Last updated: 3rd May 2020
1. Reasons For Data Collection
In order for the Services to work effectively and to constantly improve, we will be collecting different kinds of information from you. These pieces of information will enable us to:
- Administer the Services;
- Help us understand how to improve and optimise the Service in future updates;
- Customise the Services to your interests and needs;
- Identify you or reply to you if you contact us with Feedback, comments or concerns;
- Provide you with more information if we think it necessary;
2. Personal Data That We Collect
When you interact with our Website or Email notifications, we collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”).
Personal Data You Give Us. When you sign up for or use the Services, you voluntarily give us certain Personal Data, including your name, email address, password and channel from where you found us, e.g. Facebook, Friend, etc... Other kinds of information provided to us by you consist in: (a) the type contents or interests you desire (e.g. Business, Culture, Traveling, etc.) and subsequent amendments, (b) information concerning your language of preference, (c) information that may help us reply to your Feedback, (d) information collected after a content is completed, (e) comments or concerns if you send us as an e-mail. We may request other type of contact data such as billing address, mailing address, and telephone numbers.
If you register for an account through your social media account (including Facebook and Google Sign-in), you may see which of your friends are using the Services. The information we get from these accounts depends on your settings and the privacy policies of the social media platforms, so please check those policies to understand the privacy practices of those platforms.
If you buy a Linguapp subscription, you may be asked to provide payment information (including payment card number, security code associated with the card, expiry date), to one or more of our payment service providers (please see “Sharing and Disclosure” section below).
When you use the Services, you generate such as feedback data (answering questions after content completion), progress, account settings, reasons of changing account settings or referrals which we will collect and store for use in connection with the Services. In addition, we may collect Personal Data disclosed by you on our forums, blogs and our other areas of the Services to which you can post information and materials.
We may also collect non-Personal Data, such as your time zone or language.
Automatically Collected Data: When you use the Services, the following information is created and automatically logged in our systems:
- Log data: Information (“log data”) that your browser automatically sends whenever you visit the Website, or that the Apps automatically send when you use them. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Website), browser type and settings, the date and time of your request, and how you interacted with the Services.
- Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.
- Usage Information: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, the other users you interact with and the time, frequency and duration of your activities.
3. How We Use Data
We use the data we collect, described above:
- To authenticate users, provide the Services, process transactions and respond to your requests. For users located within the EU, this use is necessary to perform the contract with you.
- As necessary for certain legitimate business interests, which include the following:
- To customise the learning experience and degree of difficulty to our users’ level and needs.
- To better understand how visitors interact with our Website and Email notifications and ensure that our Website and Email notifications is presented in the most effective manner for you, and as part of our efforts to keep our Website and Email notifications, network and information systems secure.
- To conduct analytics to inform our marketing strategy and enable us to enhance and personalise our communications and the experience we offer to our users.
- To conduct or assist research and prepare scholarly papers. We may share the information we collect in anonymised and de-identified form with researchers who help us to improve the Service’s learning tools. We may also use such information to publish papers on language learning.
- Marketing. We will send you updates and information about our new products and services, upcoming events or other promotions or news by email or push notification. Where required by law, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving such emails by following the instructions contained in each promotional email we send you or by updating your user settings. We will continue to contact you via email regarding the provision of our Services and to respond to your requests.
If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, we will keep basic data to identify you and prevent further unwanted processing.
We may anonymise, de-identify and/or aggregate the information that we collect and use such anonymised, de-identified and/or aggregated data for commercial, statistical and market research purposes, including sharing it with affiliates and business partners.
For information on your rights under the applicable European Union (“EU”.) law, please see the “Rights under EU Law” section below.
4. Sharing And Disclosure
We may share your Personal Data and other information with certain third parties in the following circumstances:
- Legal Requirements: Regardless of any choice you may make regarding your personal information disclosure, the Service may decide to disclose your personal information if it deems it necessary in good faith, in the following circumstances: (a) in connection with legal investigations, (b) to comply with relevant law, (c) to protect copyright, trademark or other property rights of the Service or third parties, or (d) to assist or prevent some kind of potential violation of the law. In this instance, if we believe that disclosing your personal information may prevent you from violating a relevant law, or may protect the rights, property, and safety of us, our users, or others, we may disclose them without giving you prior notice.
Finally we may also disclose some information that does not identify you personally and individually, for instance for statistical purposes or to understand usage trends or problems. We therefore reserve the right to use anonymous data for any purpose and disclose anonymous information to third parties in our sole discretion.
5. Data Retention
6. Update Your Information
If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may do so yourself via your user settings.
7. California Privacy Disclosures
If you would like to request information about third parties that collect Personal Data on our site for direct marketing purposes please contact us to firstname.lastname@example.org.
8. Rights Under EU Law
Scope. This section provides information on your rights under EU law (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway).
Data Controller. Linguapp Limited is the data controller for your Personal Data incorporated in England and Wales with registered number 11570634.
- Your Rights. Subject to EU law, you have the following rights in relation to your Personal Data:
- Right of access: If we are processing your Personal Data you can access to that Personal Data from the "Profile" box on "My Settings" or "Settings" page.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. You can also do this yourself via your user settings. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure: You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). You can also do this yourself via your user settings. If we shared your data with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest (described under the “How We Use Data” section above) to process your Personal Data -- unless we demonstrate compelling legitimate grounds for the processing; or
- If we are processing your Personal Data for direct marketing.
- Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorised to hear those concerns.
You may contact us to email@example.com to exercise your rights.
9. Publicly Posted Information
Linguapp does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Linguapp through the Services please contact us and we will endeavour to delete that information from our databases.
11. International Transfers
Information we collect may be transferred to, stored and/or processed in any country or territory where one or more of our partners or third party service providers (for example, our hosting company) are located or maintain facilities, including destinations outside the European Economic Area (“EEA”). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
12. Links to Other Websites
The security of your personal information is important to us. We will make all reasonable endeavours to prevent the loss, misuse or alteration of your personal information. Linguapp is not responsible for any leak or disclosure of information due to user error or third party accessing Linguapp. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. We cannot guarantee the security of your data and we will notify in case of security breach. We will retain your information for as long as your account is active or as needed to provide you services via the Website or our Services. Once your account has been deleted, we will only retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer hold your personal information, contact us at firstname.lastname@example.org.
15. Contacting You
We may contact you from time to time about Linguapp, including marketing messages relating to Linguapp. We will do this electronically, for example by email.We may contact you with information about our products and services and those of specially selected parties that may be of interest to you, in line with your marketing contact preferences provided to us either through the Website or by emailing us. All such communications will come from Linguapp. You may tell us at any time if you do not wish to receive marketing messages from us by contacting us at the email below or by following any instructions we may include in the messages we send to you.
17. Contact Us