PRIVACY POLICY

Last updated: October 22, 2025

This Privacy Notice for “LinguaClubs” app — referred to as “we”, “us”, or “our” — explains how and why we access, collect, store, use, and share (“process”) your personal information when you use our services (“Services”), including in the following situations:
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for how your personal information is processed. If you do not agree with our policies or practices, please refrain from using our Services. If you have any questions or concerns, feel free to contact us at contact@linguaclubs.com.

SUMMARY OF KEY POINTS

This summary highlights the key points from our Privacy Notice.
You can learn more about each topic by following the links provided after each key point or by using the table of contents below to navigate to the relevant section.


What personal information do we process?
When you visit, use, or interact with our Services, we may process personal information depending on how you engage with us, the choices you make, and the products or features you use. Learn more in the section on personal information you disclose to us .

Do we process any sensitive personal information? Some information may be considered “special” or “sensitive” in certain jurisdictions, such as your racial or ethnic origins, sexual orientation, or religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect information from third parties.

How do we process your information? We process your information to provide, improve, and manage our Services, communicate with you, ensure security and prevent fraud, and comply with applicable laws. We may also process your information for other purposes with your consent. We only process your information when we have a valid legal reason to do so. Learn more about how we process your information .

In what situations and with which types of parties do we share personal information? We may share your information in certain situations and with specific categories of third parties. Learn more about when and with whom we share your personal information .

How do we keep your information safe? We have appropriate organizational and technical measures in place to protect your personal information. However, no method of electronic transmission or storage can be guaranteed to be completely secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will never be able to bypass our security measures and improperly access, collect, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on your location, applicable privacy laws may grant you certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The simplest way to exercise your rights is by contacting us at contact@linguaclubs.com. We will review and respond to your requests in compliance with relevant data protection laws.

Want to learn more about how we handle the information we collect? Review our full Privacy Notice for complete details.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
  7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
  8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  9. HOW LONG DO WE KEEP YOUR INFORMATION?
  10. HOW DO WE KEEP YOUR INFORMATION SAFE?
  11. DO WE COLLECT INFORMATION FROM MINORS?
  12. WHAT ARE YOUR PRIVACY RIGHTS?
  13. CONTROLS FOR DO-NOT-TRACK FEATURES
  14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
  16. DO WE MAKE UPDATES TO THIS NOTICE?
  17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on our Services, express interest in learning about us or our products and Services, participate in activities on the Services, or otherwise contact us.

Personal Information Provided by You
The personal information we collect depends on how you interact with us and the Services, the choices you make, and the products or features you use. It may include the following:



Sensitive Information
We do not process sensitive information.
Social Media or other third party Login Data We may offer you the option to register using your existing social media account or other login service accounts, such as Google, Facebook, X, or others. If you choose this option, we will collect certain profile information from the social media or login service provider, as explained in the section "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data If you use our application(s), we may also collect the following information if you choose to provide us with access or permission:
This information is mainly used to maintain the security and proper functioning of our application(s), assist with troubleshooting, and support our internal analytics and reporting.

All personal information you provide must be true, complete, and accurate. Please notify us of any changes to your personal information.

Information automatically collected

Some information, such as your Internet Protocol (IP) address and your browser or device characteristics, is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate our Services. This information does not reveal your specific identity (such as your name or contact details) but may include device and usage data, like your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and details about how and when you use our Services. This information is mainly used to maintain the security and proper functioning of our Services, as well as for internal analytics and reporting.
The information we collect includes:

Google API

Our use of information obtained from Google APIs follows the Google API Services User Data Policy , including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to provide, improve, and manage our Services, communicate with you, ensure security and prevent fraud, and comply with applicable laws. We may process personal information for the purposes listed below, and for any other purposes only with your explicit prior consent.

We process your personal information for various purposes, depending on how you interact with our Services, including:

In Short: We only process your personal information when we have a valid legal reason under applicable law, such as with your consent, to comply with legal obligations, to provide services or fulfill contractual obligations, to protect your rights, or to pursue our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the legal bases for processing your personal information. Accordingly, we may rely on the following legal bases to process your personal information:
If you are located in Canada, this section applies to you.

We may process your information if you have given us explicit consent for a specific purpose, or in situations where your consent can be reasonably inferred (implied consent). You can withdrawing your consent at any time.

In certain exceptional circumstances, we may be legally allowed under applicable law to process your information without your consent. This may include situations such as:

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in certain situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers:** We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and need access to this information to carry out their work. We have contracts with these third parties to help protect your personal information. They are not allowed to use your information for any purpose other than what we instruct, and they will not share it with any organization other than us.

The categories of third parties with whom we may share personal information are as follows:

We may also need to share your personal information in the following situations:

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the security of any information you share with third parties who are linked to or advertise on our Services but are not affiliated with or part of our Services.

The Services may contain links to third-party websites, online services, or mobile applications, and may display advertisements from third parties who are not affiliated with us. We do not guarantee the accuracy, safety, or privacy of these third-party sites and are not liable for any loss or damage resulting from their use. Inclusion of a link does not imply our endorsement. Any data collected by third parties is not covered by this Privacy Notice. You should review the privacy policies of these third parties and contact them directly for questions.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, “AI Products”). These tools are designed to enhance your experience and provide innovative solutions. The terms outlined in this Privacy Notice apply to your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers (“AI Service Providers”), including OpenAI and Deepgram. As outlined in this Privacy Notice, your input, output, and personal information may be shared with and processed by these AI Service Providers to enable your use of our AI Products for the purposes described in WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION? .
You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

How We Process Your Data Using AI

All personal information processed through our AI Products is handled in accordance with this Privacy Notice and our agreements with third parties. We implement strong security measures and safeguards to protect your personal information throughout the process, helping ensure your data remains secure and giving you peace of mind.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services allow you to register and log in using your social media accounts, such as Google, AppleId, or Facebook. If you choose this option, we may receive certain profile information from the social media provider, including your name, email address, friends list, profile picture, and other information you make public. The exact data we receive depends on the social media platform and your privacy settings.

We will use the information we receive only for the purposes described in this Privacy Notice or clearly explained on the Services. Please note that we do not control, and are not responsible for, how your social media provider uses your personal information. We recommend reviewing their privacy policies to understand how they collect, use, and share your data, and how to manage your privacy settings on their platforms.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Germany. Regardless of your location, your information may be transferred to, stored, and processed in our facilities or those of third parties with whom we share your personal information (see " WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? "), including facilities in Germany and other countries.

If you reside in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please note that data protection laws in other countries may not be as comprehensive as those in your region. Nevertheless, we take all necessary steps to protect your personal information in line with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to safeguard your personal information, including using the European Commission's Standard Contractual Clauses for transfers between our group companies and with third-party providers. These clauses require all recipients to protect personal data from the EEA or UK in accordance with European data protection laws.

Our Standard Contractual Clauses are available upon request. We have also implemented similar safeguards with our third-party providers and partners, and additional details can be provided upon request.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We retain your information only as long as needed to fulfill the purposes described in this Privacy Notice, unless a longer retention period is required by law.

We retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer period is required or allowed by law (e.g., for tax, accounting, or other legal obligations). In any case, no information will be kept longer than the duration of your account with us.

When we no longer have a legitimate business reason to process your personal information, we will delete or anonymize it. If deletion is not immediately possible (for example, if it exists in backup archives), we will securely store and isolate the information until it can be deleted.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We protect your personal information using organizational and technical security measures.

We use reasonable technical and organizational measures to protect your personal information. However, no system is completely secure, and we cannot guarantee that hackers or unauthorized parties will never access, steal, or modify your data. While we strive to protect your information, any transmission to or from our Services is at your own risk. Always access the Services from a secure environment.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect or market information to individuals under 18 years old, or the minimum age allowed by law in your country.

We do not knowingly collect, request, or market personal information to anyone under 18 years old (or the minimum age permitted by law in your region), nor do we sell such data. By using our Services, you confirm that you are at least 18 or have parental or guardian consent for a minor’s use. If we discover that data has been collected from a user under this age, we will deactivate their account and promptly delete the information. If you believe we may have collected data from a minor, please contact us at contact@linguaclubs.com

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your place of residence — such as certain U.S. states, the European Economic Area (EEA), the United Kingdom (UK), Switzerland, or Canada — you may have specific rights that give you greater control over your personal data. You can review, update, or delete your account at any time, in line with the laws of your region.

In some regions (such as the EEA, UK, Switzerland, and Canada), you have specific rights under applicable data protection laws. These rights may include: (i) the right to request access to and receive a copy of your personal information;
(ii) the right to request correction or deletion of your data;
(iii) the right to restrict the processing of your personal data;
(iv) the right to data portability (where applicable);
(v) the right not to be subject to automated decision-making;


If a decision with legal or significant effects is made solely by automated means, we will notify you, explain the main logic involved, and provide an easy way to request a human review. In certain situations, you may also have the right to object to the processing of your personal information. You can exercise these rights by contacting us using the details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below.

We will review and respond to all requests in compliance with applicable data protection laws.

If you are located in the EEA or the UK and believe we are unlawfully processing your personal information, you have the right to file a complaint with your Member State data protection authority or the UK data protection authority .

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner .

Withdrawing your consent: If we rely on your consent to process your personal information (whether express or implied, depending on the law), you may withdraw it at any time. To do so, contact us using the details provided in the HOW CAN YOU CONTACT US ABOUT THIS NOTICE? section below.

However, withdrawing your consent will not affect the legality of any processing carried out before your withdrawal. Where permitted by law, it will also not impact processing based on legal grounds other than consent.

Opting out of marketing and promotional communications: You may unsubscribe from our marketing emails at any time by clicking the “unsubscribe” link in our messages or by contacting us using the details provided in the “ HOW CAN YOU CONTACT US ABOUT THIS NOTICE? ” section below. Once you unsubscribe, you will be removed from our marketing lists. However, we may still contact you for essential non-marketing reasons — such as service updates, account administration, or responses to your support requests.

Account Information

If you wish to review, update, or delete your account information at any time, you can:

When you request to close your account, we will deactivate or remove your information from our active databases. Some data may be retained in our records to prevent fraud, resolve issues, support investigations, enforce legal agreements, or comply with legal obligations.

If you have any questions or concerns about your privacy rights, you can email us at contact@linguaclubs.com .

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers, some mobile operating systems, and certain apps offer a Do-Not-Track (DNT) feature that lets you signal your preference not to have your online activity monitored. Currently, there is no universal standard for recognizing or implementing DNT signals, so we do not respond to them at this time. If a standard is established in the future that we must follow, we will update this Privacy Notice to reflect that change.

California law requires us to disclose how we handle Do-Not-Track (DNT) signals from web browsers. Since there is currently no established industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you live in California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have certain rights regarding your personal information. These include the right to access, correct, receive a copy of, or delete your data, as well as the right to withdraw consent for its processing. Some of these rights may be subject to legal limitations.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not necessarily reflect all personal information we collect from you. For a comprehensive overview of all personal information we process, please refer to the section “ WHAT INFORMATION DO WE COLLECT? ”.
Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name Yes
B. Personal information as defined in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information Yes
C. Protected classification characteristics under state or federal law Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data Yes
D. Commercial information Transaction information, purchase history, financial details, and payment information NO
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements NO
G. Geolocation data Device location NO
H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities Yes
I. Professional or employment-related information Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us NO
J. Education Information Student records and directory information NO
K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics NO
L. Sensitive Personal Information No
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail, such as in the context of:

We will use and retain the collected personal information as needed to provide the Services for: As long as the user has an account with us or as needed to provide you services.

Sources of Personal Information

Learn more about the sources of personal information we collect in the section " WHAT INFORMATION DO WE COLLECT? ".

How we use and share Personal Information

Learn more about how we use your personal information in the section, " how we process your information ".

Will your information be shared with anyone else?

We may disclose your personal information to our service providers under a written contract between us and each provider. For more details, see the section “ WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may use your personal information for our own business purposes, such as conducting internal research for technological development and demonstration. This is not considered the “selling” of your personal information. We have not sold or shared any personal information with third parties for business or commercial purposes in the past twelve (12) months. However, we may have shared certain categories of personal information with third parties for operational purposes, such as providing services or support:


The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under " WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? ".

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in some cases, we may decline your request as permitted by law. These rights include:

Depending on your state of residence, you may also have the following rights:

How to exercise your rights

To exercise these rights, you can contact us by emailing us at contact@linguaclubs.com or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you may designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent if they do not provide valid proof of authorization to act on your behalf in accordance with applicable laws.

Request verification

Upon receiving your request, we will verify your identity to confirm that you are the person about whom we hold information. We will use only the personal information provided in your request for this verification. If we cannot confirm your identity with the information we already have, we may ask you to provide additional details for identity verification and for security or fraud-prevention purposes.

If you submit a request through an authorized agent, we may need additional information to verify your identity before processing the request. The agent must also provide a written and signed authorization from you to act on your behalf.

Appeals process

Under certain US state data protection laws, if we decline your request, you may appeal by emailing us at contact@linguaclubs.com . We will respond in writing, explaining any actions taken or not taken. If your appeal is denied, you may file a complaint with your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, allows California residents to request and obtain, once a year and free of charge, information about the categories of personal information we disclosed to third parties for direct marketing purposes, as well as the names and addresses of those third parties for the previous calendar year. To make such a request, California residents should contact us in writing using the details provided in the section" HOW CAN YOU CONTACT US ABOUT THIS NOTICE? ".

15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights depending on the country in which you reside.

Australia and New Zealand

We collect and process your personal information in accordance with the requirements of Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020.

This Privacy Notice fulfills the requirements outlined in both Privacy Acts, specifying what personal information we collect, the sources of that information, the purposes for which it is used, and the parties with whom it may be shared.

If you choose not to provide the personal information required to fulfill its intended purpose, it may affect our ability to deliver certain services, including:



At any time, you have the right to request access to or correction of your personal information. You can do so by contacting us using the details provided in the section “ HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner or about a breach of New Zealand’s Privacy Principles to the Office of the New Zealand Privacy Commissioner .

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the details provided in the section “ HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? ”.

If you are unsatisfied with the way we handle any complaint regarding our processing of personal information, you may contact the relevant data protection authority. Their contact details are:

The Information Regulator (South Africa) General enquiries: enquiries@inforegulator.org.za Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za

16. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by a revised date at the top of this Privacy Notice. If we make material changes, we may notify you by prominently posting a notice of such changes or by sending you an email message to registered with us email address. We encourage you to review this Privacy Notice regularly to stay informed about how we are protecting your information.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at contact@linguaclubs.com

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or your state of residence in the US, you may have the right to request access to the personal information we collect from you, obtain details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please send us an email at contact@linguaclubs.com