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 have any questions about this Privacy Policy, you can contact us by email at: [email protected]
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.
For the purposes of this Privacy Policy:
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.
If you contact us about our Service, we will collect the following Personal Data:
When you use our Service, we may collect the following Personal Data:
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 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.
If you “follow” or connect with us on social media, or “tag” us in posts that you upload to social media, we will collect the following information:
We use this information to respond to your comments or posts that are addressed to or reference us and to inform our social media strategy.
We allow you to create an account and log in to use the Service through your App Store Account. When you do so, we may receive information associated with your App Store Account, such as your name and email address.
The Company may use Personal Data for the following purposes:
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.
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.
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:
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.
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.
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.
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.
Apple Store In-App Payments
Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
Google Play In-App Payments
Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/
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:
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 (AdWords) 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: http://www.google.com/settings/ads.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266. To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
AdRoll remarketing service is provided by NextRoll, Inc.
You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false or the Opt Out of Personalized Advertising web page: https://help.adroll.com/hc/en-us/articles/216599538-Opting-Out-of-Personalized-Advertising. If you are a California resident, please read the “Information For California Residents Only” section in the Privacy Policy of NextRoll, Inc.: https://www.nextroll.com/privacy#service-13.
For more information on the privacy practices of AdRoll, please visit the NextRoll, Inc. Privacy Policy web page: https://www.nextroll.com/privacy
AppNexus remarketing service is provided by AppNexus Inc.
You can opt-out of AppNexus remarketing by visiting the Privacy & the AppNexus Platform web page: https://www.appnexus.com/platform-privacy-policy.
For more information on the privacy practices of AppNexus, please visit the AppNexus Platform Privacy Policy web page: https://www.appnexus.com/platform-privacy-policy
Their Privacy Policy can be viewed at https://www.tiktok.com/legal/privacy-policy-us?lang=en
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.
You may be able to exercise control by leveraging one or more targeted advertising opt-out programs including:
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. In addition, program participants may still use automatic data collection technologies to collect information about the use of the Service, including for analytics and fraud prevention and any other purpose permitted under the applicable advertising industry program.
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.
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.
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.
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.
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. For example, certain categories of Personal Data would only be collected if you provided such Personal Data directly to us.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
Collected: Yes.
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Data included in this category may overlap with other categories.
Collected: Yes.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: Yes.
Examples: Records and history of products or services purchased or considered.
Collected: Yes.
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, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
Examples: Interaction with our Service or advertisement.
Collected: Yes.
Examples: Approximate physical location.
Collected: Yes.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: Yes.
Examples: Current or past job history or performance evaluations.
Collected: No.
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.
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:
We obtain the categories of Personal Data listed above from the following categories of sources:
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:
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of your Personal Data” section.
If we decide to collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.
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:
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact disclosed, 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 disclosed.
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.
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. This means that we may have received some kind of benefit in return for sharing Personal Data, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact sold, 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 shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of Personal Data:
We may share your Personal Data identified in the above categories with the following categories of third parties:
We do not knowingly collect Personal Data from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.
We do not sell the Personal Data of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of Personal Data may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us.
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.
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 categories of Personal Data we collected about you
— The categories of sources for the Personal Data we collected about you
— our business or commercial purpose for collecting or selling that Personal Data
— The categories of third parties with whom we share that Personal Data
— The specific pieces of Personal Data we collected about you
— If we sold your Personal Data or disclosed your Personal Data for a business purpose, we will disclose to you:
— The categories of Personal Data categories sold
— The categories of Personal Data categories disclosed
— Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
— Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
— Debug products to identify and repair errors that impair existing intended functionality.
— Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
— Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
— Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
— Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
— Comply with a legal obligation.
— Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
— Denying goods or services to you
— Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
— Providing a different level or quality of goods or services to you
— Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us:
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:
We cannot respond to your request or provide you with the required information if we cannot:
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.
Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt.
For data portability requests, we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
You have the right to opt-out of the sale of your Personal Data. Once we receive and confirm a verifiable consumer request from you, we will stop selling your Personal Data. To exercise your right to opt-out, please contact us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells Personal Data as defined by the CCPA law. If you wish to opt out of the use of your Personal Data for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by updating your settings in your profile page on the Application. You may also be able to opt out of all data sharing for advertising purposes on your device by following the instructions below.
Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
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. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
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.
If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Praktika.ai Company 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 our responsible for how your Personal Data is used.
If you would like to contact us, you can do so by email to: [email protected]
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.
| 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. |
| We use this information to inform how we can improve our Service. | The processing is necessary for our legitimate interests, namely to inform service development and improvement. |
| Personal Data | How we may use it | Lawful basis we rely on |
| Language learning information, such as your native language, language learning goals and priorities, previous experience learning English and 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, gender, age group and hobbies and 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 and demographic. | The processing is necessary for our legitimate interests, namely tailoring the Service to your interests. |
| 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 to the Service through your Google Play or Apple App Store account. | We use this information to 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). |
| 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. | |
| The AI tutor or avatar you select on the Service. | We use this information to personalise your experience of the Service by offering you language instruction through your chosen AI tutor or avatar. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). |
| Recordings of your conversations with the AI tutor on the Service. | When you first start using the Service, we analyse this information to determine your current language proficiency level to create and customise your curriculum and lessons. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). |
| We analyse this information to provide you with the language learning functionality of the Service, including assessing your grammar, vocabulary to provide feedback and points for development. | The processing is necessary for the performance of a contract with you (namely our Terms & Conditions). | |
| We analyse transcripts of the conversations you have with the AI tutor on the Service to identify ways in which we can fine tune our AI models to improve the Service. | The processing is necessary for our legitimate interests, namely improving the Service. | |
| Your lesson plan and progress. | We use this information to provide you with the language learning functionality of the Service. | 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 | 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. |
| 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 in the main body of this privacy notice 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. | |
| 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 and the site to which you are going when you leave the Service, the pages you visit, the links you click, your interactions on the Service 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 “Beahvioral Advertising” section in the main body of this privacy notice 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. |
| Personal Data | How we use it | Legal basis we rely on |
| How you have interacted with us, such as any posts addressed to us or in which you tagged us, or if you have “liked” one of our posts. | We use this information to respond to your comments or posts that are addressed to us or reference us. | The processing is necessary for our legitimate interests, namely promoting the Service and any content that we publish on social media. |
| We use this information to inform our social media marketing strategy, including choosing and creating the content that we post to our social media pages. | The processing is necessary for our legitimate interests, namely informing our social media marketing strategy. | |
| The Personal Data you make public on the social media network in accordance with your settings, such as your profile name and picture. | We use this information to respond to your comments or posts that are addressed to us or reference us. | The processing is necessary for our legitimate interests, namely promoting the Service and any content that we publish on social media. |
| We use this information to inform our social media marketing strategy, including choosing and creating the content that we post to our social media pages. | The processing is necessary for our legitimate interests, namely informing our social media marketing strategy. |
| How we may share Personal Data | Lawful basis we rely on |
| Service providers, such as providers of web hosting or other technical services such as analytic services or communication services. | These service providers will use your Personal Data as processors on our instructions. |
| Advisors, such as legal advisors or accountants. These third-party vendors and other service providers perform services for us or on our behalf. | 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. For more information, please see the “Behavioral Advertising” section in the main body of this privacy notice. | 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. Your Personal Data may be disclosed to third parties in connection with a 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. These recipients will use your Personal Data to review and assess a potential transaction to purchase our business or assets. | 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. We may share your Personal Data with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and / or (iii) exercise or protect the rights, property or personal safety of the Company or others. These recipients will use your Personal Data in the performance of their regulatory or law enforcement role, or to advise us in connection with a potential claim or regulatory enforcement action. | 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. |
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:
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 end of this privacy notice.
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.
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:
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 (such as if you submit a number of repeated requests), 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.
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/about-edpb/members_en.
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