Table of Contents
- How We Collect Information
- Information We Collect That You Choose To Provide To Us
- What Information We Collect Automatically When You Use the italki Platform
- Information Provided to Us by Third Parties
- How We Use Your Information
- What Kinds of Information We Share
- Ways You Might Share Your Information through the italki Platform
- How We Keep Your Information Safe
- Where We Store Your Information
- Our Policies Regarding Children
- Your Choices and Controls
- How We Respond to Do Not Track Signals
- Contact Us
- Right to Contact a Data Protection Authority
1. How We Collect Information
We collect information: (i) that you choose to provide to us; and (ii) automatically through your use of the italki Platform. If you are a resident of the European Economic Area (the "EEA"), we rely on one of the following legal grounds to process information about you: (i) where we have your consent, (ii) where we have a legitimate interest to do so, (iii) where the processing is necessary for the performance of a contract with you, and (iv) where we need to comply with a legal or regulatory obligation.
2. Information We Collect That You Choose To Provide To Us
We collect information that you choose to provide to us, for example, when you create an account, manage your user profile, participate in any interactive features of the italki Platform, request our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support or otherwise communicate with us. The type of information we may collect includes your name, user name, country, telephone number, email address, postal address, photograph, avatar, password, security questions and answers, details about our products you use, details you provide in respond to surveys about our products, information you provide when seeking help from us, billing information, payment card number and account details, forum posts and comments and other contact or identifying information you choose to provide directly.
For your information, the Company has collected, both directly and through third parties, the following categories of personal information about consumers during the preceding twelve (12) month period:
- Identifiers, such as a real name, postal address, Internet Protocol address, account name, or other similar identifier;
- Audio, electronic, visual, thermal, olfactory, or other similar information of a living person;
- Professional or employment-related information; and
- Education information;
3. What Information We Collect Automatically When You Use the italki Platform
We automatically collect information about you including:
Device Information. We collect device-specific information when you access the italki Platform from a computer, mobile, and/or other device, including your hardware model, operating system and version, unique device identifiers, mobile network information, country of access, crash reports, request and referral URL’s and system activity details.
Software Information. We collect software-specific information about your use of the italki Platform, such as which version of our software and what updates you have installed or use, and the presence of required plug ins.
Use Information. We collect information about your use of the italki Platform, including the type of browser you use, the language you prefer, access times, pages viewed, user activity, interactions with other users, your internet protocol address and the page you visited before navigating to the italki Platform.
Information Collected by Cookies and Other Tracking Technologies. We use various technologies to collect information, and this may include sending cookies, web beacons, Flash Cookies (as defined below), or other tracking technologies.
- Cookies. Cookies are small data files stored on your hard drive or in device memory that helps us to improve the italki Platform and your experience, see which areas and features of the italki Platform are popular and count visits. For more information about cookies, and how to disable them, please see Section 11 (Your Choices and Controls) below.
- Web Beacons. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in the italki Platform or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
4. Information Provided to Us by Third Parties
In addition to the information that we collect directly from you, we also collect certain of your information from following third party sources.
App Stores or Distribution Channels. The italki Platform that are distributed through app stores or distribution channels, such as the Apple App Store, Google Play and other Chinese Android app store, may also request permission to automatically collect other information from your mobile or other device. The italki Platform may only collect such information with your authorization in accordance with your device operating system’s permission process.
Mobile Platforms. If you use or access the italki Platform on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information includes your username and/or device ID and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide. Our mobile products also may request additional personal information from you, such as push notification tokens, your precise location or contact list, and we will collect this information only if you give us your explicit consent.
We have identified the provider names of some of the third-party analytics and advertising services we use. We take no responsibility for the content or privacy practices of any third party services. We encourage you to carefully review the privacy policies of any third party services you access. Please see the links below to learn more about the data practices of our third-party service providers:
- Google Analytic: google.com/analytics
- Growing.io: growing.io
- Rakuten: https://rakutenadvertising.com/legal-notices/services-privacy-policy
5. How We Use Your Information
We may use information about you for various purposes, including to:
- Provide, maintain and improve the italki Platform;
- Provide and deliver the products and/or services you order and send you related information, including confirmations and invoices;
- Send you communications about products, services, offers, promotions, rewards or events offered by us and other companies and provide news and information we think will be of interest to you;
- Send you technical notices, updates, security alerts and support and administrative messages;
- Respond to your comments, questions, requests and provide customer service;
- Monitor and analyze trends, usage and activities in connection with the italki Platform;
- Personalize and improve the italki Platform and provide advertisements, content, suggested connections and features that match user profiles or activities;
- Process and deliver contest entries and rewards; and
- Link or combine with information we receive from others to help understand your needs and provide you with better service.
We retain your data only for as long as necessary to provide the service you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods: (i) mandated by law, contract or similar obligations applicable to our business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate business and financial records.
6. What Kinds of Information We Share
We will share personal information outside of the Company when we have your consent. We’ll ask for your explicit consent to share any sensitive personal information. We do not share your personal information with companies, organizations, or individuals outside of the Company except the following cases:
- With the Teacher of italki Platform in connection with providing Teaching Services to the Students;
- With other users of italki Platform in connection with the social features of the italki Platform (for example, your username and profile picture, you have accumulated in the italki Platform that may be visible to other users of the italki Platform, or information that you provide in your account registration for forum use and your forum comments may be visible to other forum users);
- In response to a request for information if we believe disclosure is required by or otherwise in accordance with any applicable law, regulation or legal process;
- To protect the rights, property and safety of the Company or others;
- Subject to applicable laws, in connection with any merger, sale of company assets or acquisition of all or a portion of our business; or
- With your consent or at your direction, including if we notify you through the italki Platform that the information you provide will be shared in a particular manner and you provide such information.
For your information, the Company has disclosed to third parties or service providers for business purposes the following categories of personal information about consumers during the preceding twelve (12) month period:
- Identifiers, such as an Internet Protocol address, account name, or other similar identifier;
- Audio, electronic, visual, thermal, olfactory, or other similar information;
- Professional or employment-related information;
- Education information; and
- Consumer profiles based on inferences drawn from the information provided above.
We do not sell any personal information about consumers. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. When we provide this information, we perform appropriate procedures so that the information does not identify you and we contractually prohibit recipients of the data from re-identifying this information to associate the information with you.
7. Ways You Might Share Your Information through the italki Platform
The italki Platform may offer social sharing features and other integrated tools (such as the Facebook or Twitter "Like" button and WeChat "Moments" feature), which let you share actions you take on the italki Platform with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide such features.
8. How We Keep Your Information Safe
We take commercially reasonable security measures to help protect information we collect about you from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. These security measures may include practices such as keeping your sensitive data on a secured server behind a firewall, and transmitting sensitive information (such as a credit card number) entered while using the italki Platform using secure socket layer technology ("SSL").Unfortunately, however, no security system is 100% secure, and we cannot guarantee that the information we collect from you will be free from unauthorized access by third parties. Unauthorized entry or use, hardware or software failure and other factors may compromise the security of user information. Your password is an important component of our security system, and as a result it is your responsibility to protect your password. Do not share your password with any third parties. If your password has been compromised for any reason, you should change your password immediately.
9. Where We Store Your Information
10. Our Policies Regarding Children
The italki Platform is not intended for children under the age of eighteen (18) (the "Child" or "Children"), and we do not knowingly collect any personal information from such Children. Children should not use or attempt to use the italki Platform, and if you are Children, please do not attempt to use the italki Platform or send any information about yourself to the Company.
In the event that we learn that we have inadvertently gathered personal information from a Child, we will take reasonable measures to delete such information from our records. Parents who believe that we might have gathered any information from or about a Child may submit a request to delete such information to write to our address listed in Section 13 (Contact Us) below.
11. Your Choices and Controls
We give you meaningful choices when it comes to important uses and collection of your information. To easily access, view, update, correct, delete or port your personal data, or to update your subscription preferences, please sign into your account and visit "Account Settings". Where we rely on consent to collect and use information about you, you can withdraw your consent at any time. If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any of the italki Platform purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.
Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the italki Platform. For more information, please visit: https://optout.networkadvertising.org opt-out page where you can learn more about NAI members who deliver tailored online ads and your choices to opt-out of receiving them.
Push Notifications. We may send push notifications or "alerts" to your device to provide information regarding the italki Platform, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notification settings via your device.
12. How We Respond to Do Not Track Signals
Because consumers are often unaware that their do not track beacons are active, do not track frequently does not reflect the actual preferences of our users. We currently do not respond to Do Not Track signals. In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings.
13. Contact Us
For Members that access and use of the italki Product:
Online Support: https://support.italki.com
For Members that access and use of the Lingbe Product:
14. Right to Contact a Data Protection Authority
If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority. Contact details for Data Protection Authorities in the EEA are available here.