Updated: 30 August 2022

1. BASICS

1.1. Chapenko Oleksandr, registered in Oleksandriya, Ukraine, 28000 (hereinafter - "we") owns Correct spelling - learn foreign language (hereinafter - “Application” or “App”) and pays great attention to the protection of the data that you have provided to us. Our Privacy Notice is based on the General Data Protection Regulation (GDPR) of the European Union and the California Consumer Privacy Act (CCPA) for the citizens of California, USA.

2. DEFINITIONS

2.1. PERSONAL DATA: data about a living individual who can be identified from those data (or from those and other information either in our possession or likely into our possession).

2.2. AUTOMATICALLY COLLECTED DATA: data collected automatically either generated by the use of the Application or from the Application itself (IP address, device\system data, as device ID, model etc.).

2.3. GOOGLE ACCOUNT ® DATA: data that can be requested from you via Google in order to create your personal Google account (name, phone number, address etc.)

2.4. DATA CONTROLLER: a natural or legal person who (either alone or in common with the other persons) determines the purpose for which and the manner in which any personal data are or able to be processed. For the purpose of this Privacy Notice, we are the Data Controller of your data.

2.5. DATA PROCESSOR (SERVICE PROVIDERS): any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

2.6. DATA SUBJECT: any living individual who is the subject of Personal Data.

2.7. USER: any individual using our Application. The User corresponds to Data Subject, who is the subject of Personal Data.

3. Why do we collect your data?

3.1 The purposes for which we collect your personal data are: improving our service, communicating with you as User of the App, processing your data for the marketing and advertising purposes, presenting information requested by you as a User, providing services related to the specialization of the App, as well as for other specialized and safe actions.

3.2 Also, we use your data for other reasons such as safety and security, customer support, compliance with legal obligations, accounting requirements and software development.

3.3 The main purpose of the processing of your data is to be sure that your Application usage will be comfortable and clear for you.

4. In what way do we use your personal data?

4.1 We use your personal data to make our Application quick and efficient.

4.2 We use your data in order to - effective and fully usage of all the available functions of the Application - for analytics purposes - for advertising or marketing purposes - for fraud prevention, security and legal compliance - for your personalization when using the Application

4.3 We don't collect your financial information (e.g. valid credit card number, card brand, expiration date) and sensitive data.

4.4 The Application may not access your User information from social networking sites, such as Facebook, Instagram, Pinterest, Twitter ets., including your name, your social network username, location, gender, birth date, email address, profile picture and public data for contacts.

4.5 We do not collect precise information about the location of your mobile device.

4.6 We may request access or permission to certain features from your mobile device, (camera, contacts, reminders).

4.7 We don’t collect the information from third parties, such as personal information about your friends accounts/contacts, if it is stored in your phone book.

4.8 We may use your data for some tracking technologies to analyze and track users’ use of the Application, determine the popularity of certain content, and better understand online activity and your needs as our users.

4.9 We may send you push notifications in order to send updates and reminders regarding the App. If you wish to opt-out from receiving them, you may turn them off in your device’s settings.

4.10 Some mobile operating systems (and mobile applications) include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

5. What are the legal grounds for data processing?

5.1 We check the data that we collect. Also, we determine the legal basis of processing before proceeding to the processing of your personal data. We care about your Personal data that should be processed lawfully, fairly and transparently.

5.2 We use the following grounds as a contract (Terms of use), legitimate interest to collect and manage your personal data.

6. What categories of personal data do we collect?

6.1 You may find below the personal data categories and the purposes of such collection and (or) processing which we arrange.

6.2 Please note, as you obtain the access to the App by your Google Account, your personal data can be collected by Google, to read more please follow the link

6.3 We neither keep, nor store these types of data for our servers.

6.4 We need your consent to provide you with further access to our Application. Also, we want to ensure safe work of the Application and to be compliant with law. We won’t collect or process your Personal Data until obtaining your consent. Your consent may not always mean your specific actions. If you continue to use our Application, you are deemed to have agreed to the terms and conditions specified in this Policy.

7. How do we share and disclose your data?

7.1 We may share your personal data under the following conditions: safety, legal purposes and law demand. We may disclose your personal data to third parties to the extent necessary to: comply with a government request, a court order or applicable law; defend ourselves against third-party claims; assist in fraud prevention or investigation; comply with the Google ® Monetization and Ads policy.

7.2 We may share information we have collected about you in certain situations. Your information (provided by you and/or automatically collected) may be disclosed as follows:

7.2.1. By Law or to Protect Your Rights If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies or to protect the rights, property and safety of others, we may share your information as permitted or required by any applicable law, rule or regulation. This includes exchanging information with other entities for fraud protection and other criminal actions.

7.2.2. Third-Party Service Providers We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service and marketing assistance. These people or companies have the obligation to keep the confidentiality of your Personal Data. We usually may transfer your personal data only to the subjects who are located in countries, where adequate level of data protection previously was confirmed by government authority. You may find the list of such countries by clicking here. In the event of and following discovery or notification of a breach of the security of the Personal Data, or access by an unauthorized person, we are required by law to notify you if the breach is likely to affect your privacy.

7.2.3. Marketing Communications (Advertisers and other third parties)

We may share your information with advertisers or other third parties as permitted by law, in which case we will require them to honor this Privacy Notice.

We cooperate with different Advertisers and provide them the opportunity to place their advertisements and other information (Adv. content) in certain areas of the Application, such as sidebar advertisements, banner advertisements or widget advertisements - Internal advertisement, and appearing pages of the Adv. content in the browser used - External advertisement. So, we can provide the virtual space for the Advertisers to place such advertisements.

We expressly disclaim any warranties or other representations regarding the Advertiser`s Adv. content. Please note if the Adv. content contains links to other websites and resources (also provided by Advertisers or the third parties), these links are provided without our control.

We do not control the content of these sites or resources and are not responsible for them or for any loss or damage that may result to you and your Personal Data. If you use such links, you do so entirely at your own risk and subject to the terms of use, privacy policies of such Advertisers or other third parties.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

By using the App you agree that your Personal Data can be shared with such Advertisers

.

You can withdraw it only by removing the App from your device.

7.2.4. Affiliates We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

7.2.5. Business Partners We may share your information with our business partners to offer you certain products, services or promotions in which case we will require our business partners to honor this Privacy Notice.

7.2.6. Business negotiations and transfers.

We will never sell your personal data to any company or legal entity. However, we may transfer your personal data to a successor entity upon a merger, consolidation or other corporate reorganization in which we may participate. However, this Privacy Notice does not apply to information about you collected by any third party.

We also inform you that in our application we use the Flurry system (Developed by Yahoo). Flurry is a mobile app analytics platform that empowers product, development and growth experts to build better apps that users love. All User’s actions and clicks inside the Applications are recorded and processed through the Flurry system by the Flurry, Inc. ("Flurry"), a subsidiary of Verizon Media. We do not have access to all User events and actions. We highly recommend you to check out the Flurry system Terms of Use and Privacy Notice.

Also, we use [AdMob and Appodeal] in our application. It makes earning revenue easy with in-app ads, actionable insights and powerful, easy-to-use tools that grow our business. Click here to get new insights about [AdMob Privacy Notice and Appodeal].

In addition we use Firebase in our application. Firebase gives us functionality like analytics, databases, messaging and crash reporting so we can move quickly and focus on our users during the maintenance of the Application. Find out more about Firebase Privacy Notice by clicking here.

8. Your rights

You may exercise rights regarding your Personal Data. In particular, you have the right to:

8.1. object against the processing of your information Let us know what you object against and we will consider your request. If there are no compelling interests for us to refuse to perform your request, we will stop the processing for such purposes. If we believe our compelling interests outweigh your right to privacy, we will clarify this to you.

8.2. access to your information You have the right to know what personal data we process. As such you can obtain the disclosure of the data involved in the processing and you can obtain a copy of the information undergoing processing.

8.3. verify your information and seek its rectification If you find that we process inaccurate or out-of-date information, you can verify the accuracy of your information and/or ask for it to be updated or corrected.

8.4. restrict the processing of your information. When you contest the accuracy of your information, believe we process it unlawfully or want to object against the processing, you have the right to temporarily stop the processing of your information to check if the processing was consistent. In this case, we will stop processing your data (other than storing it) until we are able to provide you with evidence of its lawful processing.

8.5. have your personal data deleted If we are not under the obligation to keep the data for legal compliance and your data is not needed in the scope of an active contract or claim, we will remove your information upon your request. You can formulate such requests or channel further questions on data protection by contacting us at […]. If you believe that our use of personal information violates your rights, or if you are dissatisfied with a response you received to a request you formulated to us, you have the right to lodge a complaint with the competent data protection authority of your choice.

9. How do we handle your personal data?

9.1. Security Measures.

9.1.1. We provide and implement industry-standard physical, electronic and procedural safeguards to protect our users’ Personal data we collect, process and maintain. Data that we receive is stored in encrypted form and can be available only to authorized employees, subcontractors, who preliminary have concluded Data Processing Agreement.

9.1.2. If you have any doubts or reason to believe that your interaction with our Application is no longer secure and safe, please immediately notify us by contacting us via email at [[email protected]. or owners email]

9.2. Retention of your personal data.

9.2.1. We retain your personal data as long as our Application is installed on your Devices but in any case no longer as it is necessary to fulfill the purposes described in this Privacy Notice, unless legislation obliges us to store personal data longer.

10. How can you manage your personal data?

10.1. In case you would like to review, update, change or delete any Personal data which we received and store about you, you can email us directly to [email protected]. or owners email]. Also, please note that you have rights such as a right to object or restrict processing and a right to data portability, or the right to be forgotten, you can email us directly to [email protected].or owners email].

11. Minors Policy

11.1. However our Application is accessible for adults and children, we do not purposefully or knowingly collect or solicit Personal data from anyone under the age of 16 (sixteen). If you believe or have any suspicions or reasons to believe that a minor has disclosed data to us, please contact us at [email protected]. or owners email]. In case you are under 16 years old, please do not attempt to send any Personal data about yourself to us. If we learn that we have collected personal data from a child under age 16, we will delete that data as promptly as possible. If you believe or have any suspicions or reasons to believe that a minor has disclosed data to us, please contact us at [email protected]. or owners email].

11.2. We take care that our Application that is easy to access to children is appropriate for children.

11.3. Also, we declare that: we do not collect any sensitive information and data related to children, such as microphone and camera sensor data. we do not transfer the User's location data to any third parties; we do not collect and transfer any User’s sensitive personal data to the third party without obtaining prior consent for such transfer.

12. Privacy and Subscription

12.1 We want you to be completely informed of our Subscription and Refund Policy. This policy is based on the basic rules and principles set out in the Google Policy. Therefore, from time to time you may receive some notification that will contain price terms and details of our subscription offer or some updates. For more details, you may check our Subscription and Refund Policy which is located in the Terms Of Use web-page at this and our website.

13. How do we update this Privacy Notice?

13.1 Applicable law and our practices may change over time. If we decide to update our Privacy Notice, we will publish the changes in our Application and on our Application Website. We strongly encourage you to read our Privacy Notice from time to time and keep yourself informed of our practices.

14. For European residents

14.1 While collecting and processing the Application’s users’ personal data, we adhere to the rules stipulated by the provisions of the General Data Protection Regulations. We invite you to read the text of the GDPR by clicking here.

14.2 We have a designated service provider, acting as Data Protection Officer - LLC “STALIROV AND COMPANY”, executing all DPO’s obligations and functions under articles 36 and 97 of the GDPR, since we process significant amounts of personal data. We occasionally audit and evaluate our system for compliance with the requirements of the GDPR and applicable law. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. In any case, you may contact our DPO by email:

15. For California residents

15.1 If you are a California resident, you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. We invite you to read the text of the CCPA by clicking here.

15.2 If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. If you are under 18 years of age, reside in California, and have installed the App, you have the right to request removal of unwanted data that you publicly post on the App, if applicable. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed in the App, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

15.3 CCPA Privacy PolicyThe California Code of Regulations defines a "resident" as: every individual who is in the State of California for other than a temporary or transitory purpose and every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are defined as "non-residents."

15.4 If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

15.5 Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

15.6 We may use your personal information for our own business purposes, such as but not limited to for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information.

15.7 If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

15.8 Right to be informed — Request to know Depending on the circumstances, you have a right to know: whether we collect and use your personal information; the categories of personal information that we collect; the purposes for which the collected personal information is used; whether we sell your personal information to third parties; the categories of personal information that we disclosed for a business purpose; the categories of third parties to whom the personal information was disclosed for a business purpose; and the business or commercial purpose for collecting personal information.

15.9 In accordance with applicable law, we are not obligated to provide or delete consumer information that is deidentified in response to a consumer request or to re-identify individual data to verify a consumer request.

15.10 Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights. Upon Verification process after receiving your request we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us.

15.11 We may also use other verification methods as the circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification.

15.12 However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud prevention purposes.

15.13 We will delete such additionally provided information as soon as we finish verifying you. Other privacy rights You may object to the processing of your personal information. You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information. You can designate an authorized agent to make a request under the CCPA on your behalf.

15.14 We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA. You may request to opt-out from future processing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission. To exercise these rights, you can contact us by email at [email protected], or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

16. Contacts

16.1. In case you have any questions related to our Privacy Notice, please, do not hesitate to contact us by mail: [email protected]. Usually, it takes up to 1 (one) month to send you the response to your request.

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