31.05.2020
LingTime Privacy Policy
LingTime is a learning service offered by 2Steps. Our services (“Services”) include a wide variety of beginner to advanced language content and courses. This content is available on applications (“Apps”) for Android operating system available to download on mobile devices.
This Privacy Policy explains what personal data (as defined below) we collect through the Services, how we use and share that data and your choices concerning our data practices.
This Privacy Policy forms part of our Terms of Use, which are available at https://lingtime.pl/terms.html
By providing us with your personal data when using the Services, you consent to the processing of your personal data as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Services.
1. PERSONAL DATA THAT WE COLLECT
When you interact with our Apps, we collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”).
Personal Data You Give Us. When you sign up for or use the Services, you voluntarily give us certain Personal Data, including:
email address
first name and last name
Google profile image
If you register for an account through your social media account (Google Sign-in), you may see which of your friends are using the Services. The information we get from these accounts depends on your settings and the privacy policies of the social media platforms, so please check those policies to understand the privacy practices of those platforms.
When you use the Services, you may generate learning data such as words, lessons, and progress within a course, which we will collect and store for use in connection with the Services.
We may also collect non-Personal Data, such as your time zone or language.
Automatically Collected Data: When you use the Services, the following information is created and automatically logged in our systems:
Log data: Information (“log data”) that the Apps automatically send. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from), the date and time of your request, and how you interacted with the Services.
Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.
Usage Information: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, the other users you interact with and the time, frequency and duration of your activities.
2. HOW WE USE DATA
We use the data we collect, described above:
To authenticate users, provide the Services, process transactions and respond to your requests. For users located within the EU, this use is necessary to perform the contract with you.
As necessary for certain legitimate business interests, which include the following:
To customise the learning experience and degree of difficulty to our users’ level and needs.
To conduct analytics to inform our marketing strategy and enable us to enhance and personalise our communications and the experience we offer to our users.
To conduct or assist research and prepare scholarly papers. We may share the information we collect in anonymised and de-identified form with researchers who help us to improve the Service’s learning tools. We may also use such information to publish papers on language learning.
Marketing. We will send you updates and information about our new products and services, upcoming events or other promotions or news by email or push notification. Where required by law, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving such emails by following the instructions contained in each promotional email we send you. We will continue to contact you via email regarding the provision of our Services and to respond to your requests.
If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, we will keep basic data to identify you and prevent further unwanted processing.
We may anonymise, de-identify and/or aggregate the information that we collect and use such anonymised, de-identified and/or aggregated data for commercial, statistical and market research purposes, including sharing it with affiliates and business partners.
For information on your rights under the applicable European Union (“EU”) law, please see the “Rights under EU Law” section below.
3. SHARING AND DISCLOSURE
Other users of the Services can see the profile information you upload to the Services including courses, learning scores.
We may share your Personal Data and other information with certain third parties in the following circumstances:
Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions your Personal Data may be shared with third-party providers of hosting, email communication and customer support services, analytics, marketing, advertising (Google, certified to the Privacy Shield).
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale of all or a portion of our assets, or transition of a service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction.
Legal Requirements: If required to do so by law, applicable regulation or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of 2Steps, (iii) act in urgent circumstances to protect the personal safety of users of the Apps, or the public, or (iv) protect 2Steps against legal liability.
4. DATA RETENTION
We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.
5. UPDATE YOUR INFORMATION
If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may do so yourself via your Settings.
6. CALIFORNIA PRIVACY DISCLOSURES
Residents of California have the right to: Know what personal information we collect about you and from where we collect it. Access a copy of the personal information we hold about you. Understand how we process your personal information and how it may be shared. Opt out of having your personal information shared with certain third parties. Request we delete your LingTime account and personal information. To make such a request, please contact us at support@lingtime.pl
7. RIGHTS UNDER EU LAW
Scope. This section provides information on your rights under EU law (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway).
Data Controller: 2Steps is the data controller for your Personal Data. Contact at support@lingtime.pl
Legitimate Interest: “Legitimate interests” means our interests in conducting our business, managing and delivering the best Services to you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.
Your Rights: Subject to EU law, you have the following rights in relation to your Personal Data:
Right of access: If we are processing your Personal Data you can view a copy of that Personal Data via Apps Settings.
Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to erasure: You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). You can also do this yourself via your Apps Settings. If we shared your data with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
If we are relying on a legitimate interest (described under the “How We Use Data” section above) to process your Personal Data -- unless we demonstrate compelling legitimate grounds for the processing; or
If we are processing your Personal Data for direct marketing.
Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.
Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorised to hear those concerns.
You may contact us at support@lingtime.pl to exercise your rights.
Changes. We will notify you of changes to the data processing activities described in this Privacy Policy by posting a prominent notice on the Apps, by email or as otherwise required by law.
8. PUBLICLY POSTED INFORMATION
This Privacy Policy shall not apply to any information you post to the public areas of the Services. Comments posted to public areas may be viewed, accessed, and used by third parties subject to those parties’ privacy practices and policies.
9. CHILDREN
2Steps does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to 2Steps through the Services please contact us at support@lingtime.pl and we will endeavour to delete that information from our databases.
10. LINKS TO OTHER WEBSITES
The Apps may contain links to other websites not operated or controlled by us (“Third Party Sites”), including social media websites and services. The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of such Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact those sites directly for information on their privacy practices and policies.
11. SECURITY
We take reasonable administrative and technical steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet is 100% secure. Therefore, while we strive to protect your data, we cannot guarantee its absolute security.
12. CHANGES TO OUR PRIVACY POLICY
We may change this Privacy Policy at any time and when we do we will post an updated version on this page. By continuing to use the Apps or providing us with information after we have posted an updated Privacy Policy you consent to the revised Privacy Policy and practices described in it.
13. CONTACT US
If you have any questions about our Privacy Policy or our data practices, please contact us at support@lingtime.pl.