Privacy Policy.

The party responsible for the processing of your personal data (the "data controller") is:

Benjamin Pfeifer
P. City English
Northville, Michigan
United States
ben@pcityenglish.com

P. City English is a sole proprietorship operated from the United States. Because our Business English courses are offered to clients in the European Union and European Economic Area, we process personal data of EU/EEA residents in accordance with the GDPR (Regulation (EU) 2016/679), as described in this policy.

Depending on how you interact with this website, we may process the following categories of personal data:

• Contact data: your name and email address, when you contact us by email or submit an inquiry
• Booking data: your name, email address, and time zone, collected by Google Calendar appointment scheduling when you book a consultation or class
• Payment data: billing name, email, and payment card details, processed by Stripe when you pay for a class at booking (Stripe is connected to the Google booking page; we never see your full card details)
• Email list data: your email address, if you have signed up to our email list for occasional Business English tips, processed by MailerLite
• Communication data: the content of emails or messages you send us
• Usage and technical data: IP address, browser type, pages visited, and approximate location, collected automatically by Vercel, our hosting provider, when you visit this website (server logs and cookieless, aggregated analytics)
• Analytics and advertising identifiers: a randomly generated identifier and details of the pages you viewed and actions you took, processed by Google Analytics and Google Ads — only if you accept cookies (see Section 7). If you arrived from one of our advertisements, this includes the click identifier Google attaches to the link.
• Cookie data: information stored in cookies on your device (see Section 7 below)

We do not collect sensitive personal data (such as health data, political opinions, or biometric data) and we do not knowingly collect data from children under 16.

We process your personal data only where we have a lawful basis under the GDPR (Regulation (EU) 2016/679). The table below sets out our purposes and the relevant legal basis (Article 6 GDPR):

• To provide Business English courses and manage our client relationship — legal basis: performance of a contract (Art. 6(1)(b))
• To respond to inquiries and communicate with you — legal basis: legitimate interest in responding to potential clients (Art. 6(1)(f))
• To process payments for course packages — legal basis: performance of a contract (Art. 6(1)(b)); compliance with legal obligations for financial records (Art. 6(1)(c))
• To send occasional Business English tips by email to people who signed up for them — legal basis: your consent, given when you sign up (Art. 6(1)(a)); you may unsubscribe at any time via the link in every email
• To improve and operate this website — legal basis: legitimate interest in maintaining a functional and secure website (Art. 6(1)(f))
• To use non-essential cookies, and to measure website use and advertising performance through Google Analytics and Google Ads — legal basis: your consent (Art. 6(1)(a)); you may withdraw it at any time via "Cookie Settings" at the bottom of any page

We use the following third-party services to operate this website and deliver our services. Each acts as a data processor on our behalf, or as an independent data controller in respect of their own services:

• Vercel Inc. (United States) — website hosting and cookieless web analytics. Data transfers to the US are covered by the EU-US Data Privacy Framework. Vercel Privacy Policy
• Stripe, Inc. (United States) — payment processing. Stripe is certified under the EU-US Data Privacy Framework and processes payment data as an independent data controller under applicable financial regulations. Stripe Privacy Policy
• MailerLite, Inc. (United States / Lithuania) — email delivery and subscriber management for our email list (occasional Business English tips). Your email address is stored with MailerLite if you have signed up. MailerLite Privacy Policy
• Google LLC (United States) - four separate services. Google Calendar appointment scheduling, which hosts the booking pages for consultations and classes and stores the details you enter when you book. Google Fonts, loaded from Google's CDN on page load; your IP address is transmitted to Google's servers when fonts are requested. Google Analytics and Google Ads, used to measure website use and advertising performance, both of which run only with your consent (see Section 7). Google is certified under the EU-US Data Privacy Framework. Google Privacy Policy

Because P. City English is operated from the United States, personal data you provide to us is processed in the United States. Where our service providers transfer EU/EEA personal data to the US, those transfers are covered by the EU-US Data Privacy Framework or Standard Contractual Clauses, as noted above.

We do not sell your personal data to any third party.

• Email correspondence and course records: retained for the duration of our client relationship and for a period of up to three years afterward, in case of follow-up or disputes
• Payment and invoice records: retained for at least seven years to comply with US federal and state tax record-keeping requirements
• Email list subscription (MailerLite): retained until you unsubscribe; unsubscribing removes you from all future mailings
• Booking data (Google Calendar): kept in our Google Calendar and subject to Google's own data retention policy; we do not store copies independently beyond what is necessary for the client relationship
• Website analytics (Vercel): aggregated and anonymized; individual visit data is not retained by us

When the applicable retention period ends, we delete your personal data securely or anonymize it.

As a data subject in the EU/EEA, you have the following rights:

• Right of access (Art. 15): you may request a copy of the personal data we hold about you
• Right to rectification (Art. 16): you may ask us to correct inaccurate data
• Right to erasure (Art. 17): you may ask us to delete your data, subject to legal retention obligations
• Right to restriction (Art. 18): you may ask us to restrict processing in certain circumstances
• Right to data portability (Art. 20): you may request your data in a machine-readable format where processing is based on consent or contract
• Right to object (Art. 21): you may object to processing based on legitimate interest; we will stop unless we can demonstrate compelling legitimate grounds
• Right to withdraw consent (Art. 7(3)): where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us at ben@pcityenglish.com. We will respond within 30 days.

When you first visit this website we ask whether you accept analytics and advertising cookies. Nothing is stored on your device for those purposes unless you accept. If you decline, the site works exactly as it does otherwise; we simply receive less detail about how it was used.

The cookies involved are:

• Google Analytics (_ga, _ga_*) — measures how the site is used, in aggregate. Set only with your consent. Typically expires after 2 years.
• Google Ads (_gcl_*) — measures whether an advertisement led to a signup or booking. Set only with your consent, and only if you arrived from one of our ads. Typically expires after 90 days.

We use Google's Consent Mode, which means the Google tags on this site are told your choice before they are allowed to store anything. If you decline, they operate without cookies and without identifying you.

Two other things are stored on your device that are not cookies and are never shared with anyone: your cookie choice itself, and, if you arrived from a campaign link, which campaign that was. Both are kept in your browser's local storage and never leave it except to label your own signup if you choose to give us your email address.

Separately, cookies may be set by embedded third-party services at the moment you actively use them — the Google Calendar booking page when you book a consultation or class, Stripe when you pay for a class through it, or MailerLite when you join the email list.

Our own web analytics from Vercel remains cookieless and aggregated, and runs whether or not you accept.

Changing your mind: select "Cookie Settings" at the bottom of any page to change your choice at any time. You can also control or delete cookies through your browser settings. Disabling cookies may affect the booking and payment features.

If you believe that our processing of your personal data violates the GDPR, you have the right to lodge a complaint with a data protection supervisory authority — in particular, the supervisory authority in the EU member state of your habitual residence, place of work, or place of the alleged infringement.

A directory of all EU/EEA supervisory authorities is available from the European Data Protection Board.

We may update this privacy policy from time to time. When we do, we will update the "Last reviewed" date at the top of this page. We encourage you to review this policy periodically. Continued use of this website after any changes constitutes your acceptance of the updated policy.