1. General

This Privacy Policy (“Policy”) describes how VILLA. and its related companies (“we,” or “us,” or “Company”) collect, use and share personal information of users of the VILLA mobile application (“VILLA” or the “App”), this website (the “Site”) and other services provided by the Company (the App, the Site, and such services shall be collectively referred to as the “Service”). This Policy also applies to any of our other mobile applications or websites that post this Policy. This Policy does not apply to websites that post different statements.

2.    Information We Collect

This Privacy Policy explains how we collect, use and share your personal data.

Information you provide

Through the registration process, you will provide us with your name, e-mail address (or parent’s e-mail address), and age or date of birth. You will also provide us with your payment transaction information if you choose to pay for VILLA services.

Activity Data

When you use the Service, you will submit information and content to your profile. We will also generate data about your use of our Services including your engagement in educational activities on the Service, or your sending of messages and otherwise transmitting information to other users. We also collect technical data about how you interact with our Services.

Speaking practice

When you take a Speaking Lesson, we will use your computer's microphone throughout the lesson to speak to your “APP tutor”. VILLA records these audio and video lessons and retains them until you close your VILLA account. VILLA uses this data to help improve the quality of the lessons and for internal research purposes.

VILLA does not share any of your personal data with your tutor. VILLA only shares some basic skill level information with the tutor, prior to your lesson, so they understand how best to speak to you.

Product Research and Development

We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We will record the video, audio and text transcriptions of this feedback together with any additional contact information you provide and will retain this data for two years.

3. Use of information obtained by VILLA

We use your personal information for the following purposes:

• To operate, maintain, and improve our sites, products, and services.

• To otherwise operate, maintain, and improve our sites, products, and services.

• To analyze your usage of the App for the purpose of improving our App.

• To find and connect with your friends (when instructed by you).

• To provide custom, personalized advertisements, content, and information.

• To let your friends know about your activity on VILLA.

• To respond to comments and questions and provide customer service.

• To send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

• To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners. The legal bases for our processing of your personal information are our obtaining your consent for the processing of your personal information for the foregoing purposes, and the fact that such processing is necessary for us to render the Service. We retain your personal information to provide the Service to you and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; otherwise, we will delete your personal information immediately after you terminate your account.

4. Sharing your personal data with third parties

VILLA shares your personal data only when it is necessary to offer the Service, legally required, or permitted by you.

These data processors help us bring you the Service. For example, we may share your information in order to detect where or how you encountered a bug when using our mobile application. In connection with these operations, our service providers will have access to personal data for a limited time. When we utilize service providers for processing any personal data, we implement contractual protections limiting the use of that personal data to the provision of services to VILLA.

We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the VILLA name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies.

VILLA will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service.

5. Data retention

We will retain your personal information for as long as your account is active, and as long as is reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

6. Advertisement and remarketing

We may allow other companies, called third party ad servers or ad networks, to serve advertisements within the Site or the App. These third party ad servers or ad networks use technology to send, directly to your browser, the advertisements and links that appear on the Site. They automatically receive your IP Address when this happens. They may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize their advertising content. Further, these advertisers may also serve ads to you on other websites (including ads for our products and services) based on information collected from you while using the Site. For example, we may use Google’s “remarketing” service to target our ads to you based on your prior use of the Site or the App when you visit on other sites in Google’s content network.

You should be aware that advertisers may target advertisements to users based on certain user characteristics. If you respond to this type of targeted advertisement, the advertiser or ad server may conclude that you fit the description of the audience they were trying to reach. Our Privacy Policy does not apply to, and we cannot control the activities of, such ad servers, ad networks, or their advertiser clients.

7. Information security

VILLA has implemented administrative and technical safeguards it believes are appropriate to protect the confidentiality, integrity and availability of your personal data, Testing ID, User Photo, access credentials. However, given sufficient resources, a determined attacker could defeat those safeguards and may, as a result, gain access to the data we seek to protect.

8. Links

The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave the Service to read the privacy statements of other websites that collect personally identifiable information. This Privacy Policy applies only to information collected by VILLA via the Service.

9.  Children

Consistent with the federal Children's Online Privacy Protection Act of 1998 (COPPA), we do not knowingly collect personally identifiable information from anyone under the age of thirteen (13) without parental consent. Any person who provides their personal information to us through the Site represents that they are 13 years of age or older. We ask for and store users’ date of birth to ensure they are 13 or older, but do not share that information unless the user chooses to share it on the user’s profile. If you believe that we have collected information from an individual under the age of 13, please contact us so that we may take appropriate steps to address the issue.

10. Contact us

If you have questions, comments or complaints about this Privacy Policy or our privacy practices, or would like to exercise any of your rights and choices under this Privacy Policy or applicable law, you may contact our Data Protection Officer at the following email address: tamtue.com@gmail.com