Privacy Policy 

This privacy policy ("Privacy Policy") explains how information about you is collected, used and disclosed by us. This Privacy Policy applies to information we collect when (i) you access to and use of our Sites, (ii) your access to and use of our Applications, or (iii) your access to and use of our services that link to or reference our lingotalk Terms. The Site, Application and other lingotalk services together are hereinafter collectively referred to as the "lingotalk Platform". The Privacy Policy is intended to meet our duties of transparency under the "General Data Protection Regulation" or "GDPR".

Modifications

Because we are always looking for new and innovative ways to help you achieve your goals in connection with the use of our lingotalk Platform, this Privacy Policy may change over time, so please review it frequently. The effective date at the top indicates the last time this Privacy Policy was modified. If we are required by applicable data protection laws to give you enhanced notice or seek your consent for any such changes, we will do so. You can see when this policy was last updated by checking the "last updated" date displayed at the top of this policy. Any revised Privacy Policy will supersede all previous privacy policies.

Table of Contents

1. How We Collect Information
2. Information We Collect That You Choose To Provide To Us
3. What Information We Collect Automatically When You Use the lingotalk Platform
4. Information Provided to Us by Third Parties
5. How We Use Your Information
6. What Kinds of Information We Share
7. Ways You Might Share Your Information through the lingotalk Platform
8. How We Keep Your Information Safe
9. Where We Store Your Information
10. Our Policies Regarding Children
11. Your Choices and Controls
12. How We Respond to Do Not Track Signals
13. Contact Us
14. Right to Contact a Data Protection Authority

1. How We Collect Information

We collect information: (i) that you choose to provide to us; and (ii) automatically through your use of the lingotalk Platform. If you are a resident of the European Economic Area (the "EEA"), we rely on one of the following legal grounds to process information about you: (i) where we have your consent, (ii) where we have a legitimate interest to do so, (iii) where the processing is necessary for the performance of a contract with you, and (iv) where we need to comply with a legal or regulatory obligation.

2. Information We Collect That You Choose To Provide To Us

We collect information that you choose to provide to us, for example, when you create an account, manage your user profile, participate in any interactive features of the lingotalk Platform, request our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support or otherwise communicate with us. The type of information we may collect includes your name, user name, country, telephone number, email address, postal address, photograph, avatar, password, security questions and answers, details about our products you use, details you provide in respond to surveys about our products, information you provide when seeking help from us, billing information, payment card number and account details, forum posts and comments and other contact or identifying information you choose to provide directly.

For your information, the Company has collected, both directly and through third parties, the following categories of personal information about consumers during the preceding twelve (12) month period:

• Identifiers, such as a real name, postal address, Internet Protocol address, account name, or other similar identifier;
• Audio, electronic, visual, thermal, olfactory, or other similar information of a living person;
• Professional or employment-related information; and
• Education information;

3. What Information We Collect Automatically When You Use the lingotalk Platform

We automatically collect information about you including:

Device Information. We collect device-specific information when you access the lingotalk Platform from a computer, mobile, and/or other device, including your hardware model, operating system and version, unique device identifiers, mobile network information, country of access, crash reports, request and referral URL’s and system activity details.

Software Information. We collect software-specific information about your use of the lingotalk Platform, such as which version of our software and what updates you have installed or use, and the presence of required plug ins.

Use Information. We collect information about your use of the lingotalk Platform, including the type of browser you use, the language you prefer, access times, pages viewed, user activity, interactions with other users, your internet protocol address and the page you visited before navigating to the lingotalk Platform.

Information Collected by Cookies and Other Tracking Technologies. We use various technologies to collect information, and this may include sending cookies, web beacons, Flash Cookies (as defined below), or other tracking technologies.

• Cookies. Cookies are small data files stored on your hard drive or in device memory that helps us to improve the lingotalk Platform and your experience, see which areas and features of the lingotalk Platform are popular and count visits. For more information about cookies, and how to disable them, please see Section 11 (Your Choices and Controls) below.
• Web Beacons. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in the lingotalk Platform or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

4. Information Provided to Us by Third Parties

In addition to the information that we collect directly from you, we also collect certain of your information from following third party sources.

App Stores or Distribution Channels. The lingotalk Platform that are distributed through app stores or distribution channels, such as the Apple App Store, Google Play and other Chinese Android app store, may also request permission to automatically collect other information from your mobile or other device. The lingotalk Platform may only collect such information with your authorization in accordance with your device operating system’s permission process.

Apple App Store. The lingotalk Platform that is distributed through the Apple App Store may also request permission to automatically collect other information from your mobile or other device. The Apple App Store may collect information regarding customer activity on the Apple App Store and aggregate that information to understand which part of Apple’s services are of most interest to you. More information on Apple’s privacy policy can be found here. We may only collect such information with your authorization in accordance with your device operating system’s permission process.

Google Play. The lingotalk Platform that are distributed through Google Play may also request permission to automatically collect other information from your mobile or other device. Google Play may collect device-specific information to help the user decide on which devices the user would like purchases to be available for use. In mobile applications, Google Play may use identifiers specific to your device to serve you more relevant advertisements. More information on Google’s privacy policy can be found here. The lingotalk Platform may only collect such information with your authorization in accordance with your device operating system’s permission process.

Mobile Platforms. If you use or access the lingotalk Platform on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information includes your username and/or device ID and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide. Our mobile products also may request additional personal information from you, such as push notification tokens, your precise location or contact list, and we will collect this information only if you give us your explicit consent.

Third Party Services and User Information. We may allow third parties to serve advertisements in connection with the lingotalk Platform, to provide analytics services and provide you with other services, such as social media, rewards programs and tournaments. These third parties may use cookies, web beacons and other technologies to collect information about you on the lingotalk Platform and other websites and online services, such as your name, profile picture, email address, your internet protocol addresses, identifiers associated with your mobile device or applications on the device, pages viewed, time spent on pages, links clicked and conversion information. Some of such third party analytics and advertising services may offer you a choice to opt-out of the collection and/or sharing of this information. This Privacy Policy does not apply to and we are not responsible for, third party cookies, web beacons or other tracking technologies. In addition, we may also receive information about you when other users choose to share their contact lists with us. For example, (i) if you create or log into your account through a social media site (such as Facebook and Wechat), we might have access to certain information from that site, such as your name, profile picture, phone number and/or email address in accordance with the authorization procedures determined by such social media site; and (ii) our services utilize the YouTube application programming interfacing services (API Services) as a third party services, and you are agreeing to be bound by the YouTube’s Terms of Service(https://www.youtube.com/t/terms) and Privacy Policy(http://www.google.com/policies/privacy), and API Services Terms of Service(https://developers.google.com/youtube/terms/api-services-terms-of-service) when engaging YouTube content and services through our service.

We have identified the provider names of some of the third-party analytics and advertising services we use. We take no responsibility for the content or privacy practices of any third party services. We encourage you to carefully review the privacy policies of any third party services you access. Please see the links below to learn more about the data practices of our third-party service providers:

• Google Analytic: google.com/analytics
• Growing.io: growing.io

5. Information You Provide Voluntarily

Lingotalk collects the following information, either directly from Lingotalk Users, Invitees, or Viewers, or through third-parties regarding Users, Invitees, or Viewers.

- Appointment Information. A Lingotalk User, Invitee, or a third-party may voluntarily give us certain information. This can include names, email addresses, and phone numbers; email addresses of other people; the subject of the meeting; and any other information provided to us or as required by the Lingotalk User upon scheduling, pursuant to the Lingotalk Terms of Use. If you receive an invitation from a Lingotalk User but do not wish to become a Lingotalk User, please contact the Lingotalk User who sent the invitation through other means to set up your meeting.

- Calendar Information. A Lingotalk User may connect their calendar with Lingotalk. Our calendar integration only checks the duration and free/busy status of the events in your calendar so that we don’t book you when you’re busy. We never store who you are meeting with, their email address, the meeting title, or any other details about the appointments in your connected calendar.

6. How We Use Your Information

We may use information about you for various purposes, including to:

• Provide, maintain and improve the lingotalk Platform;
• Provide and deliver the products and/or services you order and send you related information, including confirmations and invoices;
• Send you communications about products, services, offers, promotions, rewards or events offered by us and other companies and provide news and information we think will be of interest to you;
• Send you technical notices, updates, security alerts and support and administrative messages;
• Respond to your comments, questions, requests and provide customer service;
• Monitor and analyze trends, usage and activities in connection with the lingotalk Platform;
• Personalize and improve the lingotalk Platform and provide advertisements, content, suggested connections and features that match user profiles or activities;
• Process and deliver contest entries and rewards; and
• Link or combine with information we receive from others to help understand your needs and provide you with better service.

We retain your data only for as long as necessary to provide the service you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods: (i) mandated by law, contract or similar obligations applicable to our business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate business and financial records.

7. What Kinds of Information We Share

We will share personal information outside of the Company when we have your consent. We’ll ask for your explicit consent to share any sensitive personal information. We do not share your personal information with companies, organizations, or individuals outside of the Company except the following cases:

• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf, based on our instructions and in compliance with our Privacy Policy and other appropriate confidentiality and security measures;
• With the Teacher of lingotalk Platform in connection with providing Teaching Services to the Students;
• With other users of lingotalk Platform in connection with the social features of the lingotalk Platform (for example, your username and profile picture, you have accumulated in the lingotalk Platform that may be visible to other users of the lingotalk Platform, or information that you provide in your account registration for forum use and your forum comments may be visible to other forum users);
• In response to a request for information if we believe disclosure is required by or otherwise in accordance with any applicable law, regulation or legal process;
• To protect the rights, property and safety of the Company or others;
• Subject to applicable laws, in connection with any merger, sale of company assets or acquisition of all or a portion of our business; or
• With your consent or at your direction, including if we notify you through the lingotalk Platform that the information you provide will be shared in a particular manner and you provide such information.

For your information, the Company has disclosed to third parties or service providers for business purposes the following categories of personal information about consumers during the preceding twelve (12) month period:

• Identifiers, such as an Internet Protocol address, account name, or other similar identifier;
• Audio, electronic, visual, thermal, olfactory, or other similar information;
• Professional or employment-related information;
• Education information; and
• Consumer profiles based on inferences drawn from the information provided above.

We do not sell any personal information about consumers. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. When we provide this information, we perform appropriate procedures so that the information does not identify you and we contractually prohibit recipients of the data from re-identifying this information to associate the information with you.

8. Ways You Might Share Your Information through the lingotalk Platform

The lingotalk Platform may offer social sharing features and other integrated tools (such as the Facebook or Twitter "Like" button and WeChat "Moments" feature), which let you share actions you take on the lingotalk Platform with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide such features.

9. How We Keep Your Information Safe

We take commercially reasonable security measures to help protect information we collect about you from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. These security measures may include practices such as keeping your sensitive data on a secured server behind a firewall, and transmitting sensitive information (such as a credit card number) entered while using the lingotalk Platform using secure socket layer technology ("SSL").Unfortunately, however, no security system is 100% secure, and we cannot guarantee that the information we collect from you will be free from unauthorized access by third parties. Unauthorized entry or use, hardware or software failure and other factors may compromise the security of user information. Your password is an important component of our security system, and as a result it is your responsibility to protect your password. Do not share your password with any third parties. If your password has been compromised for any reason, you should change your password immediately.

10. Where We Store Your Information

Your information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United State, Spain or any other country in which the Company, its subsidiaries, or third party agents operate. If you are a resident of the EEA, we may transfer your information to affiliated entities or third parties to jurisdictions outside the EEA. Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place to allow the transfer of your information across borders outside of the EEA.

11. Our Policies Regarding Children

The lingotalk Platform is not intended for children under the age of eighteen (18) (the "Child" or "Children"), and we do not knowingly collect any personal information from such Children. Children should not use or attempt to use the lingotalk Platform, and if you are Children, please do not attempt to use the lingotalk Platform or send any information about yourself to the Company.

In the event that we learn that we have inadvertently gathered personal information from a Child, we will take reasonable measures to delete such information from our records. Parents who believe that we might have gathered any information from or about a Child may submit a request to delete such information to write to our address listed in Section 13 (Contact Us) below.

12. Your Choices and Controls

We give you meaningful choices when it comes to important uses and collection of your information. To easily access, view, update, correct, delete or port your personal data, or to update your subscription preferences, please sign into your account and visit "Account Settings". Where we rely on consent to collect and use information about you, you can withdraw your consent at any time. If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any of the lingotalk Platform purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the lingotalk Platform.

Push Notifications. We may send push notifications or "alerts" to your device to provide information regarding the lingotalk Platform, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notification settings via your device.

Promotional Communications. You may opt-out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you administrative, transactional, or relationship messages, such as those about your account or our ongoing business relations including but not limited to administrative confirmations, order confirmations, important updates regarding the lingotalk Platform and notices regarding this Privacy Policy and our lingotalk Terms.

13. How We Respond to Do Not Track Signals

Because consumers are often unaware that their do not track beacons are active, do not track frequently does not reflect the actual preferences of our users. We currently do not respond to Do Not Track signals. In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings.

14. Contact Us

If you have any questions about this Privacy Policy, please contact us as follows:

1. For Members that access and use of the lingotalk Product:

   Online Support: https://support.lingotalk.com

   Email: hi@lingotalk.com

15. Right to Contact a Data Protection Authority

If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority. Contact details for Data Protection Authorities in the EEA are available here.