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Privacy Policy of Vocabulity

Vocabulity is an interactive training service provided by Vocabulity (“Company”). Our services (“Services”) include a wide range of language content and courses from elementary to advanced levels. This content is available in applications (“Apps”) for various operating systems that can be downloaded to mobile phones and/or tablets.

This Privacy Policy explains the personal data (defined below) that we collect through the Services, how we use and transmit this data, and your options regarding our data processing practices.

By providing your personal data when using the Services, you agree to the processing of your personal data as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not access the Services and do not use them.

1. The Personal Data We Collect

When you interact with our Apps, we collect data that can be used separately or in combination with other information to identify you (“Personal Data”).

Personal data that you provide us. When you register or use the Services, you voluntarily provide us with certain Personal Data, including your name (surname), email address, and photo. If you register using your social network account (such as Facebook, etc.), the information we receive from these accounts depends on your settings and the Privacy Policies of these social networking platforms. Please consult their Policies to understand how to maintain confidentiality on these platforms.

We may also collect information not related to Personal Data, such as your time zone or language.

Automatically collected data. When you use the Services, our systems automatically create and record the following information:

  • Event log data: Information (“event log data”) automatically sent by the Apps when you use them. Event log data includes the Internet Protocol (IP) address, browser type and settings, date and time of your request, and information about your interactions with the Services.

  • Device Information: This includes the type and settings of your device, operating system, unique device identifiers, network information, and other device-related data. The information we collect may depend on the type of device you are using and its settings.

  • Activity Information: We collect information about how you use our Services, such as the types of content you view or work with, the functions you use, the actions you take, interactions with other users, and the frequency and duration of your activity.

2. How We Use the Data

We use the collected data for the following purposes:

  • Authenticating users, providing Services, processing transactions, and responding to your requests. For users in the EU, this use is necessary to fulfill the terms of the contract with them.

When necessary, based on legitimate business interests, these purposes include:

  • Adapting the training experience and complexity to the levels and needs of our users.
  • Understanding how visitors interact with our Apps and ensuring the best possible provision of Services.
  • Sending email messages that we believe will interest you.
  • Conducting research or promoting research and publishing scientific papers. We may transfer anonymized and impersonalized information to researchers to help improve the learning tools of the Services. This information may also be used for publishing works on language studies.

Analyzing data to support our marketing strategy and ensure the improvement and personalization of our messages and the opportunities offered to our users.

We may anonymize, remove personally identifiable information, and/or aggregate the information we collect and use such anonymous, impersonal, and/or aggregated data for commercial, statistical, and market research purposes, including sharing this data with affiliates and business partners.

Mobile Analytics

We use mobile analytics software to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the Apps, events that occur in the Apps, aggregated usage, performance data, and where the App was downloaded. We may combine this information with any personal information you send through the mobile app.

We use third-party trackers to inform us when users visit Apps by clicking on our ads or content hosted on third-party platforms.

The Apps use Posthog, Supabase to collect statistical information. Analytics information helps us estimate the exact number of Apps visitors and usage capacity. For more information on how Analytics processes this information, contact their developers’ sites.

Marketing

We collaborate with third parties, such as Facebook, to manage the advertising of our Apps on other websites or platforms. Our third-party partners may use cookies to collect information about your activity within the Apps to provide you with retargeted advertising.

We will send you updates and information about our new products and services, upcoming events, or other advertising campaigns or news via email or pop-up notifications. In cases provided by law, we will send you marketing information only if you have given us consent when providing us with your Personal Data. You can opt out of receiving such emails by following the instructions contained in each advertising email that we send, or by updating your user settings. Moreover, if you decide at any time not to receive further marketing messages, please contact us at contact@vocabulity.com. We will continue to contact you by email regarding the provision of our Services and respond to your requests.

Information about your rights in accordance with the current law of the European Union (“EU”) is provided below in the section “Rights according to EU regulations.”

3. Data Transfer and Disclosure

We may transfer your Personal Data and other information to certain third parties in the following cases:

  • Developers and service providers: To help us meet business needs and perform certain services and functions, your Personal Data may be transferred to third-party providers of hosting services, email delivery, customer support services, analytics, marketing services, and advertising (including Amazon and Google web services in the USA, which have certificates of the Program for the Protection of Confidential Information).
  • Transfer of control over the Company: If we participate in a merger, acquisition, financing, complex financial and legal due diligence, reorganization, bankruptcy proceedings, forced liquidation, sale of all or part of our assets, or the transfer of the service to another provider, your Personal Data and other information may be transferred to the assignee or an affiliate during this operation.
  • Legal requirements: If required by law, applicable regulations, or in good faith belief that such actions are necessary to (1) comply with a legal obligation, (2) protect the rights or property of the Company, (3) act in urgent circumstances to protect the personal safety of our users or the public, or (4) rescue the Company from legal responsibility.

4. Data Storage

We will retain your Personal Data for as long as reasonably necessary to achieve the objectives described in this Privacy Policy, or for a legitimate business need, or in accordance with legal requirements (for example, for tax, legal, accounting, or other purposes), depending on whichever period is longer.

5. Updating Personal Data

If you need to change or correct your Personal Data, or if you want to remove it from our systems, please contact us. We will consider your request in accordance with current law. Additionally, you can update your Personal Data yourself in your user settings.

6. Rights according to EU Regulations

Scope of application: This section provides information on your rights under EU law (including the countries of the European Economic Area: Iceland, Liechtenstein, and Norway).

Controller of Personal Data: Vocabulity is the controller of your Personal Data. To find information about our registered office, please visit our “contact us” page.

Your rights: Under EU regulations, you have the following rights concerning your Personal Data:

  • Right of access: Upon your request, we will confirm whether we process your Personal Data, and if so, we will provide you with a copy of this Personal Data along with other details. If you need additional copies, you may need to pay a reasonable fee.

  • Right to make corrections: If your Personal Data is inaccurate or incomplete, you have the right to ask us to correct or update it. If we have transferred your Personal Data to third parties, we will notify them of the correction, if possible. Upon your request, and if it is possible and legal, we will also notify you to whom we have transferred your Personal Data so that you can contact them directly.

  • Right to delete information: You can ask us to delete your Personal Data in some cases, for example, if we no longer need it or if you have withdrawn your consent (if applicable). If we have transferred your Personal Data to third parties, we will inform them about the need to delete the data, if possible. Upon your request, and if it is possible and legal, we will also notify you to whom we have transferred your Personal Data so that you can contact them directly.

  • The right to limit the processing of Personal Data: You can ask us to restrict or “block” the processing of your Personal Data in certain circumstances, for example, when you dispute the accuracy of the data or object to their processing (please read the section below to learn about your right to object). We will notify you before removing any data processing restrictions. If we have transferred your Personal Data to third parties, we will notify them of the restriction, if possible. Upon your request, and if it is possible and legal, we will also notify you to whom we have transferred your Personal Data so that you can contact them directly.

  • Right to data portability: You have the right to receive your Personal Data from us that you consented to provide us or that was provided to us as long as necessary according to the contract between you and the Company. We will provide your Personal Data in a structured, commonly used, and machine-readable format. You can reuse it anywhere.

  • Right to object: You can request us to stop processing your Personal Data at any time, and we will do so if we are proceeding from the legitimate interest (described above in the section “How We Use the Data”) regarding the processing of your Personal Data, unless we provide compelling legal grounds for data processing, or if we process 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, if this is not necessary regarding the contract between you and the Company, and if you have not given your consent to such usage.

  • Right to withdraw consent: If we proceed based on your consent to process your Personal Data, you have the right to withdraw this consent at any time. This will not affect the processing of your Personal Data that we have already carried out.

  • The right to file a complaint with the Data Protection Authority: If you are concerned about our methods of protecting confidential information, including how we process your Personal Data, you can report it to the Data Protection Authority, which is authorized to address such matters.

Please contact us to exercise your rights.

Legitimate interest: “Legitimate interests” are our interests in running our business, managing, and providing you with better Services. This Privacy Policy describes the cases in which we process your Personal Data to satisfy our legitimate interests, what these interests are, and what your rights are. We will not use your Personal Data for actions where their impact on you contradicts our interests unless we have obtained your consent or when these actions are provided for or permitted by law.

Changes to this Privacy Policy We will notify you of changes in the data processing activities described in this Privacy Policy by posting a prominent notification in the Apps or taking other actions in accordance with legal requirements.

7. Public Information

This Privacy Policy does not apply to any information that you post in the public areas of the Services. These include (but are not limited to) comments in blogs or public forums. Comments posted in public areas can be viewed and used by third parties and accessed by them in accordance with the rules and privacy policies of these parties.

8. Children

Vocabulity does not intentionally collect Personal Data about children under 13. If you have reason to believe that a child under the age of 13 has provided the Company with Personal Data via the Services, please contact us, and we will endeavor to remove this information from our databases.

9. Links to Other Applications

The Apps may contain links to other websites or applications that are not managed or controlled by us (“Third-Party Sites”), including websites and social networking services. The information you share with Third-Party Sites will be regulated by the privacy policies and terms of use of these Third-Party Sites, not by this Privacy Policy. By providing these links, we do not imply that we approve or verify these sites. Contact these sites directly for information on their methods of protecting personal data and privacy policies.

10. Data Protection

We take reasonable administrative and technical measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, modification, or destruction. However, no method of transferring data over the Internet is 100% secure. Therefore, while we strive to protect your data, we cannot guarantee its absolute safety.

11. Changes in the Privacy Policy

We may change this Privacy Policy at any time. When we do so, we will publish an updated version on this page. By continuing to use the Apps or providing us with information after the updated Privacy Policy is published, you agree to the revised Privacy Policy and the procedures described therein.

12. Contact Us

If you have any questions about this Privacy Policy or our data processing practices, please contact us.