Privacy Policy
This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your Personal Data when you use the Service and tells you about your privacy rights.
Please read this Privacy Policy carefully to understand how we use your Personal Data, including any additional disclosures relevant to the country, region or state you are in:
- If you are in California, please refer to the additional disclosures set out in the CCPA Privacy section below.
- If you are in the European Economic Area or United Kingdom, please refer to the additional disclosures set out in the European Privacy section below.
Contact Us
If you have any questions about this Privacy Policy, you can contact us by email at: support@tavumi.app
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
- Account means a unique account created for you to access our Service or parts of our Service.
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- App Store Account means your account on the Apple App Store or Google Play Store.
- Application or Service means the software program provided by the Company, named Tavumi, together with our websites.
- Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' Personal Data and determines the purposes and means of the processing of Consumers' Personal Data, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' Personal Data, that does business in the State of California.
- Company (referred to as either the "Company", "we", "us" or "our" in this Agreement) refers to Lumenfield LLC, 30 N Gould St, Ste R, Sheridan, WY 82801.
- Consumer, for the purpose of the CCPA, means a natural person who is a California resident.
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
- Personal Data is any information that relates to an identified or identifiable individual.
- Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal Data to another business or a third party for monetary or other valuable consideration.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- You means the individual accessing or using the Service.
Collecting and Using your Personal Data
Types of Data Collected
We collect Personal Data that you provide to Us when you set up an Account and use our Service. Like most online service providers, we also collect certain Usage Data about how you use our Service in order to understand how the Service is used and how we can improve it.
The categories of Personal Data we collect and how we use them will depend on how you interact with Us, as set out in more detail below.
If you are in California, further information about the Personal Data we collect and how we use it is set out in the CCPA Privacy section below.
If you are in the European Economic Area or United Kingdom, further information about the Personal Data we collect, how we use it and the lawful basis we rely on is set out in the European Privacy section below.
Personal Data that you provide to us
If you contact us about our Service, we will collect the following Personal Data:
- Contact details (including your name and email address);
- The subject matter and content of your enquiry or any other correspondence between you and us.
When you use our Service, we may collect the following Personal Data:
- Your email address;
- Your password, which is stored only in hashed form;
- Profile information, such as your name and the interests you tell us about;
- Language learning information, such as your native language, the language you are learning, your learning goals and priorities, and your current proficiency level;
- Subscription information, such as the start date and duration of the subscription to the Service that you purchase and any free trial periods;
- Purchase information, namely confirmation that you have purchased a subscription to the Service, together with the plan, amount, currency, payment status and the last four digits and country of your payment card;
- Audio recordings of language lessons that you upload to the Service, and the transcripts and analyses generated from them;
- Transcripts of your conversations with the AI tutor on the Service;
- Your vocabulary, lesson plan and progress, including the words you save, your answers to exercises and your review schedule;
- Your preferences, such as the preferences you set for push notifications, app interface language and email communications.
Information about how you use the Service
Usage Data is collected automatically when you use the Service.
Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We use the above Personal Data to present the Service to you on your device, monitor and improve the performance of the Service (such as identifying, diagnosing and fixing errors), including monitoring aggregate metrics such as total number of visitors, traffic, usage and usage patterns on our Service. We also use this information to measure the effectiveness of, and improve our online advertising campaigns, as further described in the "Behavioral Advertising" section below.
If you are in the European Economic Area or United Kingdom, other than where our use of Usage Data is strictly necessary to provide the Service or a certain feature or functionality of the Service, we will only collect Usage Data to the extent you give us your consent to do so.
Information from your Google or Apple account
We allow you to create an account and log in to use the Service through your Google or Apple account. When you do so, we may receive information associated with that account, such as your name, email address and whether that email address has been verified by the provider. We do not receive your password for those accounts.
Information from your App Store Account
If you subscribe through an App Store Account, we may receive information associated with your App Store Account, such as confirmation of your purchase and its status.
Use of your Personal Data
The Company may use Personal Data for the following purposes:
- To provide our Service, including to provide the features and functionalities of the Service and tailor the Service to individual users.
- To transcribe and analyze the lesson recordings you upload, in order to generate vocabulary, exercises and lesson materials for you.
- To manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
- To contact you: To contact you by email or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable for their implementation.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about in accordance with your preferences.
- To manage your requests: To attend and manage your requests to us.
- To measure the effectiveness of, and improve our online advertising campaigns: We work with third party advertising partners to serve ads online in relation to our Service. We may use your information, such as whether you have started the Service and purchased a subscription, as further described in the Behavioral Advertising section below.
- For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
- To analyze the performance of and improve the Service: We may use your information to monitor the performance of our Service, conduct data analysis to identify usage trends, and to evaluate and improve our Service, products, services, marketing and your experience.
Retention of your Personal Data
The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
In addition, the following retention periods apply:
- Audio recordings of lessons are deleted once they have been transcribed and analyzed.
- Transcripts of lessons are retained for 12 months.
- Transcripts of conversations with the AI tutor are retained for 12 months.
- Your vocabulary, lesson plan, progress and lesson analyses are retained for as long as your Account exists.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Data.
If you are in the European Economic Area or United Kingdom, further information about how we may transfer Personal Data to recipients outside the jurisdiction you are in is set out in the European Privacy section below.
Disclosure of your Personal Data
We may share your Personal Data in the following situations:
- With Service Providers: We may share your Personal Data with Service Providers to host the Service and store your content, to transcribe and analyze your recordings and generate learning materials, to monitor and analyze the use of our Service, for payment processing, to send emails, and to advertise on third party websites to you after you visited our Service.
- For business transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company. If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
- With advertising optimisation partners: We may share certain Personal Data, such as whether you have started the Service or purchased a subscription, with online advertising partners in order to measure the effectiveness of, and improve, our online advertising campaigns.
- With law enforcement or for legal reasons: Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). The Company may also disclose your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
- With your consent: We may disclose your Personal Data for any other purpose with your consent.
If you are in the European Economic Area or United Kingdom, further information about how we may disclose your Personal Data is set out in the European Privacy section below.
Security of your Personal Data
The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Email Marketing
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
Payments
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Data is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Stripe
Their Privacy Policy can be viewed at https://stripe.com/privacy
Apple Store In-App Payments
Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/
Google Play In-App Payments
Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/
Behavioral Advertising
We and our third-party advertising partners use Personal Data about your use of the Service to measure and optimise the performance of our online advertising campaigns. We and our third-party vendors use cookies and other trackers (such as mobile SDKs) to:
- recognise your Device and identify whether you have started our Service or subscribed to it after viewing an advert for the Service on another platform or website; and
- identify and develop audiences of individuals with similar interests that may be interested in our Service so that we can serve them advertisements for our Service on other platforms and websites.
We may share information, such as hashed email addresses (if available) or other online identifiers collected on our Service with these third-party vendors. This allows our third-party vendors to recognize and deliver you ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.
The third-party vendors we use for these purposes are:
Google Ads
Google Ads remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: https://adssettings.google.com/
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Meta (Facebook and Instagram)
Meta remarketing service is provided by Meta Platforms, Inc.
You can learn more about interest-based advertising from Meta by visiting this page: https://www.facebook.com/help/516147308587266. To opt-out from Meta's interest-based ads, follow these instructions: https://www.facebook.com/help/568137493302217
You can also opt-out from Meta and other participating companies through the Digital Advertising Alliance in the USA https://optout.aboutads.info/, the Digital Advertising Alliance of Canada in Canada https://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe https://youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Meta, please visit: https://www.facebook.com/privacy/policy
Google Ads. Google Ads is an advertising service provided by Google LLC. We use the Google tag to measure conversions and to show interest-based ads. You can opt out of personalized advertising by Google at https://adssettings.google.com/ and learn more at https://policies.google.com/technologies/ads.
TikTok for Business. TikTok for Business is an advertising service provided by TikTok Pte. Ltd. and its affiliates. We use the TikTok Pixel to measure conversions and to show interest-based ads. You can learn more at https://www.tiktok.com/legal/page/global/privacy-policy/en and manage ad personalization in your TikTok settings.
We may test other advertising networks from time to time; any such vendor receives only the categories of Personal Data described in this section, under the same purposes and safeguards, and will be listed here before it is used.
Your Privacy Choices
Modifying or deleting your Personal Data
You can view, update or delete certain information by accessing and updating your profile page on the Application. If you have any questions about reviewing, modifying or deleting your Personal Data, you can contact us using the details set out in the "Contact Us" section above.
Behavioral advertising preferences
You may be able to exercise control by leveraging one or more targeted advertising opt-out programs including:
- Device-Specific Opt-Out Programs: You may also opt-out of all personalized advertising by enabling privacy features on your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See your mobile device Help system for more information.
- Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.aboutads.info/ for browser-based advertising and https://youradchoices.com/appchoices for app-based advertising.
- European Interactive Digital Advertising Alliance: Please follow the instructions at https://www.youronlinechoices.eu to opt out of browser-based targeted advertising carried out by third parties that participate in their program.
- Network Advertising Initiative: Please follow the instructions at https://optout.networkadvertising.org/ to opt out of browser-based targeted advertising carried out by third parties that participate in their self-regulatory program.
- Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform. Please refer to your platform provider's user guides for additional information.
Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us. Instead, it means that the online ads you do see from relevant program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties' opt-out options or programs or the accuracy of their statements regarding their programs.
Users in the European Economic Area, United Kingdom and California
If you are in the EEA, UK or California, you have certain rights in relation to the Personal Data we process as further set out in the CCPA Privacy and European Privacy sections below. These sections also set out how you can control certain ways in which Personal Data is collected from your Device automatically and how it is used.
Links to Other Websites
Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
CCPA Privacy
This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of Personal Data which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected.
Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Collected: Yes.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, address, telephone number, or any other financial information. Some Personal Data included in this category may overlap with other categories.
Collected: Yes.
Category C: Protected classification characteristics under California or federal law.
Examples: Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information.
Collected: Yes.
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: Yes.
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints.
Collected: No. We process voice recordings of lessons to transcribe them, but we do not extract voiceprints or any other biometric identifiers from them.
Category F: Internet or other similar network activity.
Examples: Interaction with our Service or advertisement.
Collected: Yes.
Category G: Geolocation data.
Examples: Approximate physical location.
Collected: Yes.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: Yes.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No.
Category J: Non-public education information.
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf.
Collected: No.
Category K: Inferences drawn from other Personal Data.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: Yes.
Under CCPA, Personal Data does not include:
- Publicly available information
- Deidentified or aggregated consumer information
Sources of Personal Information
We obtain the categories of Personal Data listed above from the following categories of sources:
- Directly from you. For example, from the forms you complete on our Service, preferences you express or provide through our Service, the recordings you upload, or from your purchases on our Service.
- Indirectly from you. For example, from observing your activity on our Service.
- Automatically from you. For example, through cookies we or our Service Providers set on your Device as you navigate through our Service.
- From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to deliver targeted advertising to you, third-party vendors for payment processing, or other third-party vendors that we use to provide the Service to you.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose Personal Data we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:
- To operate our Service and provide you with our Service.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Service.
- To fulfill or meet the reason you provided the information.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Data or as otherwise set forth in the CCPA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Data for business or commercial purposes:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute
- Category D: Commercial information
- Category F: Internet or other similar network activity
- Category H: Sensory data
When we disclose Personal Data for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.
Sale of Personal Information
As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Data by the business to a third party for valuable consideration.
We do not sell Personal Data for money. However, our use of advertising partners (Google, Meta, TikTok and other networks we may test) may be considered a "sale" or "sharing" of Personal Data under the CCPA. We may therefore sell or share the following categories of Personal Data: Category A (Identifiers), Category B (Personal information categories listed in the California Customer Records statute), Category D (Commercial information) and Category F (Internet or other similar network activity). You may opt out of the sale or sharing of your Personal Data as described in the "Your Rights under the CCPA" section below.
Share of Personal Information
We may share your Personal Data identified in the above categories with the following categories of third parties:
- Service Providers
- Payment processors
- Our business partners
- Third party vendors to whom you or your agents authorize us to disclose your Personal Data in connection with products or services we provide to you
Sale of Personal Information of Minors Under 16 Years of Age
We do not knowingly collect Personal Data from minors under the age of 16 through our Service. We do not sell the Personal Data of Consumers we actually know are less than 16 years of age.
If you have reason to believe that a child under the age of 13 (or 16) has provided us with Personal Data, please contact us with sufficient detail to enable us to delete that information.
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their Personal Data. If you are a resident of California, you have the following rights:
- The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to know. Under CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of Personal Data.
- The right to say no to the sale of Personal Data (opt-out). You have the right to direct us to not sell your Personal Data.
- The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to complete a transaction, detect security incidents, debug products, comply with a legal obligation, or make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights.
Exercising your CCPA Data Protection Rights
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us by email: support@tavumi.app
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Data.
Your request to us must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it
We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked.
Children's Privacy
Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.
European Privacy
Who is responsible for your Personal Data
Lumenfield LLC is the controller of the Personal Data that we hold and use as set out in this Privacy Policy. This means that we determine and are responsible for how your Personal Data is used.
If you would like to contact us, you can do so by email to: support@tavumi.app
Optional and mandatory information
When we ask you to provide Personal Data, we will indicate to you if the provision of certain Personal Data is mandatory or optional. If you choose not to provide any Personal Data marked as mandatory, we may not be able to respond to your queries or provide you with certain features and functionalities of our Service.
Additional information about Personal Data we collect and how we use it
Personal Data that you provide to us when you contact us about our Service
| Personal Data | How we may use it | Lawful basis we rely on |
|---|---|---|
| Your contact details (including your name and email address) | We use this to communicate with you and respond to your enquiries. | The processing is necessary for our legitimate interests, namely to communicate with users of our Service and prospective customers. |
| Comments and enquiries that you submit to us. | We use this to communicate with you and respond to your enquiries and provide customer or technical support. | The processing is necessary for our legitimate interests, namely to communicate with users of our Service and prospective customers. |
Personal Data that you provide to us when you use our Service
| Personal Data | How we may use it | Lawful basis we rely on |
|---|---|---|
| Language learning information, such as your native language, the language you are learning, your goals and priorities and your current proficiency level. | We use this information to tailor the curriculum, lessons, feedback, prompts and hints provided to you through the Service. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). |
| Profile information that you provide when you set up your Account, namely your name and your interests. | We use this information to set up your Account on the Service and tailor the content provided to you through the Service to your interests. | The processing is necessary for our legitimate interests, namely tailoring the Service to your interests. |
| Your email address and password. | We use these to create your Account, authenticate you when you sign in and allow you to reset your password. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). |
| Your email address. | We use this information to send you service-related communications, such as renewal reminders and purchase confirmations. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). |
| We use this information to send you promotional emails in accordance with your preferences. | The processing is necessary for our legitimate interests, namely promoting the features and functionalities of our Service to our users. | |
| Subscription information, such as the start date and duration of the subscription to the Service that you purchase and any free trial periods. | We use this information to manage subscriptions and grant you access to the paid features of the Service. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). |
| Purchase information, namely confirmation that you have purchased a subscription, the plan, amount, currency and payment status. | We use this information to grant you access to the paid features of the Service, to issue receipts and to keep accounting records. | The processing is necessary for the performance of a contract with you, and for compliance with a legal obligation to which we are subject. |
| Audio recordings of lessons that you upload, and the transcripts and analyses generated from them. | We transcribe and analyse this information to extract vocabulary, identify your mistakes and topics, and generate lesson materials and exercises for you. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). |
| Transcripts of your conversations with the AI tutor. | We analyse this information to provide you with the language learning functionality of the Service, including assessing your grammar and vocabulary to provide feedback and points for development, and to allow you to revisit past conversations. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). |
| Your vocabulary, lesson plan and progress. | We use this information to provide you with the language learning functionality of the Service and to schedule your reviews. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). |
| Push notification settings, namely whether you have agreed to receive push notifications from us. | We use this to serve push notifications from our Service in accordance with your preferences. | The processing is necessary for our legitimate interests, namely providing notifications in accordance with user preferences. |
| Email preferences, such as whether you agree to receive promotional emails from us. | We use this information to send you updates about us and our Service only in accordance with your preferences. | The processing is necessary to comply with a legal obligation to which we are subject. |
| Language preferences, such as the language in which the Service is displayed to you. | We use this information to present the Service to you in accordance with your language preferences. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). |
Personal Data we collect automatically
| Personal Data | How we use it | Legal basis we rely on |
|---|---|---|
| Information about your device and network, such as device type, manufacturer, model, operating system, IP address, browser type and unique identifiers associated with your device or your network. | We use this information to operate the Service and present it to you in the correct format for your device. | The processing is necessary for the performance of a contract with you. |
| Information about how you use the Service, such as the time you access the Service and how long you access it for, the approximate location that you access the Service from, the site from which you came, the pages you visit, the links you click and other actions you take on the Service. | We use this information to operate the Service and present it to you in the correct format for your device. | The processing is necessary for the performance of a contract with you. |
| We use this information to identify and prevent suspicious or fraudulent use of our Service. | The processing is necessary for our legitimate interests, namely ensuring the security of our Service. | |
| We use this information to analyse the performance of the Service to identify errors and ways in which we can improve the Service. | We will only use your Personal Data in this way if you have given us your consent to do so. | |
| We and our advertising partners use this information as further described in the "Behavioral Advertising" section to measure the effectiveness of, and improve our online advertising campaigns. | We will only use your Personal Data in this way if you have given us your consent to do so. |
Additional information about how we share Personal Data
| How we may share Personal Data | Lawful basis we rely on |
|---|---|
| Service providers, such as providers of web hosting, file storage, artificial intelligence processing, speech synthesis, email delivery, payment processing or analytics services. | These service providers will use your Personal Data as processors on our instructions. |
| Advisors, such as legal advisors or accountants. | The lawful basis we rely on for these transfers is that the processing is necessary for our legitimate interests, namely obtaining legal, accounting and other professional advice. |
| Advertising partners. We work with third-party ad networks and advertising partners to measure the effectiveness of, and improve our online advertising campaigns on other websites and services. | We will only share your Personal Data with these recipients to the extent you give us your consent to do so. |
| Purchasers and third parties in connection with a business transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business. | The lawful basis we rely on for these transfers is that they are necessary for our and the purchaser's legitimate interests, namely to conduct due diligence on our business and assets in connection with a potential acquisition. |
| Law enforcement, regulators and other parties for legal reasons. | The lawful basis we rely on for sharing Personal Data with these recipients is that the processing is either necessary to comply with a legal obligation to which we are subject or, where there is no applicable legal obligation to share this data, that the sharing is necessary for our legitimate interests, namely enforcing our rights or complying with requests from regulatory authorities. |
International transfers
The Personal Data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. We will ensure that these international transfers of your Personal Data are made pursuant to appropriate safeguards, such as:
- ensuring that the Personal Data is only transferred to countries or recipients recognised by the UK Secretary of State or the European Commission (as applicable) as offering an equivalent level of protection as compared to the level of protection in the country you are located ("Adequacy"); or
- the transfer is to a third party who uses appropriate safeguards in respect of the processing in question, including but not limited to the UK or EU standard contractual clauses ("Standard Contractual Clauses").
We may transfer your Personal Data to, or store your Personal Data in, the following countries:
| Country | Appropriate Safeguard |
|---|---|
| United States | Standard Contractual Clauses; Adequacy (for recipients certified to the EU-U.S. Data Privacy Framework and UK Extension) |
| European Economic Area | Adequacy (UK) |
We will take appropriate steps to ensure that your Personal Data is treated securely and in accordance with applicable law and this privacy notice regardless of where it is processed.
If you wish to enquire further about the safeguards we use, please contact us using the details set out at the top of this privacy notice.
Automatic data collection
Other than Personal Data that is required to operate the Service or provide you with a functionality you have requested, we will only collect information about your use of the Service automatically through cookies and similar tracking technologies to the extent you give us your consent to do so. You can change your preferences any time by updating your settings on your profile page in the Application.
Privacy rights
If you are resident in the UK or EEA, in accordance with applicable privacy law you have the following rights in respect of your Personal Data that we hold:
- Right of access. You have the right to obtain:
- confirmation of whether, and where, we are processing your Personal Data;
- information about the categories of Personal Data we are processing, the purposes for which we process your Personal Data and information as to how we determine applicable retention periods;
- information about the categories of recipients with whom we may share your Personal Data; and
- a copy of the Personal Data we hold about you.
- Right of portability. You have the right, in certain circumstances, to receive a copy of the Personal Data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Data to another person.
- Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete Personal Data we hold about you without undue delay.
- Right to erasure. You have the right, in some circumstances, to require us to erase your Personal Data without undue delay if the continued processing of that Personal Data is not justified.
- Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified.
- Right to withdraw consent. Where we rely on your consent for processing your Personal Data, you have the right to withdraw your consent. Withdrawal of your consent will not affect the lawfulness of the processing of your Personal Data before you withdrew your consent.
You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your Personal Data despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
If you wish to exercise one of these rights, please contact us using the contact details at the top of this privacy notice.
We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive, in which case we may charge you a reasonable fee to cover our administrative costs.
We may ask you to provide certain information to confirm your identity in order to process your request.
Privacy wrongs
You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, your local data protection authority is the Information Commissioner's Office, which can be contacted using the details at https://ico.org.uk/global/contact-us/. If you are in the European Economic Area, you can find your local Data Protection Authority at https://www.edpb.europa.eu/about-edpb/our-members_en