Provide tutoring assistance

We do not use user content to train our own AI models.

AI-generated outputs may be stored as part of the user's educational experience.

8. Legal Bases for Processing

Under UK GDPR, we rely on one or more of the following lawful bases:

Contract

Where processing is necessary to provide our services.

Consent

Where users or parents voluntarily provide information and consent is required.

Legitimate Interests

For:

• Platform security

• Fraud prevention

• Service improvement

• Operational management

Legal Obligations

Where processing is necessary to comply with legal requirements.

Special Category Data

Health-related information is processed only where:

• Explicit consent has been provided, or

• Processing is necessary to protect vital interests.

9. Sharing Personal Information

We may share information with:

• Hosting providers

• Cloud infrastructure providers

• AI service providers

• Video communication providers

• Payment processors

• Technical support providers

• Professional advisers

• Government authorities where required by law

Current service providers may include providers supporting infrastructure, AI functionality, payment processing, and video communication.

10. International Transfers

Because our services operate internationally, personal information may be transferred outside the United Kingdom.

Where international transfers occur, we implement appropriate safeguards, including:

• UK International Data Transfer Agreements (IDTAs)

• UK Addendum to Standard Contractual Clauses

• Adequacy regulations approved by the UK Government

11. Data Retention

We retain personal information only for as long as necessary to:

• Provide services

• Maintain educational records

• Fulfil contractual obligations

• Comply with legal requirements

• Resolve disputes

Users may request deletion of their account through the application.

Certain information may be retained where legally required.

12. Security

We use appropriate technical and organisational measures to protect information, including:

• Encryption in transit

• Secure hosting

• Access controls

• Authentication mechanisms

• Monitoring and security procedures

Although we take reasonable measures, no system can guarantee absolute security.

13. Cookies and Similar Technologies

We use cookies, local storage, session storage, and similar technologies.

These technologies are used to:

• Maintain login sessions

• Store user preferences

• Support Kids Mode settings

• Improve functionality

• Maintain platform performance

Third-party services may also use essential cookies for payment processing and communication services.

We do not use advertising cookies or cross-site behavioural advertising technologies.

Where required by law, users will be provided with appropriate cookie choices.

14. Service Notifications

We may send service-related communications, including:

• Lesson reminders

• Account notifications

• Security alerts

• Schedule changes

• Technical notices

We do not send marketing communications without an appropriate legal basis.

15. Your Rights

Under UK GDPR, you may have the right to:

• Access your personal information

• Correct inaccurate information

• Request deletion

• Restrict processing

• Object to processing

• Request portability of information

• Withdraw consent where consent is relied upon

Requests may be submitted to:

upgradegenova@gmail.com

16. Complaints

If you have concerns about how we process personal information, please contact us first.

UK users may also complain to the Information Commissioner's Office (ICO).

17. Account Deletion

Users may request deletion directly through the application.

Upon deletion:

• Personal information will be deleted or anonymised where appropriate.

• Certain accounting, legal, safeguarding, or transaction records may be retained where required by law.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Any significant changes will be communicated through the platform or by other appropriate means.

19. Contact

For privacy-related enquiries:

Gabriella Danovaro
Piazza Goffredo Villa 28/4
Email: upgradegenova@gmail.com

Last Updated: 11 June 2026

1. INTRODUCTION

Welcome to Upgrade English ("App", "Platform", "Service").

These Terms and Conditions ("Terms") govern your access to and use of the Upgrade English mobile application, website, educational services, and related features.

By creating an account, accessing, or using the Service, you agree to be bound by these Terms.

If you do not agree to these Terms, you must not use the Service.

2. SERVICE PROVIDER

The Service is operated by:

Gabriella Danovaro
Piazza Goffredo Villa
Genova, Italy

Email: [INSERT SUPPORT EMAIL]

Throughout these Terms, "we", "our", and "us" refer to Upgrade English and Gabriella Danovaro.

3. ELIGIBILITY

3.1 Adults

Individuals aged 18 years or older may create and manage their own accounts.

3.2 Minors

The Platform is intended for educational use by minors, including children as young as four (4) years old.

Users under the age of 18 may only use the Service through a parent or legal guardian account or with parental authorization where permitted by applicable law.

Parents and legal guardians are responsible for:

• supervising child users;

• reviewing activity and permissions;

• managing account settings;

• ensuring compliance with these Terms.

4. ACCOUNT REGISTRATION

To use certain features, users must create an account.

You agree that all information provided is:

• accurate;

• current;

• complete;

• maintained and updated when necessary.

You are responsible for maintaining the confidentiality of your account credentials.

You are responsible for all activities occurring under your account.

5. EDUCATIONAL SERVICES

The Platform provides English language learning services, which may include:

• online courses;

• live lessons;

• group classes;

• educational resources;

• assignments and learning activities;

• communication with teachers and authorized participants.

We reserve the right to modify, suspend, or discontinue any aspect of the Service at any time.

6. VIDEO COMMUNICATION FEATURES

The Platform may provide video and audio communication functionality through Jitsi and related technologies.

By participating in video calls, users acknowledge and agree that:

• camera and microphone access are required for certain educational activities;

• participants may be visible and audible to authorized users within the session;

• sessions are intended solely for educational purposes.

Recording Policy

Upgrade English does not intentionally record or archive video or audio communications unless explicitly stated and consented to in advance.

However, users acknowledge that:

• other participants may independently take screenshots;

• other participants may independently record their screens;

• Upgrade English cannot technically prevent all unauthorized recordings by third parties.

Users agree not to record, distribute, publish, or share educational sessions without proper authorization.

7. CHILD SAFETY

Child safety is a fundamental principle of the Platform.

We may implement safety measures including:

• parental supervision tools;

• account restrictions;

• communication limitations;

• moderation controls;

• teacher verification procedures.

Any conduct that may place a child at risk may result in immediate account suspension or termination.

8. USER CONTENT

Users may upload content including:

• profile pictures;

• educational files;

• assignments;

• documents;

• other authorized materials.

You retain ownership of content you upload.

However, you grant Upgrade English a non-exclusive, worldwide, royalty-free license to:

• host;

• store;

• process;

• display;

• transmit

such content solely for the purpose of operating and improving the Service.

9. PROHIBITED CONTENT

Users may not upload, share, publish, or transmit content that:

• violates applicable law;

• infringes intellectual property rights;

• contains hate speech;

• contains harassment or bullying;

• contains sexually explicit material;

• promotes violence;

• promotes illegal activities;

• contains malware or malicious code.

We reserve the right to remove content at our sole discretion.

10. SOCIAL FEATURES

Certain versions of the Platform may allow users to:

• create public profiles;

• connect with other learners;

• share educational content.

Any social functionality may be restricted for minors and subject to parental controls.

We reserve the right to limit, modify, or disable social features at any time.

11. PAYMENTS

11.1 Payment Providers

Payments may be processed through:

• Apple App Store;

• Google Play;

• Stripe;

• other authorized payment processors.

We do not store credit card information.

11.2 Invoices

To comply with Italian tax laws, we may collect:

• first name;

• surname;

• address;

• tax code (Codice Fiscale);

• VAT number (Partita IVA).

This information is used exclusively for billing and legal compliance purposes.

11.3 Subscriptions

Certain services may be offered through recurring subscriptions.

Subscription terms, pricing, renewal conditions, and cancellation procedures will be displayed before purchase.

Unless otherwise stated:

• subscriptions automatically renew;

• users may cancel future renewals at any time;

• cancellation does not automatically entitle users to refunds already processed.

11.4 Refunds

Refund requests are handled according to:

• Apple App Store policies;

• Google Play policies;

• Stripe terms;

• applicable consumer protection laws.

Where legally required, refunds will be processed in accordance with applicable legislation.

12. INTELLECTUAL PROPERTY

All Platform content, including:

• trademarks;

• logos;

• software;

• educational materials;

• designs;

• text;

• graphics;

is owned by Upgrade English or licensed to Upgrade English.

Users may not reproduce, distribute, modify, sell, or exploit Platform materials without written permission.

13. ACCEPTABLE USE

You agree not to:

• interfere with the Platform;

• attempt unauthorized access;

• circumvent security measures;

• reverse engineer software;

• impersonate others;

• harass users or teachers;

• distribute spam.

Violation of these rules may result in suspension or termination.

14. ACCOUNT SUSPENSION AND TERMINATION

We may suspend or terminate accounts when:

• these Terms are violated;

• fraudulent activity is suspected;

• child safety concerns arise;

• legal obligations require action;

• platform security is threatened.

Users may discontinue use of the Platform at any time.

15. DISCLAIMERS

The Service is provided on an "as is" and "as available" basis.

To the fullest extent permitted by law, we do not guarantee:

• uninterrupted availability;

• error-free operation;

• compatibility with all devices;

• specific educational outcomes.

Educational progress depends on individual effort and circumstances.

16. LIMITATION OF LIABILITY

To the maximum extent permitted by law, Upgrade English shall not be liable for:

• indirect damages;

• incidental damages;

• loss of profits;

• loss of data;

• unauthorized recordings made by third parties;

• service interruptions beyond our reasonable control.

Nothing in these Terms excludes liability that cannot legally be excluded under applicable law.

17. PRIVACY

Use of the Platform is also governed by our Privacy Policy.

Users should review the Privacy Policy carefully before using the Service.

18. CHANGES TO THESE TERMS

We may modify these Terms periodically.

Updated versions will be published within the Platform.

Continued use of the Service after updates constitutes acceptance of the revised Terms.

19. GOVERNING LAW

These Terms shall be governed by and interpreted under the laws of Italy.

Any disputes arising from these Terms shall be subject to the jurisdiction required by applicable consumer protection laws and Italian law.

20. CONTACT INFORMATION

For questions regarding these Terms, please contact:

Gabriella Danovaro
Piazza Goffredo Villa
Genova, Italy

Email: [INSERT SUPPORT EMAIL]

Last Updated: 11 June 2026

1. Purpose

This Parental Consent Agreement governs the participation of minors in the Upgrade English educational platform.

By creating, approving, or managing a child account, the parent or legal guardian agrees to the terms described below.

2. Parent or Guardian Declaration

I declare that:

• I am the parent or legal guardian of the child.

• I have legal authority to provide consent on behalf of the child.

• The information provided during registration is accurate.

• I understand how the Platform collects and processes personal data as described in the Privacy Policy.

3. Consent to Data Processing

I authorize Upgrade English to process the child's personal data for the purposes of:

• account creation and management;

• participation in educational activities;

• attendance tracking;

• communication with teachers;

• participation in live video lessons;

• storage of educational materials uploaded by the child.

I understand that Upgrade English processes such data in accordance with applicable privacy laws, including GDPR.

4. Video and Audio Participation

I understand that:

• live lessons may include video and audio communication;

• my child may be visible and audible to authorized teachers and participants;

• Upgrade English does not intentionally record lessons unless expressly communicated and consented to beforehand.

I acknowledge that unauthorized screenshots or recordings by third parties cannot be completely prevented.

5. Parent Rights and Controls

As parent or guardian, I have the right to:

• review my child's account information;

• request correction of inaccurate information;

• request deletion of the child's data;

• restrict access to platform features;

• withdraw consent at any time;

• contact Upgrade English regarding safety or privacy concerns.

6. Child Safety

I understand that Upgrade English may apply restrictions, monitoring measures related to platform security, and safety controls designed to protect minors.

These measures may include:

• limited communication permissions;

• age-appropriate restrictions;

• teacher supervision requirements;

• account verification procedures.

7. Educational Responsibility

I acknowledge that I remain responsible for supervising my child's use of the Platform and internet-connected devices.

Upgrade English supplements, but does not replace, parental supervision.

8. Withdrawal of Consent

I may withdraw this consent at any time by contacting:

[INSERT SUPPORT EMAIL]

Withdrawal of consent may result in suspension or termination of the child's access to the Platform where continued processing is necessary for service delivery.

9. Agreement

By creating or approving a child account, I confirm that I have read, understood, and accepted this Parental Consent Agreement.

Last Updated: 11 June 2026

1. Purpose

This Teacher Code of Conduct establishes the standards expected of all teachers, tutors, instructors, assistants, and educational personnel using Upgrade English.

The protection and wellbeing of children is our highest priority.

2. Professional Conduct

Teachers must:

• behave professionally at all times;

• treat all students with respect and dignity;

• create a safe and inclusive learning environment;

• avoid discriminatory, abusive, or inappropriate behavior.

3. Child Protection Principles

Teachers must:

• prioritize student safety;

• report concerns regarding child welfare;

• comply with applicable child protection laws;

• follow all safeguarding procedures established by Upgrade English.

Teachers shall never engage in conduct that may exploit, endanger, intimidate, or manipulate a student.

4. Communication Rules

Teachers may communicate with students only through authorized Platform channels.

Teachers must not:

• request personal contact information from students;

• communicate privately through personal social media accounts;

• encourage off-platform communication without parental authorization;

• engage in inappropriate personal discussions.

5. Video Call Standards

During video sessions, teachers must:

• maintain professional appearance and conduct;

• ensure lessons occur in appropriate environments;

• avoid inappropriate language or content;

• respect student privacy.

Teachers should encourage camera participation where educationally appropriate, while respecting individual circumstances and applicable parental preferences.

6. Physical and Emotional Safety

Teachers must not:

• use threatening behavior;

• humiliate students;

• engage in bullying;

• use discriminatory language;

• expose students to inappropriate content.

Constructive feedback must always be respectful and age appropriate.

7. Confidentiality

Teachers must maintain confidentiality regarding:

• student information;

• educational records;

• family information;

• personal circumstances disclosed during lessons.

Confidential information may only be disclosed where legally required or necessary to protect a child from harm.

8. Recordings and Screenshots

Teachers may not record, capture, distribute, or publish student images, video sessions, or educational interactions without explicit authorization from Upgrade English and, where applicable, parental consent.

9. Reporting Obligations

Teachers must immediately report:

• suspected child abuse;

• inappropriate user behavior;

• safety concerns;

• security incidents;

• violations of this Code.

Reports should be made through designated safeguarding procedures.

10. Compliance

Violation of this Code may result in:

• suspension;

• removal from teaching activities;

• termination of contractual relationships;

• referral to authorities where required by law.

11. Acknowledgment

By providing services through Upgrade English, teachers acknowledge that they have read, understood, and agree to comply with this Teacher Code of Conduct.

Upgrade English
Last Updated: 11 July 2026

1. PURPOSE

Upgrade English is committed to providing a safe, respectful, and supportive learning environment for all children and young people who use our platform.

This Child Safeguarding Policy outlines our commitment to protecting children from abuse, exploitation, neglect, harassment, bullying, and any other form of harm that may arise in connection with our educational services.

The welfare and safety of children are our highest priorities.

2. SCOPE

This Policy applies to:

• students using the Platform and attending a course, online or frontal, one-on-one or in a group;

• parents and legal guardians;

• teachers, tutors, and instructors;

• contractors and service providers;

• employees and administrators;

• any individual interacting with children through the Platform.

3. DEFINITIONS

For the purposes of this Policy:

Child

A child is any individual under the age of 18.

Safeguarding

Safeguarding refers to the actions taken to protect children from harm and to promote their wellbeing.

Harm

Harm includes:

• physical abuse;

• emotional abuse;

• psychological abuse;

• sexual abuse;

• neglect;

• bullying;

• cyberbullying;

• exploitation;

• grooming;

• discrimination.

4. SAFEGUARDING PRINCIPLES

Upgrade English is guided by the following principles:

4.1 Child-Centered Approach

The safety, dignity, and wellbeing of children take precedence over all other considerations.

4.2 Prevention

We seek to prevent harm through policies, platform design, supervision, and education.

4.3 Accountability

All adults interacting with children through the Platform are expected to follow safeguarding standards.

4.4 Respect

Every child shall be treated with respect regardless of age, gender, nationality, religion, ethnicity, disability, language, or background.

5. PARENTAL INVOLVEMENT

Because our Platform may be used by children as young as four (4) years old, parental involvement is a core safeguarding measure.

Parents and legal guardians may:

• create and manage child accounts;

• review account activity where available;

• control permissions and access settings;

• communicate with the Platform regarding concerns;

• request correction or deletion of information.

Child accounts operate under the supervision and authority of a parent or legal guardian.

6. SAFETY MEASURES

Upgrade English implements reasonable safeguards designed to protect children, including:

Account Controls

• Parent-linked child accounts

• Age-appropriate restrictions

• Permission-based access

Platform Restrictions

• Limited access to communication features

• Restricted visibility of child profiles

• Controlled participation in educational activities

Security Measures

• Secure authentication procedures

• Access controls

• Data protection measures

• Encrypted communications where applicable

7. VIDEO LESSONS AND LIVE COMMUNICATIONS

The Platform may provide live educational sessions through video and audio technology.

To support child safety:

• Lessons are intended solely for educational purposes.

• Teachers are expected to maintain professional conduct at all times.

• Children may be required to activate their cameras when appropriate to verify participation and ensure classroom safety.

• Parents are encouraged to supervise younger children during lessons.

Upgrade English does not intentionally record lessons unless clearly disclosed and consented to in advance.

8. SCREENSHOTS AND RECORDINGS

Upgrade English does not authorize unauthorized recording of educational sessions.

Users are prohibited from:

• recording lessons without permission;

• distributing screenshots of children;

• sharing educational sessions publicly;

• publishing images or recordings of participants without authorization.

While we prohibit such behavior, we acknowledge that unauthorized screenshots or recordings may be technically difficult to prevent entirely.

Any misuse may result in account suspension or termination.

9. ONLINE CONDUCT

All users must behave respectfully.

The following conduct is prohibited:

• harassment;

• bullying;

• cyberbullying;

• intimidation;

• discrimination;

• inappropriate language;

• sharing offensive content;

• sharing sexually explicit material;

• threats or coercion;

• impersonation.

Violations may result in immediate action.

10. TEACHER RESPONSIBILITIES

Teachers and instructors must:

• comply with the Teacher Code of Conduct;

• maintain professional boundaries;

• communicate only through approved channels;

• avoid inappropriate personal interactions;

• report safeguarding concerns promptly.

Teachers may not:

• request private contact information from children;

• encourage off-platform communication;

• engage in discriminatory or inappropriate conduct.

11. REPORTING CONCERNS

Parents, students, teachers, and users are encouraged to report any safeguarding concerns immediately.

Examples include:

• suspected abuse;

• inappropriate communications;

• bullying;

• harassment;

• unauthorized recordings;

• suspicious user behavior;

• safety risks.

Reports should be submitted to:

Safeguarding Contact:
Gabriella Danovaro
Email: [INSERT SAFEGUARDING EMAIL]

12. RESPONSE TO SAFEGUARDING INCIDENTS

When a safeguarding concern is reported, Upgrade English may:

• investigate the report;

• restrict account access;

• suspend and/or expel users;

• remove content;

• notify parents or guardians;

• cooperate with law enforcement or competent authorities where legally required.

Responses will be proportionate to the nature and seriousness of the concern.

13. EXPULSION POLICY AND CRITERIA

Parents will be admonished once or twice (depending on the severity of the offence, which will be determined by the teacher present at the time and discussed with other teachers who know the student(s) involved and the administration. A written report will be submitted to the parents. In case of suspension from group activities, should it be possible to transform the course in one-on-one, that shall be attemped. Should the abusive behaviour somehow persist towards other students or teachers, the expulsion will be confirmed, with no refund. The remaining course hours may, if possible, be transferred to another student in the same or different age group and level assessment (subject to availability of spots in pre-existing courses).

Parents are asked to please report any and all instances in which their child should feel uncomfortable or victimized. We will do everything in our power to safeguard the student, which may mean moving them to a different class, removing another student, or any other measure we feel necessary to ensure the safety and well-being of all those involved.

14. DATA PROTECTION AND CHILDREN

We are committed to protecting children's personal information.

Child-related data is processed in accordance with:

• GDPR (Regulation (EU) 2016/679);

• applicable Italian privacy laws;

• our Privacy Policy.

Personal data is collected only where necessary for educational services and platform operation.

15. TRAINING AND REVIEW

Upgrade English may periodically review and update safeguarding measures, policies, and procedures to reflect:

• legal developments;

• technological changes;

• platform features;

• emerging child protection risks.

16. POLICY REVIEW

This Policy may be updated from time to time.

The most current version will be made available through the Platform and associated websites.

Continued use of the Service following updates constitutes acceptance of the revised Policy.

16. CONTACT

Questions regarding this Policy may be directed to:

Gabriella Danovaro
Piazza Goffredo Villa
Genova, Italy

Email: [INSERT SUPPORT EMAIL]

SAFEGUARDING COMMITMENT

Upgrade English believes that every child has the right to learn in a safe, respectful, and supportive environment. We are committed to taking reasonable and proportionate measures to protect children and promote their wellbeing throughout their educational experience.