Privacy Policy

Last update: May 15th, 2018

The Short Version

Your data belongs to you and not to us. We don’t resell or re-use data from our users or data extracted from your integrations.

Keeping your data safe is our highest priority and we take extended measurements to guarantee data security. You can find detailed information on how we secure your data in our Data Security Statement.

The Long Version (hereinafter “FEEDBACKPANDA”) is a service operated by SureSwift Capital, Inc. (hereinafter “THE SERVICE PROVIDER”). THE SERVICE PROVIDER undertakes to protect the Personal Data of its Clients. This Privacy Policy is part of the Terms of Service. Each word defined in the Terms of Service shall have the same meaning as in the Terms of Service.

By visiting or registering to FEEDBACKPANDA on the website or any subdomain, the Client acknowledges to comply with the Privacy Policy, which may be amended from time to time without prior notice. Any modification or update shall be uploaded on the website or FeedbackPanda application.

1. Collected Data

While registering to and using FEEDBACKPANDA, THE SERVICE PROVIDER collects, on a voluntary basis, from the Client a limited number of data, including Personal Data, which is solely for the performance of FEEDBACKPANDA and used in connection with FEEDBACKPANDA.

The Client may therefore be required to provide the following information:

  • First name
  • Last name
  • Email address
  • Phone
  • Company name
  • Company billing address
  • Company tax identification number (VAT number for European based Clients).

In addition, thereto, THE SERVICE PROVIDER may collect data concerning the Client’s preferences or behavior on the website and the FeedbackPanda application (what pages the Client visits, surveys, etc.).

While using FEEDBACKPANDA, the Client typically imports ESL classroom data through our application, by email, via our API or a third party integration partner. Imported data will then be processed and feedback data is generated.

2. Usage of Data

The purpose of data collection within FEEDBACKPANDA is to enhance the Client experience. We will retain any Data you submit for as long as FEEDBACKPANDA deems it necessary to provide adequate service to the User, unless explicitly asked by a User for their Data to be deleted.

The Client has a permanent right to access, amend or delete any information related to him/her/it by sending an email to

All data provided by the Client, including Personal Data, Imported Data and Generated Content will not be freely given to anyone. We do not, under any circumstances, sell either your Personal Data or your Data.

If someone originating from your account account holder or someone contacted via FEEDBACKPANDA at the User’s discretion playing role of “Client” complains or contacts us, we might then contact that person.

THE SERVICE PROVIDER does not collect any personal data that reveals, directly or indirectly, the racial and ethnic origins, the political, philosophical, religious opinions or trade union affiliation of persons, or information which concerns the health or sexual life of any person. Such sensible data shall not be sent, processed or stored through FEEDBACKPANDA.

For purposes of the Data Protection Act 1998 and GDPR, FEEDBACKPANDA acts as the “data controller” for Personal Data and acts as the “data processor” for Imported Data and Generated Content.

All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998 and the European Union’s General Data Protection Regulation. For more details on these two security regulations see the clause below (Security).

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Personal Data may be used by us for the following reasons:

  • internal record keeping;
  • improvement of our products / services;
  • transmission by email of promotional materials that may be of interest to you;
  • transmission to 3rd parties in order for them to market relevant promotional materials that may be of interest to you;
  • The ability to make automated decision making, including profiling, only for the purpose of offering a better and more personalized experience for the User or
  • marketing to new users based on information from the users of FEEDBACKPANDA in aggregate;

in each case, in accordance with this privacy policy.

3. Third party websites and services

FEEDBACKPANDA may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. THE SERVICE PROVIDERs of such services have access to certain Personal Data provided by Users of this Website and may be located in various locations throughout the world.

Unless we specifically say otherwise, your Data will never be intentionally disclosed to third parties for the sake of administering better service, but never for marketing purposes through various affiliates and / or other companies within our group.

Any Personal Data used by such parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with the Data Protection Act 1998 and GDPR.

Additionally, Data can be transmitted to 3rd parties for relevant marketing purposes at the sole discretion of those employed by THE SERVICE PROVIDER and FEEDBACKPANDA.

If requested by law or by court order, THE SERVICE PROVIDER may provide the Personal Data to the legal authorities.

4. Links to other websites

FEEDBACKPANDA and all its websites may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

5. Controlling use of your Data

Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:

  • use of Data for direct or indirect marketing purposes; and
  • You have the right to ask for a copy of any of your personal Data held by FEEDBACKPANDA.
  • You have the right to withdraw consent necessary to use the services provided by FEEDBACKPANDA at any time.
  • You have the right for your data to be deleted from the servers and databases of FEEDBACKPANDA.

6. Security

THE SERVICE PROVIDER takes data security very seriously and its system is compliant with the latest web security standards. FEEDBACKPANDA uses full SSL encryption, between its server and the Client once the latter is logged in and for the transfer to the Client. The login system is protected against brute­force attacks, injection of malicious scripts and other commonly known attack types. The access to FEEDBACKPANDA or to the Client’s Account and thus to the processed data is only possible through a valid password. The passwords are stored encrypted hash keys in the database and not visible to the staff of THE SERVICE PROVIDER.

FeedbackPanda Solution is running on the Amazon Webservices Cloud, which datacenter is located in North Carolina, USA. All servers are always up­to­date with the latest security releases. A full backup is made on a daily basis and all data is constantly stored on different hard­drives to prevent data loss in case of a hardware failure. Personal data pertaining to the Clients will be deleted at the latest two (2) months after the closing or deletion of the Client’s Account.

Only authorized employees have access to view Personal Data, Imported Data and Generated Content.

If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.

We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not always perfectly secure and is done at your own risk. We cannot ensure the security of your Data transmitted to FEEDBACKPANDA.

7. Cookies

This Website may place and access certain Cookies on your computer. FEEDBACKPANDA uses Cookies to improve your experience of using the Website and to improve our range of products and services.

FEEDBACKPANDA has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling THE SERVICE PROVIDER to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

This Website may place the following Cookies:

  • FeedbackPanda Cookie The FeedbackPanda cookies are used to identify you as a Client and track how you found our service.
  • Google Analytics The Google Analytics cookies are used to aggregate anonymized website visitor statistics.

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

8. Communication by THE SERVICE PROVIDER

THE SERVICE PROVIDER may send emails to the Client for technical or administrative purposes or to inform the Client of the latest development of FEEDBACKPANDA. THE SERVICE PROVIDER may also send unrelated commercial offers to the Client but in relation with the activity of the Client.

9. General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

The Privacy Policy is governed by and interpreted according to the laws of Canada. Any dispute, controversy or claim arising under, out of or relating to the validity, interpretation and performance of this Privacy Policy shall be referred to and finally determined by the competent courts of the Province of British Columbia and British Columbia law shall apply.

For any questions or concerns relating to the use of your User Data while using FEEDBACKPANDA, you are welcome to contact the THE SERVICE PROVIDER’s chosen Data Protection Officer who can be reached by sending an email to

Every user of FEEDBACKPANDA has a variety of rights relating to the use of their data while using FEEDBACKPANDA, including the right to lodge a complaint with a supervisory authority.

10. Changes of business ownership and control

THE SERVICE PROVIDER may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of FEEDBACKPANDA. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us. We may also disclose Data to a prospective purchaser of our business or any part of it. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

11. Changes to this privacy policy

THE SERVICE PROVIDER reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact THE SERVICE PROVIDER by email at