DO NOT USE THE APP.
Linguado LLC (the “Linguado,” “we,” or “us”) owns and operates the App that provide access to an
online platform to link you with native speakers of the language of your choice, by proximity to you or worldwide.
will indicate this when we publish our revised policy. We may also inform you directly of the changes.
- Who Is Responsible for the Data Processing and How Can I Contact
Linguado is the data controller responsible for determining the purposes for which personal data
- What are the Types of Personal Data We Collect?
We collect personal data from people who use the App and from service providers or vendors who
provides services or items to us in support of the App and related programs and activities.
Personal Data of App Users
When you open an account and use the App, we and our service providers (including Google Analytics) collect and process certain of your personal data in order to help connect you with native speakers. We collect basic profile details, including your language and geographic preferences. We collect your name, e-mail address, online identifiers, and similar identifiers. We also collect geolocation data when you expressly permit it and allow this feature to be active on the App. Geolocation data includes tracking of physical locations and/or movements; however, we show other users only your general physical location, which you have the ability to switch on and off as you wish.
If you choose to request information from us in a direct email, we will process only the information you provide to us, namely your contact information (name and email address) and other information you provide in the message to us. We process this personal data to communicate directly with you, and
as needed to address your inquiry.
Personal Data of Representatives of Service Providers and Vendors
If you or your company provides goods or services to us, we will process personal data to fulfill the contract and maintain a business relationship with you. We process limited personal information for this purpose, such as contact name, address, email address and other contact details that you may provide to us to allow us to communicate with you.
- On What Legal Basis Do We Process Personal Data?
We process personal data in accordance with data privacy laws applicable to us in the context of
processing your personal data.
Lawful Basis for Processing Personal Data of the App Users
legitimate interests in performing the essential functions of the App and providing you with App services, as
well as to communicate with you in response to any inquiry or request you make of us. This includes using and
sharing data to help you make connections to other users, as requested by you.
Lawful Basis for Processing Personal Data of Service Providers and Vendors
We process personal data of our vendors and service providers for the legitimate interests of addressing our contractual obligations with them. Our processing of personal data allows us to provide or receive goods and services pursuant to these contracts or to carry out pre-contractual measures that occur as part of a request by a customer or service providers.
Other Legitimate Interests
Where required, we also process personal data for the purposes of other legitimate interests pursued by us or a third party. Such legitimate interests include the following:
- Asserting legal claims and defenses in legal disputes;
- As required by law including, but not limited to, to comply with a subpoena or other legal
process, regulatory requirement, judicial proceeding, or court order served on us, or to comply with
government reporting obligations;
- When we believe in good faith that disclosure is necessary (a) to protect our rights, the
integrity of the App, or your safety or the safety of others, (b) to detect, prevent, or respond to fraud,
the App, or (c) for corporate audits or to investigate or respond to a complaint or security threat; and
- To affiliates, service providers, advisors, and other third parties in connection with the
negotiation or completion of a merger, acquisition, or sale of all or a portion of our assets.
In each case where the legal basis for our processing is our legitimate interests, you have the right to object to the processing of your personal data by submitting your request to email@example.com, and we will consider and respond to the request in accordance with applicable law.
- Who Receives My Data?
Anyone within Linguado who requires the personal data to facilitate our mission, program and services, address related operational concerns, or fulfill our contractual and legal obligations will have access to it.
We may share your personal data with third parties only if necessary in the context of the
We will also share certain data with other users while you are using the App (to the extent you provide this
information in your App profile), such as the picture you chose to insert in the profile, languages you speak
and level of proficiency and languages you want to learn, your nationality, and your general location. You
control whether this information is shown or not. The parties with whom we share your personal data may be
located outside of the country where you accessed the App or where your information was originally collected.
- Will Data Be Transferred to a Third Country or an
Personal data collected by Linguado is stored in Germany, but the storage location may be changed
from time to time. Personal data we collect or receive from you may be transferred outside of the country where
you reside, including to countries outside Europe or to countries that have not been deemed to have the same
legal protections for personal data as your country. If the party receiving the data is located in a country
that has not been deemed to have adequate levels of legal protection for personal data as your country, the
party receiving your personal data will either be required to agree to standard data contractual clauses or have
in place another mechanism under which the party promises to safeguard the personal data it receives. Note
that the EU has determined that if an organization agrees to standard contractual clauses, the level of data protection is adequate.
- For How Long Will My Personal Data Be Stored?
We generally remove user data if you delete your account from the App. If required by law or by a legal order, we may process and store your personal data for a period consistent with the law or legal order or our contractual rights. For example, we may need to keep your personal data longer if necessary to fulfill obligations to preserve records under tax law or for accounting purposes, or if we are obligated to hold information because of a legal prohibition against removing or deleting the data.
- What Data Privacy Rights Do I Have?
Subject to some exceptions and limitations, you have several rights, including:
- The right to access, which allows you to obtain a copy of your personal data, on request;
- The right to rectification, which requires us to change incorrect or incomplete data about
- The right to restrict and object to processing, which requires us to limit or stop
processing your data under certain circumstances;
- The right to erasure, which requires us to erase your data; and
- If applicable, the right to data portability, which allows you to transfer your personal
data from the App to another entity if technically feasible.
You may exercise any of these rights by sending an email indicating your request to firstname.lastname@example.org.
If we ever process your personal data based on your consent as the lawful basis, you can withdraw consent by contacting us at email@example.com at any time. Please note that withdrawal of consent applies only to future actions. Processing that was carried out before the withdrawal of consent is not affected.
- Am I Obligated to Provide Personal Data?
In the context of responding to your inquiry or using our App, you must provide all personal data that is required (as applicable) for that purpose. Without this data, we are not able to address your request, provide you with services or facilitate opening your account.
- Will Linguado Use My Personal Data for Marketing?
We do not use or share personal data for third-party marketing purposes, unless you request information that may be considered marketing materials, in which case we send that information to you.
- Children’s Data
Individuals below the age of 18 are not permitted to use the App. The
App is not directed to, nor do we knowingly collect information from, anyone under the age of 18. If you become
aware that a child under the age of 13 has provided us with information via this the App without the consent of
a parent or guardian, please contact us at the contact information listed above.
- Security of Your Personal Data
We are committed to protecting our users’ personal data. We employ a range
of reasonable technical, administrative, and physical safeguards for securing personal data, including:
- Secure access to the App via unique user authentication controls
- Logging practices to aid auditing
- Patching of servers for security updates
- Regular risk assessments
While we take reasonable data protection precautions, no security measures are completely
effective, and we do not guarantee the security of user data at any time. We cannot guarantee, ensure, or
warrant the security of any information you transmit to us. There is no guarantee that information may not be
accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or administrative
safeguards. Even though there are many benefits to using our App, as with all electronic communications there
are some risks such as (i) failure of hardware, software and/or Internet connections; we are not responsible for
failures, distortions, delays, or other problems resulting from equipment configuration, connection, signal
power, hardware, software or any equipment used to access the internet; and (ii) no guarantee that the
confidentiality or security of electronic transmissions can be assured due to potentially unsecure devices and
links. This could result in your data becoming lost or intercepted during transmission. It is your
responsibility to protect the security of your login information and to use good judgment before deciding to
send information through the App. We will not be liable for any breach of the security measures on the App or
any loss, misuse, or alteration of information resulting therefrom.
The App can only be accessed after your username and password are accepted. This allows Linguado
to verify who you are and prevents unauthorized access to your data. You are responsible for:
- Selecting a long and complex password
- Changing your password at regular intervals
- Not sharing your password with anyone
- Not writing down your password
- Logging out of the site and not just closing the the App when you finish.
- Social Media and Links to Other Websites or Apps
App may also contain links to other third-party websites. Please be aware that we are not responsible for the
on this App. We encourage you to read the privacy policies of other websites and apps you link to from our App
or otherwise visit.
As a user, you can turn tracking on or off at any time on the App.
This Supplemental Policy (the “Supplement”) is part of our Privacy
Policy and is directed to you if you are a California resident and therefore have certain rights under the
When we operate as a “service provider” (as defined under the CCPA) for our customers and they provide us with your personal information for business purposes under a service contract, the CCPA applies primarily to those customers, not to us. In such cases, we will direct any requests you send us to exercise your rights under the CCPA to the applicable customer.
Information We Collect as a Business
We collect the following categories of personal information as defined under the CCPA:
Type of information
Collected by Us
Name, postal address, e-mail address, IP address, online identifiers, account name and similar identifiers.
Name, e-mail address, account name and similar identifiers
Information specified in California Consumer Records statute
Name, signature, postal address, telephone number, employment.
Name, telephone number
Protected classifications under California or federal law
Age, race, national origin, citizenship, religion or creed, marital
status, gender, sexual orientation, health status
Age and gender
Records of personal property, products, services purchased or
Genetic, physical, behavioral or biological characteristics, such as
fingerprints, iris scans, voiceprints, health/exercise or sleep data
Internet and similar network activity
Browsing history, analytics, app interactions.
Analytics, app interactions
Physical locations and/or movements
General location only
Audio, visual, or similar data related to physical characteristics
Audio, photo user selects for profile
Professional or employment-related information
Current employment or job history
Non-public educational information
Educational records under Federal law
Inferences drawn from other personal information
Profiling of preferences, personal characteristics, behavior, attitudes
Personal information does not include: (i) information publicly available from government
records, (ii) deidentified or aggregated information, or (iii) information addressed by certain state and
federal data privacy laws (e.g., personal health information subject to federal health privacy law).
Categories of Sources of Information We Collect
We obtain the categories of information described in this Supplement from the same categories of
Our Use of Personal Information
We use the personal information we collect, as described in this Supplement, for the same
Our Disclosure of Personal Information
We may disclose the personal information we collect, as described in this Supplement, for any of
the same purposes and to the same categories of persons and entities as identified in Sections 3 and 4 of our
Your Rights Regarding Your Personal Information
The CCPA gives certain rights to California residents regarding their personal information. We summarize below what those rights are and how you may exercise them. You do not need to have an account with us to exercise these rights.
The CCPA also gives California residents the right to opt out of--or for minors under 16, the
ability to opt in to-- sales of their personal information, although the App is not intended for use by anyone under 18. However, we do not and will not sell your personal
information. If, in the future, we decide to sell personal information, we will provide you with notice and the right to opt-out of (or for minors, opt-in to) such sales.
- Right to Know About the Collection, Use, Disclosure and Sale of Personal Information
- Upon providing us with a verified consumer request, you may ask us to disclose certain types of your personal information we have collected and used over the 12-month period prior to the date of your request. You may make this request only twice within any 12-month period. You may request:
- The categories of personal information we collected about you
- The categories of sources of the personal information we collected about you
- The business or commercial purpose for collecting that personal information
- The categories of third parties with whom we shared that information
- The specific pieces of personal information we collected about you (except to the extent
prohibited under CCPA including, for example, disclosure of Social Security numbers or other government,
health insurance or medical identification numbers, account passwords)
- If we disclosed your personal information for a business purpose, a list identifying the
personal information we disclosed to each category of recipient.
- Right to Request Deletion of Personal Information
- You have the right to submit a verified consumer request at any time that we delete any of your personal information collected and retained by us, unless an exception under the CCPA applies.
- If no exception applies, and if we have been able to verify your consumer request, we will delete, aggregate or de-identify your personal information from our records in accordance with the CCPA. We will also direct third parties to whom we have disclosed your personal information to delete it, although we cannot guarantee that such third parties will comply with our direction.
Please note that we may deny your deletion request if your personal information based on certain
provisions of the CCPA, including where it is necessary for us or our service providers to carry out certain
business functions, comply with laws or to engage in other internal and lawful uses of the information within
the context in which you provided it to us.
Making a verified consumer request to us
To make a request to exercise your rights under CCPA described above, please submit a verifiable request to us by emailing us at firstname.lastname@example.org
A verifiable consumer request must be made by you or a person registered with the California Secretary of State whom you have authorized to make the request on your behalf. (A representative must be authorized by you in writing or have a valid power of attorney under California probate law.) You may also make a verifiable request to us on behalf of your minor child.
To be considered a proper verified request, your request must:
(1) provide us with sufficient information allowing us to reasonably verify that you are the
same person about whom we collected the personal information or the authorized representative, and
(2) describe your request in reasonable detail so we can correctly understand, evaluate and respond to the request.
We may ask you for additional information if needed in order to verify your request, but if we
do, we will use such additional information only to verify your identity (or the authority of the
representative) and for security and fraud-prevention purposes.
We will also ask you to separately confirm, by e-mail to confirm any request to delete personal
Responding to your verifiable consumer request
We will use reasonable efforts to respond to your verifiable consumer request within 45 days of receiving it. If some cases, we may require more time (up to 90 days). If that is the case, we will communicate to you in writing (electronically) the reason and the length of anticipated delay. We will not be able to fulfill your request if we cannot verify your identity (or the authority of your representative) and confirm that the personal information subject to the request relates to you.
Disclosures we provide in response to a verified consumer request will cover only the 12-month
period before we received the request If we deny part or all of a verified consumer request, we will provide a
reasonable explanation for the denial.
We do not charge fees for responding to verifiable consumer request unless they are excessive, repetitive or manifestly unfounded. If we determine that a fee is appropriate, we will provide you with an explanation and a cost estimate before we complete your request.
We will keep records of consumer requests and our responses as required under the CCPA.
We will not discriminate against you for exercising any of your rights under the CCPA. This means that, except where permitted under the CCPA, if you make a request for disclosure or to delete your personal information, we will not (i) deny you goods or services, (ii) charge you different prices for goods or services (e.g., through penalties or withholding of otherwise available discounts), (iii) giving you a different level of goods or services, or (iv) suggesting to you we will take any of the actions in (i) through (iii).
How to Contact Us to Exercise Your California Rights
This Supplement was last updated on June 16, 2020.