Privacy Policy

Privacy policy for Dot Languages mobile application and services

Privacy policy

We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) in the “Dot Languages” mobile application (“Mobile Application” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and Dot Languages (“Dot Languages”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Mobile Application and Services. By accessing and using the Mobile Application and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Table of contents

  • Collection of personal information
  • Sensitive personal information
  • User-generated content and shared data
  • Cookies and tracking technologies
  • Privacy of children
  • Use and processing of collected information
  • Artificial intelligence and automated decision-making
  • Payment processing
  • Managing information
  • Disclosure of information
  • Retention of information
  • Transfer of information
  • Data protection rights under the GDPR
  • Data protection rights under the UK GDPR
  • California and US state privacy rights
  • Brazil (LGPD) privacy rights
  • How to exercise your rights
  • Email marketing
  • Links to other resources
  • Information security
  • Data breach
  • Changes and amendments
  • Acceptance of this policy
  • Contacting us

Collection of personal information

You can access and use certain features of the Mobile Application and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered in the Mobile Application, you may be asked to provide certain Personal Information (for example, your name and e-mail address).

We receive and store any information you knowingly provide to us when you create an account, publish content, upload or share user-generated content, interact with other users, make a purchase, or fill any forms in the Mobile Application. When required, this information may include the following:

  • Contact information (such as email address, phone number, etc.)
  • Basic personal information (such as name, date of birth, country of residence, preferred language, etc.)
  • Account credentials (such as username, unique user ID, and password)
  • Profile information (such as profile picture, bio, learning preferences, and language proficiency level)
  • User-generated content (such as text, audio recordings, images, videos, comments, and other materials you create, upload, or share through the Service)
  • Communication data (such as messages, comments, feedback, and interactions with other users)
  • Transaction and billing information (such as purchase history, subscription details, and payment-related identifiers)

We also automatically collect certain information when you use the Mobile Application, including:

  • Device information (such as device type, operating system, unique device identifiers, and mobile network information)
  • Log and usage data (such as access times, pages viewed, features used, learning activity, and the page you visited before navigating to our Service)
  • Location data (such as IP address, and where applicable and with your consent, approximate or precise geolocation)
  • Performance data (such as crash reports, load times, and diagnostic information)

Some of the information we collect is directly from you via the Mobile Application and Services. However, we may also collect Personal Information about you from other sources such as public databases, social media platforms, third-party data providers, and our joint marketing partners. Personal Information we collect from other sources may include demographic information, such as age and gender, device information, such as IP addresses, location, such as city and state, and online behavioral data, such as information about your use of social media websites, page view information and search results and links.

You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features in the Mobile Application. Users who are uncertain about what information is mandatory are welcome to contact us.

Sensitive personal information

Certain categories of Personal Information are considered “sensitive” under applicable laws. We may collect the following categories of sensitive Personal Information in connection with the Services:

  • Audio data (such as voice recordings made during pronunciation exercises or speaking practice features)
  • Precise geolocation data (only when you have granted explicit consent through your device settings)
  • Account login credentials in combination with any required security or access code, password, or similar credentials allowing access to an account
  • Information related to a child under the age of 13 (or such other age as defined under applicable law), as described in the “Privacy of children” section below

We process sensitive Personal Information only for the purposes of providing and improving the Services, and as otherwise permitted or required by applicable law. Where required by law, we obtain your explicit consent before collecting or processing sensitive Personal Information. You may have the right to limit or restrict the use or disclosure of your sensitive Personal Information as described in the applicable rights sections of this Policy.

User-generated content and shared data

The Mobile Application includes features that allow you to create, upload, share, and interact with content created by other users (“User-Generated Content” or “UGC”). When you use these features, please be aware of the following:

Content you share publicly or with other users. Any content you upload, post, or share through the Service may be viewable by other users. You should not include Personal Information in your UGC that you do not wish to make publicly accessible. We are not responsible for the Personal Information you choose to include in your UGC.

Content that includes third-party information. If your UGC contains information about other individuals (such as their name, image, or voice), you represent that you have obtained all necessary consents from those individuals and have the legal right to include their information in your content.

How we process UGC. We may process your UGC for the following purposes: hosting and distributing it as you direct; enforcing our Terms of Service and Community Guidelines; detecting illegal or infringing content; improving and developing the Service and its features; aggregated analytics and research; and such other purposes as described in the “Use and processing of collected information” section of this Policy. We may use automated tools to scan, filter, or review UGC for compliance, safety, and quality purposes. Details about content licensing are set forth in our Terms and Conditions.

Interactions with other users. When you interact with other users through the Service (such as by commenting on, liking, or sharing their content), certain information about you may be visible to those users, including your username, profile picture, and the nature of your interaction.

Cookies and tracking technologies

We use cookies, pixels, software development kits (SDKs), and similar tracking technologies (collectively, “Tracking Technologies”) to collect and store certain information when you use the Mobile Application and Services.

Types of Tracking Technologies we use:

  • Essential/Functional Technologies: Required for the operation of the Service, including authentication, security, and accessibility features. These cannot be disabled.
  • Analytics Technologies: Help us understand how users interact with the Service, which features are most popular, and how we can improve the experience. These may include third-party analytics services.
  • Performance Technologies: Monitor application performance, identify errors, and help us maintain and improve the Service. We do not serve advertisements in the Mobile Application. We do not use advertising or marketing Tracking Technologies and we do not share your data with advertising networks.

Third-party analytics partners. We may use third-party analytics services (such as Firebase Analytics, Amplitude, or similar services) that use their own Tracking Technologies to collect information about your use of the Service. These third parties may use this information to provide analytics services to us in accordance with their own privacy policies.

Your choices. Where required by applicable law, we will obtain your consent before placing non-essential Tracking Technologies. You may manage your preferences through the consent management tools provided in the Mobile Application, or through your device settings. Please note that disabling certain Tracking Technologies may affect the functionality of the Service.

For EU/EEA and UK users, we comply with applicable requirements under the ePrivacy Directive and local implementing legislation regarding the use of Tracking Technologies. Non-essential cookies and tracking will not be activated until you have provided affirmative consent, and you may withdraw your consent at any time through the settings within the Mobile Application.

Privacy of children

The Mobile Application is designed as an educational language learning service for users of all ages, including young children. We recognize the need to provide further privacy protections with respect to Personal Information we may collect from children and take special precautions to protect their privacy. For the purposes of this Policy, a “child” means a user under the age of 13 in the United States, under the age of 16 in the European Economic Area (unless the applicable EU member state has set a lower age, but not below 13), and under the age defined by applicable law in other jurisdictions.

Information we collect from children. We may require a child to disclose limited Personal Information to use the Mobile Application and Services. We do not collect more information from children than is reasonably necessary to provide the Services, and Personal Information collected from children will not be used or disclosed for purposes other than those for which it was collected. We do not require children to disclose more Personal Information than is reasonably necessary to participate in the applicable activity.

Parental consent. Where required by applicable law (including the US Children’s Online Privacy Protection Act, as amended), we obtain verifiable parental consent before collecting, using, or disclosing Personal Information from children. We will provide direct notice to parents of our data collection practices and obtain consent through a method reasonably calculated to ensure that the person providing consent is the child’s parent or legal guardian.

Separate consent for third-party disclosure. We will obtain separate, additional verifiable parental consent before disclosing a child’s Personal Information to third parties, unless the disclosure is necessary to provide the Services, protect safety, or comply with legal obligations.

No advertising. We do not serve any advertisements in the Mobile Application, including to children. We do not use children’s Personal Information for profiling, automated decision-making, or marketing purposes.

Privacy by default. All information created or submitted by a child is set to private by default, meaning only the User who submitted it may view it. Children’s accounts have enhanced privacy settings that restrict the sharing of UGC and interaction with other users.

Data retention limits for children. We retain children’s Personal Information only for as long as reasonably necessary to fulfill the purpose for which it was collected. We do not retain children’s Personal Information indefinitely. When the information is no longer needed, or when a parent requests deletion, we will promptly and securely delete or de-identify it.

Parental rights. Parents and legal guardians have the right to: review the Personal Information we have collected from their child; request that we delete the Personal Information we have collected from their child; refuse to allow any further collection or use of their child’s Personal Information; and withdraw consent previously provided. To exercise these rights, parents or guardians may contact us using the information provided in the “Contacting us” section.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Mobile Application and Services without their permission.

Use and processing of collected information

We act as a data controller and a data processor when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.

Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Mobile Application and Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information and we comply with data controllers’ obligations set forth in applicable data protection laws.

We act in the capacity of a data processor in situations when you submit Personal Information through the Mobile Application and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller.

In order to make the Mobile Application and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:

  • Create and manage user accounts
  • Deliver, operate, and improve the Mobile Application and Services
  • Personalize learning experiences, content recommendations, and user interfaces
  • Enable user-generated content features including hosting, distributing, and displaying content you upload or share
  • Enable interaction between users, including comments, messages, and collaborative features
  • Moderate content and enforce our Terms of Service and Community Guidelines
  • Detect, investigate, and prevent illegal content, intellectual property infringement, fraud, and security threats
  • Process transactions and manage subscriptions
  • Communicate with you, including sending service-related notices, updates, and promotional communications (where permitted)
  • Conduct analytics, research, and reporting to understand usage patterns and improve the Service
  • Train, develop, and improve machine learning models and artificial intelligence features used in the Service (using aggregated or de-identified data where feasible)
  • Comply with legal obligations, enforce our agreements, and protect our rights and the rights of others
  • Protect from abuse and malicious users

Processing your Personal Information depends on how you interact with the Mobile Application and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Artificial intelligence and automated decision-making

We may use artificial intelligence (“AI”), machine learning, and automated decision-making technologies in connection with the Mobile Application and Services. These technologies may be used for the following purposes:

  • Personalizing learning content, recommendations, and difficulty levels based on your performance and behavior
  • Providing language assessment, scoring, and feedback on exercises and activities
  • Analyzing pronunciation and speech patterns through audio processing features
  • Automatically moderating and reviewing user-generated content for compliance with our policies and applicable laws
  • Detecting and preventing fraud, abuse, and security threats
  • Improving the quality and effectiveness of the Service through aggregated data analysis

Your rights regarding automated decision-making. To the extent that any automated processing produces legal effects concerning you or similarly significantly affects you, you have the right to: (i) be informed that such automated decision-making is taking place; (ii) receive meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing; (iii) object to the processing; and (iv) request human intervention, express your point of view, and contest the decision.

These rights apply under the EU and UK GDPR, the California Privacy Rights Act (CPRA), and other applicable data protection laws. To exercise these rights, please contact us using the information provided in the “Contacting us” section.

AI training data. We may use aggregated, de-identified, or anonymized data derived from user interactions and content to train and improve our AI and machine learning models. We do not use individually identifiable Personal Information for AI training without your consent or another lawful basis, except where the data has been sufficiently aggregated or de-identified such that it can no longer be linked to any individual. Where required by applicable law (including the EU AI Act and California AB 2013), we will provide additional transparency about our AI systems and training data upon request.

Payment processing

In case of Services requiring payment, you may need to provide your credit card details or other payment account information, which will be used solely for processing payments. We use third-party payment processors (“Payment Processors”) to assist us in processing your payment information securely.

Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over a SSL secured communication channel and is encrypted and protected with digital signatures, and the Mobile Application and Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.

Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. The Payment Processors’ use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.

Managing information

You are able to access, update, and delete certain Personal Information we have about you. The Personal Information you can manage may change as the Mobile Application and Services change. When you update or delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and for the other purposes described in this Policy.

You can manage your Personal Information by: accessing and updating your account settings within the Mobile Application; deleting specific content or data you have submitted; adjusting your privacy and sharing preferences for user-generated content; managing your notification and communication preferences; and contacting us to request access, correction, or deletion of your data.

Disclosure of information

Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with the following categories of recipients:

  • Affiliates and related companies. We may share your information with our affiliates and related companies for the purposes described in this Policy.
  • Service providers. We share your information with contracted companies and service providers (“Service Providers”) we rely upon to assist in the operation of the Mobile Application and Services, including hosting providers, analytics services, content delivery networks, content moderation services, customer support tools, email service providers, and payment processors. Service Providers are given only the information they need to perform their designated functions and are not authorized to use or disclose your information for their own marketing or other purposes.
  • Other users. When you use UGC features, certain information (such as your username, profile picture, and content you share) will be visible to other users of the Service as directed by you and in accordance with your privacy settings.
  • Legal and regulatory authorities. We may disclose Personal Information if required or permitted by law, such as to comply with a subpoena, court order, or similar legal process, to cooperate with regulatory authorities, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • In connection with business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, dissolution, or other transaction or proceeding involving transfer of all or a portion of our business to another company. In such event, we will endeavor to direct the transferee to use Personal Information in a manner consistent with this Policy.

We will not sell your Personal Information to third parties. We will not share your personally identifiable information with unaffiliated third parties for their own direct marketing purposes without your consent.

Retention of information

We retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements, and to enforce our agreements. The retention period varies depending on the context of the processing and our obligations:

  • Account information: Retained for as long as your account is active, plus a reasonable period thereafter to allow for account reactivation, comply with legal obligations, and enforce our agreements.
  • Transaction and billing data: Retained for the period required by applicable tax, financial, and commercial laws, typically up to 60 months after the last transaction.
  • User-generated content: Retained for as long as your account is active and a commercially reasonable period after deletion to account for cached, archived, or distributed copies. Content that has been shared with or downloaded by other users may persist beyond account deletion, and our license to such content continues as described in our Terms and Conditions.
  • Children’s data: Retained only for as long as reasonably necessary to fulfill the purpose for which it was collected, and promptly deleted or de-identified when no longer needed or upon parental request.
  • Analytics and aggregated data: Anonymized or aggregated data that can no longer identify you may be retained indefinitely for research, analytics, and service improvement purposes.
  • Legal and compliance data: Retained for the period required by applicable laws and regulations, including for the establishment, exercise, or defense of legal claims.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the applicable retention period expires, Personal Information shall be securely deleted or anonymized. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

Transfer of information

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. The Service operates globally, and your information may be transferred to and processed in countries where our servers, affiliates, or service providers are located, including countries outside the European Economic Area (“EEA”), the United Kingdom, and Switzerland.

Transfers from the EEA, UK, and Switzerland. Where we transfer Personal Information from the EEA, UK, or Switzerland to a country that has not been deemed to provide an adequate level of data protection, we rely on appropriate safeguards, including:

  • The EU-US Data Privacy Framework (DPF), the UK Extension to the DPF, and/or the Swiss-US DPF, where the recipient is a certified participant
  • Standard Contractual Clauses (“SCCs”) approved by the European Commission or the UK Information Commissioner’s Office, as applicable, together with supplementary technical and organizational measures where necessary
  • Adequacy decisions adopted by the European Commission or the UK Secretary of State
  • Other legally recognized transfer mechanisms under applicable data protection law

We conduct transfer impact assessments where required to evaluate whether the legal framework of the recipient country provides adequate protection for your Personal Information, and we implement supplementary safeguards (including encryption and access controls) where necessary.

You may obtain a copy of the relevant transfer safeguards by contacting us using the information provided in the “Contacting us” section.

Data protection rights under the GDPR

If you are a resident of the European Economic Area (“EEA”), you have certain data protection rights under the General Data Protection Regulation (“GDPR”) and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

(i) You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

(ii) You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.

(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.

(iv) You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.

(v) You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, exercise, or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.

(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise, or defense of legal claims.

(vii) You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.

(viii) You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such decision is necessary for entering into or performing a contract with you, is authorized by applicable law, or is based on your explicit consent.

(ix) You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority in the EEA. For more information, please contact your local data protection authority.

Data protection rights under the UK GDPR

If you are located in the United Kingdom, you have data protection rights under the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, which are substantially similar to the rights described in the GDPR section above. The Information Commissioner’s Office (“ICO”) is the supervisory authority for data protection in the United Kingdom.

In addition to the rights described above, the following applies specifically to UK residents:

UK Age Appropriate Design Code. Where applicable, we design and operate the Service in accordance with the principles of the UK Age Appropriate Design Code (the Children’s Code), including providing high privacy settings by default for users we identify as children, applying data minimization principles, keeping geolocation services off by default, and not using personal data in ways that are detrimental to children’s wellbeing.

Complaints. If you are not satisfied with how we handle your Personal Information or your privacy request, you have the right to lodge a complaint with the ICO at https://ico.org.uk/make-a-complaint/ or by calling their helpline.

California and US state privacy rights

California residents. If you are a California resident, you have certain rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”). This section describes those rights and how to exercise them.

You have the right to:

  • Know and access. Request that we disclose the categories and specific pieces of Personal Information we have collected about you, the categories of sources from which it was collected, the business or commercial purpose for collecting or selling it, and the categories of third parties with whom we share it.
  • Delete. Request the deletion of your Personal Information, subject to certain exceptions.
  • Correct. Request the correction of inaccurate Personal Information.
  • Opt out of sale or sharing. We do not sell your Personal Information and we do not share your Personal Information for cross-context behavioral advertising.
  • Limit use of sensitive Personal Information. You have the right to limit the use and disclosure of your sensitive Personal Information to the purposes necessary to provide the Services.
  • Non-discrimination. We will not discriminate against you for exercising any of your privacy rights.
  • Automated decision-making. You have the right to opt out of automated decision-making technology, including profiling, and to request information about any automated decision-making we engage in.

To submit a request, please contact us using the information in the “Contacting us” section. We will verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf.

We are required to disclose the following information regarding our data practices over the past 12 months:

  • Categories of Personal Information collected: Identifiers, personal information under California Civil Code Section 1798.80, commercial information, internet or electronic network activity information, geolocation data, audio data, inferences drawn from the above, and sensitive Personal Information as described in this Policy.
  • Categories of sources: Directly from you, automatically through your use of the Service, and from third-party sources as described in this Policy.
  • Business or commercial purposes for collection: As described in the “Use and processing of collected information” section.
  • Categories of third parties with whom we share Personal Information: Service providers, other users (for UGC features), and legal/regulatory authorities, as described in the “Disclosure of information” section.

Other US state residents. If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, Tennessee, Indiana, Minnesota, Nebraska, New Hampshire, New Jersey, Maryland, or another US state with an applicable comprehensive privacy law, you may have similar rights, including the right to access, correct, delete, and obtain a copy of your Personal Information; the right to opt out of the sale of Personal Information and profiling in furtherance of decisions that produce legal or similarly significant effects (note: we do not serve targeted advertising or sell Personal Information); and the right to appeal our decision regarding your privacy request. To exercise these rights, please contact us using the information in the “Contacting us” section.

Brazil (LGPD) privacy rights

If you are located in Brazil, you have certain rights under the Lei Geral de Protecao de Dados (“LGPD”), including the right to: confirmation of the existence of processing; access to your data; correction of incomplete, inaccurate, or outdated data; anonymization, blocking, or deletion of unnecessary or excessive data or data processed in non-compliance with the LGPD; portability of your data to another service or product provider; deletion of Personal Information processed with your consent; information about public and private entities with which we have shared your data; information about the possibility of denying consent and the consequences thereof; and withdrawal of consent. To exercise these rights, please contact us using the information in the “Contacting us” section.

How to exercise your rights

Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.

You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

We will respond to your request within the timeframes required by applicable law (typically 30 to 45 days, depending on the jurisdiction and complexity of the request). If we need additional time, we will inform you of the reason and the extended period.

If we decline to take action on your request, we will inform you of the reason and provide instructions for how to appeal our decision, where applicable under law.

Email marketing

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

The Mobile Application and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Mobile Application and Services and to read the privacy statements of each and every resource that may collect Personal Information.

Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. These measures include encryption of Personal Information in transit (using TLS/SSL) and at rest (using industry-standard encryption), access controls limiting access to Personal Information to authorized personnel on a need-to-know basis, regular security assessments and vulnerability testing, and employee training on data protection and privacy.

However, no data transmission over the Internet or wireless network can be guaranteed to be perfectly secure. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Mobile Application and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.

Data breach

In the event we become aware that the security of the Mobile Application and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.

In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. We will provide notification within the timeframes required by applicable law, including within 72 hours of becoming aware of the breach where required under the GDPR. When we do, we will send you an email and/or provide notice through the Mobile Application. The notification will include, to the extent known, the nature of the breach, the categories of data affected, the likely consequences, and the measures we have taken or propose to take to address the breach.

We will also notify the relevant supervisory authority where required by applicable law.

Changes and amendments

We reserve the right to modify this Policy or its terms related to the Mobile Application and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page, post the updated Policy within the Mobile Application, and, for material changes, provide notice to you through the Mobile Application or by email to the address associated with your account.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Mobile Application and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected. For material changes that affect the processing of children’s data, we will obtain new verifiable parental consent as required by applicable law.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Mobile Application and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Mobile Application and Services.

Contacting us

If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the following details:

Privacy inquiries: privacy@dotlanguages.com

General contact: contact@dotlanguages.com

EU/EEA representative: For users in the European Economic Area, you may contact our EU representative at the address above.

UK representative: For users in the United Kingdom, you may contact our UK representative at the address above.

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

This document was last updated on February 6, 2026