Privacy Policy
Lingo Buddies is dedicated to ensuring the safety and protection of your personal data. We have crafted this Privacy Policy using clear and straightforward language to promote transparency and easy understanding. Before providing your consent or any personal information on our website, we kindly ask you to thoroughly read this Policy to comprehend how we handle your data.
This Privacy Policy is applicable to your use of the Lingo Buddies Services, as defined in our Terms of Service. It outlines the when, where, and why we process the personal data of individuals using the Lingo Buddies Platform, how we utilize this data, the conditions under which it may be disclosed to others, your rights concerning your personal data, and the security measures in place to safeguard it.
Access to the Lingo Buddies Platform, including the Website, associated software, and mobile application, is available with or without registration. You can explore the Website, discover how Lingo Buddies works, browse through language tutors, read our language-learning resources, and more, without the need to register. However, during your visit to the Website, we collect log information and employ cookies to track your activity. You can choose to opt out of most cookies, except those that are essential for the Website’s functionality.
Upon registering an account, we may collect and process various data, including cookie identifiers and information provided during registration, such as first name, last name, email, phone number, Skype ID, or social network ID (if linked through Facebook, Google+, or Google Calendar), time zone, IP address, and device type.
For language tutors, we may additionally collect and process data such as zip code, gender, year of birth, city of residence, and educational background, along with profile pictures and preferred currency for actions related to our Refund and Payments Policy.
To learn more about the specific instances of data collection and the purposes of processing such data, please refer to the relevant section of this Privacy Policy.
Please be aware that this Privacy Policy may be updated periodically, and we will publish the changes on this page along with the modification date. In case of significant changes, we will notify you through email.
At times, we may experiment with different features on the Lingo Buddies Platform that could impact the processing of personal data. In such situations, we will provide prior notice and, if necessary, seek your consent.
If you have any inquiries regarding this Policy or our language-learning services, please reach out to legal@lingobuddies.com.
1. What Is Personal Data and the Processing of Personal Data? Main Definitions
Personal data refers to any information related to you that, either alone or when combined with other information, allows Lingo Buddies or the entity processing the data to identify you as an individual.
Processing of personal data encompasses any operation involving your personal data, whether automated or not. This includes actions like data collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, transmission or disclosure, dissemination, alignment or combination, restriction, erasure, or destruction.
The data subject refers to any identified or identifiable natural person whose personal data is processed by Lingo Buddies as the controller; in this context, it pertains to you as a user of Lingo Buddies.
Consent of the data subject/user is an essential aspect, which means any freely given, specific, informed, and unambiguous indication of your wishes. This can be expressed through a statement or clear affirmative action, signifying your agreement to the processing of personal data related to you.
2. Lingo Buddies’ Lawful Bases for Processing
Lingo Buddies only processes your personal data when there are lawful bases for doing so. These bases include:
– Processing based on your consent: This includes activities like sending newsletters, collecting, analyzing, and publishing user feedback and reviews, analyzing video lessons, your participation in events and webinars, and the use of various types of cookies, as well as announcing sweepstakes winners, all of which are carried out based on your consent.
– Processing necessary to provide services according to our Terms of Service: This refers to the data processing required to fulfill the contract between you and Lingo Buddies for information services.- Processing for legitimate interests: Lingo Buddies may process your data to achieve its legitimate interests. These interests may include complying with U.S. financial and accounting legislation, analyzing the traffic and financial performance indicators of the Lingo Buddies Platform, promoting Lingo Buddies through various channels, such as social media networks and affiliates, and using tutors’ information for marketing or promotional purposes in accordance with the Terms of Service. Other legitimate interests include fraud prevention, tutor verification, and improving the learning experience for both tutors and students through AI-powered recommendations, interactive learning tools, and enhanced lesson planning.
– Processing to comply with applicable legislation: In some cases, Lingo Buddies may process your data to fulfill legal requirements, such as processing data subject requests.
– Processing to protect vital interests: On rare occasions, personal data may be processed to protect your vital interests or those of another natural person.
– Processing for tasks carried out in the public interest: Lingo Buddies may process personal data when performing tasks that serve the public interest or are exercised under official authority vested in the organization.
In all instances, Lingo Buddies will inform you about the specific legal basis for data processing and any other relevant details before commencing the processing, except when it is not possible due to obligations under applicable legislation.
3. Data We Collect: Scope
Lingo Buddies collects the following information from you for the specified purposes:
(1) Account for Learners (Students)
When you register for an account, Lingo Buddies collects and processes personal data provided by you. For registration, you need to provide your login credentials (username and password), first name, last name, and email. You can also add more information to your account settings and sync your Google and Lingo Buddies Calendars. The additional information can help you find suitable time slots with tutors and manage your schedule, but it’s optional, and you can choose not to provide it.
(2) Account for Language Tutors
Upon registration, language tutors provide their login credentials (username and password), first name, last name, and email. Tutors can also edit their profiles and add additional information, such as zip code, country, language skills, education, and work experience. This information can assist in finding suitable time slots with students or organizing schedules, but providing additional data is not mandatory.
Certain personal data, such as user names and locations listed in user profiles or derived from IP addresses, may be publicly visible to other users on the platform or the web. Lingo Buddies may implement privacy settings allowing users to choose what information becomes public.
(3) Subscription to the Lingo Buddies Blog
You can subscribe to the Lingo Buddies Blog to receive newsletters and updates. For this, you need to provide your email address.
(4) Posting of Information
Lingo Buddies processes personal data you voluntarily submit to the platform, such as surveys, online forms, questions, comments, or feedback. Content and messages posted on or through the platform, including personally identifiable information, will be visible to Lingo Buddies and other users of the platform. Some content cannot be deleted as it may be related to lessons used by other users. Lingo Buddies may retain this information for dispute resolution, customer support, and troubleshooting as allowed by law. Accounts of users violating the Terms of Service may be terminated.
(5) Service Use, Cookies, and Similar Technologies
Lingo Buddies monitors and analyzes web traffic and user behavior when using the platform. For further details about the use of cookies and similar technologies, refer to our Cookie Policy.
(6) Billing Information
Details of transactions carried out on the Lingo Buddies Platform, such as transaction IDs, dates, and times, are processed for billing purposes.
(7) Lingo Buddies for Business
If you inquire about Lingo Buddies Business Services, we may collect your name, email, company name, and phone number to provide more information as defined in the Lingo Buddies Business Terms.
(8) Sensitive Data
Lingo Buddies does not process your sensitive data unless you expressly agree.
(9) Pages on Social Networks
Lingo Buddies maintains official pages on social networks like Facebook, TikTok, Instagram, and LinkedIn. Interactions on these pages, such as subscribing, leaving comments, or reacting to posts (e.g., ‘liking’ posts), may be analyzed for measuring social media marketing campaigns and efficiency in our legitimate interests.
(10) Tutors Community (for Tutors Only)
Lingo Buddies has a Tutors Community accessible through the Website via Single-Sign-On (SSO). Interaction and usage data within the Tutors Community are collected and processed to fulfill the purposes specified under subsection (10) of section (4) of this Privacy Policy.
(11) Tutors Academy (for Tutors Only)
Registered tutors can access the Tutors Academy to take various courses for skill improvement and optimizing their tutoring on the Lingo Buddies Platform. Activity data, comments, reviews, and survey results are collected and processed to enhance and make the courses more engaging and effective.
(12) Information Required for Submitting Tax Documentation
To comply with applicable tax and accounting legislation, Lingo Buddies may process various tax documentation containing your personal data, such as federal tax form 1099 or other necessary tax forms for sweepstakes prizes or tax withholding. Personal data like full name, country of citizenship, permanent residence address, mailing address, date of birth, U.S. taxpayer identification number, or foreign tax identifying number may be processed for this purpose.
(13) Information Required for Marketing and Promotion
Lingo Buddies may collect tutors’ postal addresses to promote their tutoring services on the platform and help reach more prospective students in specific geographical areas.
(14) Analysis of Speech Activity
During lessons on the Lingo Buddies Platform, microphone activity may be analyzed to provide an overview of speaking activity and engagement levels. No voice recordings or conversation content is recorded. Users in the European Economic Area (EEA) or Switzerland have the option to disable this feature based on legitimate interests.
(15) Language Assessment
Lingo Buddies processes personal data to assess language proficiency levels. This may include your name, email address, and language assessment results, which can take place before or after platform registration.
(16) Video Lessons, Sales Calls, Events, and Webinars
Lingo Buddies may process your likeness and interactions in videos for group classes, sales calls, webinars, and events. Prior notice and consent will be obtained if required before recording.
(17) Information Processed by AI-Powered Tools
AI-powered tools may use your text prompts and, with consent, lesson transcripts to offer personalized learning recommendations, generate lesson plans, provide grammar explanations, vocabulary enrichment, exercises, homework suggestions, language proficiency assessment, and chatbot functionality.
4. Data We Collect: Purposes
We process the personal data you voluntarily provide to personalize your Lingo Buddies experience and offer high-quality Services under the Terms of Service. The purposes for processing your personal data include:
(1) Provision of Services
Processing your data to authorize access, facilitate tutor-student interactions, schedule and conduct lessons, and track learning progress.
(2) Payment Services
Using third-party payment providers to bill and process payments securely.
The data collected and processed by Lingo Buddies serve specific purposes and are crucial for providing our language-learning services effectively.
(3) Referral Programs
Lingo Buddies offers two referral programs:
– “Tell-A-Friend” Referral Program: We generate a personalized referral link for you to share with friends. We only collect your friend’s personal data when they follow the link and access the Lingo Buddies Platform.
– B2B Referral Program: For the B2B program, you can share the name, job position, and email of colleagues interested in Lingo Buddies Business Services. We inform your colleagues about the use of their personal data during the initial contact.
(4) Communications
Lingo Buddies may contact you via email and other means for Services-related purposes, such as welcome letters, security and legal notices, announcements, updates, reminders, and suggestions. Communication also enables user interactions, including messaging, video calls, and feedback about other users.
You may receive push notifications through the Lingo Buddies mobile application, which can be adjusted through your smartphone’s internal settings. You can opt-out of certain communications, excluding essential notices and reminders, by following the provided mechanisms.
(5) User Research
Your contact data (email, phone number, Skype name, etc.) may be used to gather feedback through research. Lingo Buddies may contact you for internal purposes, such as feature development, marketing activities, customer support updates, and service improvements. Research activities will not record your voice, image, or be used without obtaining your consent.
(6) Marketing and Promotion of Lingo Buddies
With your consent, Lingo Buddies may use your first name, last name, and email for mailing lists, newsletters, and promotional messages about our Services. You can opt-out of marketing messages through provided links in each message and user settings on the platform.
Phone numbers may be used to contact you with commercial or promotional information. Lingo Buddies allows individuals to participate in the affiliate program to promote the platform through blogs and influencer channels. Feedback provided may be used by Lingo Buddies under the Terms of Service without additional compensation.
(7) Behavioral and Social Media Marketing
Lingo Buddies may share your email address with Google and Meta for personalized advertisements and behavioral and social media marketing based on legitimate interests and consideration for your privacy.
(8) Identifying Influencers for Potential Collaborations
Third-party services like Captiv8, Inc. and LiveRamp Holdings, Inc. may analyze the information you provide during registration to identify influential students. If identified as an influencer, Lingo Buddies may propose collaboration and provide a detailed privacy notice.
(9) Analytics and Development
Lingo Buddies monitors and analyzes personal data, including information provided during registration, web traffic, cookies, and usage data, using services like Google Analytics, Hotjar HeatMaps & Recordings, Amplitude Analytics, Branch.io, Braze, and Intercom. Research activities, polls, surveys, and personalized “A/B” tests are conducted to improve the user experience, develop features, and streamline Services. User feedback and usage data may be processed to provide relevant advertising based on past use of Lingo Buddies Services, adhering to the Cookie Policy.
(10) Tutor Verification and Program Preparation
Lingo Buddies collects and processes tutor credentials to verify their eligibility to teach claimed subjects and to assist tutors in developing learning programs. Analytics is used to automate and improve the tutor verification process.
(11) Improvement of Tutors’ Ranking Algorithm
Various metric-based data, including personal data provided by tutors and students on the platform, is used to enhance the tutors’ ranking algorithm and improve user experience, based on legitimate interests.
(12) Managing Tutors Community
Email, interaction, and usage data of tutors participating in the Tutors Community are processed to facilitate interaction, share best practices, provide official information, and improve the tutor’s user experience. Access to personal data within the Tutors Community is restricted to service providers and employees on a need-to-know basis.
(13) Support and Platform Supervision
Data, including communications, may be used to resolve disputes, supervise user behavior on the platform, and respond to complaints or requests.
(14) Events and Webinars Conducted by Lingo Buddies
Personal data collected when registering or attending events or webinars is used to provide access, send registration confirmations, reminders, and related materials or information about the Services.
(15) Competitions and Sweepstakes
• Competitions: Registration forms are used for learning-focused competitions to organize and conduct the competition, determine winners, and contact them regarding results and prizes.
• Sweepstakes: User ID, name, date of birth, country of legal residence, and email address associated with the account are processed to administer sweepstakes, verify eligibility, contact winners, provide prizes, and comply with legal requirements. The names of sweepstakes winners may be posted on the website with consent.
(16) Compliance with Legal Requirements
Payment information is processed to comply with financial and accounting legal requirements. Data collected on the platform may be processed in connection with legal requests received and to exercise, defend, and establish legal rights.
(17) Fraud Prevention
Certain information, including log information, payment details, and user behavior, is supervised to prevent fraudulent activities and assist with user session management.
(18) Changes
Lingo Buddies may update the Privacy Policy from time to time. Your rights will not be reduced without explicit consent. The latest version of the policy is posted on the website, and substantial changes will be notified through email.
5. How Is Personal Data Shared?
To provide high-quality services, Lingo Buddies collaborates with various entities under data processing agreements (DPA) or Standard Contractual Clauses (SCCs). Some personal data may be shared with these entities. Secure storage places, such as those provided by AWS (Amazon, the USA), with servers located in Ireland, Germany, and the United States, are used.
(1) Categories of Third-Party Service Providers
Various third-party service providers may receive different categories of personal data:
– Analytics services: Data described in subsections 5 and 14 of section 3 of this Privacy Policy.
– Social network platforms and search engines: Data described in subsection 7 of section 4 and subsection 2 of section 5 of this Privacy Policy.
– Customer communication solutions: Data described in subsection 4 of section 3 of this Privacy Policy.
– User research tools: Data described in subsection 5 of section 4 of this Privacy Policy.
– Services to manage emails and send out push notifications: Contact details and personal identifiers provided.
– SMS providers for mobile marketing and notifications: Contact details and personal identifiers provided.
– Payment services providers: Data described in subsection 6 of section 3 of this Privacy Policy.
– AI-powered service providers: Data described in subsections 16 and 17 of section 3 of this Privacy Policy.
– Providers of video conferencing, speech-to-text, and conversation analytics tools: Data described in subsection 16 of section 3 of this Privacy Policy.
– Influencer marketing solution providers: Name and other identifiers described in subsections 1 and 2 of section 3 of this Privacy Policy.
– Language assessment tools: Data described in subsection 15 of section 3 of this Privacy Policy.
– Search engine optimization and marketing tools: Data described in subsection 13 of section 3 of this Privacy Policy.
– Services to manage Tutors Academy: Data described in subsection 11 of section 3 of this Privacy Policy.
– Services to manage Tutors Community: Data described in subsection 10 of section 3 and subsection 10 of section 4 of this Privacy Policy.
(2) Use of Social Network Platforms
Lingo Buddies maintains social media pages on platforms like Facebook, Instagram, LinkedIn, and TikTok. Different platforms have different roles in processing personal data, and they may act as joint controllers or independent controllers depending on the circumstances.
(3) Data Transfer in Case of Change of Control or Asset Disposition
In the event of any merger, acquisition, sale, or change of control, Lingo Buddies ensures the confidentiality of personal data and provides notice to affected users before data transfer or becoming subject to a different privacy policy.
(4) Companies Using Lingo Buddies Business Services
Lingo Buddies may share language learning progress and assessment results with employees or contractors of companies using its Business Services.
(5) Lingo Buddies Independent Contractors
Lingo Buddies collaborates with independent contractors to provide various services. Contractors have access to personal data only on a need-to-know basis and under strict privacy and security obligations.
(6) Other Users of the Lingo Buddies Platform
Personal data may be visible to other users and visitors of the Lingo Buddies Platform through personal contacts, group classes, or tutor reviews.
6. How Long Will the Personal Data Be Processed and Stored by Lingo Buddies?
Lingo Buddies will store your personal data for as long as necessary to fulfill the purposes for which it was collected. Generally, your data will be retained as long as your account is active. If there has been no activity on your account for more than 2 years, it will be considered expired, and your personal data will be removed from active systems and servers within 90 days or earlier if you choose to delete your account.
However, in certain cases such as ongoing conflict situations or legal requirements, Lingo Buddies may retain your personal data for a longer duration. Upon the resolution of such situations, your data will be deleted after the standard retention period has expired.
If you have subscribed to Lingo Buddies’ mailing list or newsletter, your contact data will be stored as long as you are interested in receiving emails. You can unsubscribe at any time using the link provided in each email.
Data collected during events or webinars will be merged with your account data if registered using your account credentials, and other contact details will be deleted within 30 days after the event or webinar.
Lists of sweepstakes participants, including mail-in entries, will be deleted 30 days after the sweepstakes’ end, but the names of winners will remain publicly available until consent is withdrawn.
Lingo Buddies will terminate the processing of your personal data after the retention period expires unless required otherwise by relevant legislation.
7. Your Rights as a Data Subject Regarding Your Personal Data Processed by Lingo Buddies
As a data subject, you have several rights regarding your personal data processed by Lingo Buddies:
– Right of Confirmation: You can confirm whether Lingo Buddies is processing your personal data.
– Right of Access: You can access the personal data Lingo Buddies has processed about you.
– Right to Rectification: You can request correction of incomplete or inaccurate personal data.
– Right to Erasure (Right to Be Forgotten): You can request the deletion of your personal data, subject to certain legal requirements.
– Right of Restriction of Processing: You can contest the accuracy of your data or restrict processing under specific circumstances.
– Right to Data Portability: You can request the direct transmission of your personal data to another controller where technically feasible and without affecting the rights and freedoms of others.
– Right to Object to Processing: You can object to the processing of your personal data when it is performed for specific reasons.
– Right to Withdraw Consent: You can withdraw your consent to the processing of your personal data at any time.
You can exercise these rights by contacting Lingo Buddies via email. The requests are free of charge. If you believe your rights have been violated, you can lodge a complaint with the competent data protection authority.
8. Other Privacy Commitments by Lingo Buddies
Lingo Buddies processes personal data both within the United States and outside the United States, ensuring high standards of data privacy and compliance.
Response to your rights requests will be provided within one month, with a possible extension if necessary due to complexity or a high volume of requests.
Lingo Buddies takes technical and organizational measures to ensure the security of personal data.
In exceptional cases requiring customer support, Lingo Buddies’ support specialists may need access to your account, but they will seek your permission before doing so.
Lingo Buddies takes privacy of children seriously and does not knowingly collect information from children under 13 without parental consent.
In case of a personal data breach with a high risk of affecting your rights, Lingo Buddies will inform you and the data protection agencies without delay.
Lingo Buddies does not sell your personal data and respects your choices regarding direct marketing.
9. Legal Matters
Lingo Buddies may disclose your personal data to comply with the law, enforce the Privacy Policy, investigate potential violations, or protect its rights and safety.
If you have any questions or concerns regarding your privacy, you can contact Lingo Buddies at support@lingobuddies.com.
Your Lingo Buddies Team