Privacy Policy

BY USING ANY OF OUR ONLINE SERVICES, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY.

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE ANY OF OUR ONLINE SERVICES OR SUBMIT PERSONAL INFORMATION TO US IN ANY MANNER.

Last Updated: April 2, 2024

Learn2Speak.Live and its subsidiaries and affiliates, and their respective directors, officers, owners, employees, contractors, agents, successors, and assigns (collectively, “we,” “us,” “our,” or the “Platform”) have developed this Privacy Policy (this “Privacy Policy”) to (1) describe the types of personal information that we may collect about current, prospective, or past users or students (collectively, “Users,” “you,” or “your”), such as when using any website, mobile app, social media account or other digital property or service controlled by the Platform that links to this Privacy Policy (such digital properties and services are referred to, collectively, as the “Online Services”) and (2) explain how the Platform handles such personal information. Your use of our Online Services is subject to this Privacy Policy and your compliance with all applicable laws. Your use of our Online Services is further subject to our Terms and Conditions. This Privacy Policy does not apply to digital properties that do not link to this Privacy Policy or to third-party websites to which the Online Services may link.

If you are a resident of California, Connecticut, or Virginia, please see below for additional state-specific privacy disclosures.

Collection of Personal Information

The Platform may collect personal information directly from you, such as first and last name, home or physical address, telephone number, email address, age, and other demographic information, account login credentials and other Internet or electronic network activity information, as well as financial information, including credit or debit card numbers, and commercial information such as products or services you purchased, considered, or used. For quality purposes, as well as to support internal training and improve service, the Platform may also record individual sessions and group classes, and as a result the Platform may collect video and audio recordings of you.

The Platform may collect this personal information when you:

• Register for, or otherwise interact with, our Online Services (for example, when you search our Online Services or create or update an online account);
• Participate in sweepstakes or contests or other such interactive activities via our Online Services;
• Submit content to be posted on our Online Services;
• Purchase other products or services from the Platform via our Online Services;
• Respond to questions, prompts, or suggestions we make on our Online Services;
• Contact or communicate with our team, either via our Contact Page or by email;
• Participate in an assessment or similar service;
• Register for or reserve a spot in a class or activity; or
• Complete online forms or surveys.

In addition, the Platform may collect personal information about you, such as first and last name, telephone number, email address, and other demographic information, indirectly from other users via referrals. 

The Platform may also collect such personal information indirectly from our business partners, for example, when you use our Online Services in connection with obtaining discounted access to services offered by the Platform or in connection with a third-party program offering rewards, reimbursements, benefits, or other incentives based on your use of the Platform’s services (such third-party program, including a right to access to our Online Services that is available through a school, an employer, or other group, a “Third-Party Offer”), but solely for the business purpose of facilitating the provision of such access or discounts, rewards, reimbursements, benefits, or other incentives to you under Third-Party Offer (see also Disclosure of Personal Information to Third-Party Recipients below.)

Furthermore, we may receive information about you from our advertising/marketing and analytics or other business partners. We and our advertising/marketing and analytics or other business partners may also automatically collect personal information from or about you or your device when you interact with our products and services. The information collected about you may include your operating system (for example, iOS, Android, Windows), your browser type (for example, Internet Explorer, Chrome, Firefox, Safari), geolocation data, internet protocol (IP) addresses, first- or third-party cookie IDs, other proprietary digital identifiers, bounce rates, page views, email open rates and links clicked therein, actions taken on pages, referring/exit pages, user agent string, and other device metadata. While other technologies may also be used (e.g., APIs), this information is often collected via pixel tags (essentially, JavaScript code that sends information to a first- or third-party server) and, relatedly, first- or third-party cookies (which are created by pixels). Cookies are small text files stored onto your device that may “remember” certain information about you.

Moreover, if you access our Online Services through a mobile device, we may collect geolocation data such as the physical location of your device by, for example, using satellite, cell phone tower, or Wi-Fi signals. We may use your device’s physical location to provide you with location-based services and content. You may be able to allow or deny access to your device’s location by changing your device’s location settings but, if you choose to deny such access, we may not be able to provide you with location-based services and content.

Use and Disclosures of Personal Information

In addition to any other uses set forth in this Privacy Policy, personal information may be used for purposes such as the following:

• To provide our products or services, including our Online Services, for example in connection with scheduling individual sessions or booking classes or delivering digital contents;
• To communicate with you about our products or services, including our Online Services (or to communicate with you about products or services of third parties), such as in connection with updating your account information, or informing you about new offerings from us or third parties;
• To better understand Users’ use of, and to improve, our products and services, including our Online Services (or the products or services of third parties), such as through internal research and generation/analysis of analytics data and usage trends;
• To target you or others with advertising and to measure the effectiveness of such advertising campaigns, such as:
  • To market the Platform’s products or services to you (or the products or services of third parties), including through marketing emails or text messages or other commercial messages or ads, and to alert you to special promotions, discounts, offers, and the like; and
  • To match your use or purchase of products and services with your online activity on our Online Services (for example, we may connect your location and native language with activity on our Online Services or share the personal information you provide when you sign up for classes with advertising/marketing and analytics partners to facilitate or track the effectiveness of advertising campaigns);
• To assist with customer service or otherwise respond to requests;
• To distribute surveys and collect feedback;
• To facilitate transactions;
• To coordinate sweepstakes and contests;
• To protect the safety, security and integrity of our Users and Online Services;
• To monitor and prevent fraud;
• To recognize you and your devices (for example, such as when you use our Online Services);
• To support internal training;
• To conduct audits; and
• To fulfill contractual obligations or otherwise take steps to effectuate or defend our rights.

Disclosure of Personal Information to Third-Party Recipients

In addition to the disclosures otherwise set forth in this Privacy Policy, your personal information is disclosed to affiliates and to service providers, contractors, and other third-party partners to provide various products and services (for example, hosting vendors, payment processors, advertising/marketing partners, analytics companies, security vendors, and CRM providers) and for the other purposes set forth in, or consistent with, this Privacy Policy. The Platform also reserves the right to disclose personal information to respond to authorized information requests from government authorities, to address national security situations, to effectuate or defend our rights, or when otherwise required by law, in the Platform’s sole discretion.

The Platform’s Privacy Policy shall also include the Privacy Policy from each of the online payment systems accessible through our Online Services. The Platform offers the following online payment systems:

• Paypal: we encourage you to review Paypal Privacy Policy here
• WooCommerce: we encourage you to review WooCommerce Privacy Policy here

Additionally, if the Platform sells one or more of its product lines, divisions, or assets (such as your subscription to our Online Services), personal information may be transferred to the buyer. Similarly, if the Platform purchases a product line or division or other assets (such as your subscription) from a third party, personal information may be transferred from the seller to us.

Finally, if you are accessing our Online Services via a Third-Party Offer, the Platform may share your personal information (including identifiers such as a unique personal identifier and commercial information such as your use of such services or the number of times you visit our website each month) with the applicable third party in accordance with the terms of such Third-Party Offer for the business purpose of facilitating the provision of such access or discounts, rewards, reimbursements, benefits, or other incentives to you under the Third-Party Offer. You may always request that we stop sharing such personal information. However, in that case, you may not be eligible to access our Online Services or obtain any such rewards, reimbursements, benefits, or other incentives.

Email Marketing

You may opt-out of marketing emails by following the “unsubscribe” or similarly worded link within each marketing email. Note that you cannot opt-out of transactional communications, unless otherwise required by law.

Additional Advertising Information

We use advertising and marketing partners and analytics partners (including advertising agencies) and our own in-house advertising/marketing and analytics operations. These services are used for purposes such as to better understand our Users, analyze email open rates and user journeys, analyze trends, measure traffic and usage on our products and services, administer or personalize our products and services, record users’ movements or actions on our Online Services (e.g., across our websites or apps), gather demographic information, link online activity with offline activity, target or retarget Users (or target similar persons, such as via “look-a-like” audiences) via advertisements on third-party properties or on our own properties, serve ads to you from other advertisers, measure the effectiveness of advertising campaigns (for example, to measure views of ads, viewability, clicks, registrations, interactions, purchases, or other “conversion” events), and facilitate ad targeting by third parties for others’ products or services. In some cases, third-party advertising technology services may send out “bid requests,” which may contain information about the user such as IP address or device ID or hashed email address, to its partners in order to find advertisers that are willing to “bid” on an ad placement (or may themselves bid on ad placements on third-party properties as well, including on our behalf).

To the extent we use Google, Facebook, or Instagram, for advertising purposes, please see these links provided by these respective companies to understand some of their related opt-out choices. More broadly, the online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative or the Digital Advertising Alliance (including for mobile apps at https://youradchoices.com/appchoices). Please note you must separately opt out in each browser and on each device; if you clear cache or cookies, be sure to reset your preferences as applicable (such as in the browser context). We are not responsible to the extent any such opt-outs are not honored by any advertising technology companies, as opt-out preferences provided by such companies are not under our control.

Some internet browsers allow you to limit or disable the use of tracking technologies. More detailed information about cookie management or other passive transmissions by specific web browsers can be found at the browser’s respective websites, documentation, or settings pages.

Security of Personal Information

We seek to use industry standard security measures designed to protect your personal information. However, no safeguards are 100% secure and you provide information to us at your own risk.

Links to Other Websites

The Online Services may contain links to digital properties operated by others. Each of those maintains its own policies about the collection, use, and security of personal information. The Platform is not responsible for how others use your personal information. Before providing personal information to any other digital property, you should read its privacy policy and terms of use and ensure they are acceptable to you. Notwithstanding any content on the Online Services indicative of the contrary, the Platform makes no endorsement of or representation about any such third-party properties, or any information, software, or other products or materials found there, or any results that may be obtained from using them.

If you decide to access any digital property linked to in our Online Services, you do so entirely at your own risk. The Platform does not guarantee that you will receive an alert when you leave the Online Services and it is your responsibility to determine when you have left the Online Services. The Platform recommends that you review any third-party digital property’s privacy policies before submitting any information. The Platform assumes no responsibility for, and shall not be liable for, the privacy, terms of use, or other policies of any third-party digital property, any damage to, or viruses that may infect your computer equipment or other property, or for any loss or corruption of data resulting from any third-party digital property navigated to or accessed from links hosted on or contained in the Online Services.

Personal Information Related to Children: A Note for Parents or Legal Guardians

The Platform does not intend to, or knowingly, collect any personal information of children under the age of thirteen (13), except in the limited cases where a parent or guardian purchases services for a minor under the age of thirteen (13) and, on behalf of such minor, provides certain identifiers such as the child’s name or allows the photographing of such minor to facilitate the minor’s use of such services. If the Platform becomes aware of a child under the age of thirteen (13) providing personal information directly, we will attempt to delete that information. If your child under the age of thirteen (13) has provided personal information to us, please contact us so it can be deleted.

State Privacy Disclosures

These state privacy disclosures apply solely to residents of California, Connecticut, and Virginia whose personal information is covered under the State Privacy Laws (collectively, “consumers,” “you,” or “your”) and supplements the information contained elsewhere in this Privacy Policy.

1. Your Rights

Under the California Consumer Privacy Act (as amended by the California Privacy Rights Act) (the “CCPA”), the Connecticut Data Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “State Privacy Laws”), you have several rights in relation to your personal information as it applies to our business, as summarized below:

2. Submitting Rights Requests

You may exercise your right to request access, deletion, and correction of your personal information (as such rights are described above) by emailing us at learn2speaklive@gmail.com 

For the rights to opt-out of “sales,” “shares,” and processing of personal information for “targeted advertising,” (as such rights are described above), please email us at learn2speaklive@gmail.com or otherwise activate the “Global Privacy Control” (GPC) on the browsers or browser extensions that support such signal (for pixel-based opt-outs on the browser level, in the case of GPC).

As permitted by applicable law, we may require verification of your, or your authorized agent’s, identity for security of your personal information (such as by requesting certain information that cross-references with information we have internally, or for authorized agents, ensuring that they are duly authorized by you, such as name, email address, zip code, and first five digits of your payment method).

3. Non-Discrimination and Appeals

You have the right not to receive discriminatory treatment for exercising the rights set forth in the table above. However, if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request) in certain contexts, we may no longer be able to provide you certain related products and services or engage with you in the same manner.

In the event that we decline to take action on a request exercising one of your rights set forth above, Connecticut and Virginia residents have the right to appeal our decision under their respective State Privacy Law.

4. Authorized Agents

You are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above, though we must verify the authorized agent’s authority to act on your behalf before acting on such request.

For requests to access, delete, and correct personal information, we require the following for verification purposes:

•  a power of attorney valid under the laws of the relevant state from you or your authorized agent; or
• sufficient evidence to show that you have:
  •  provided the authorized agent signed permission to act on your behalf; and
  •  verified your own identity directly with us.

5. Shine the Light/Financial Incentives (California)

• “Shine the Light” Law: If you have an established business relationship with us, you may have rights to know how your information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). To make such a request, please use our Contact Page.
• Notice of Financial Incentives: Under the CCPA, we may offer you “financial incentives” for the collection, sale, retention, and use of your personal information that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs or their terms by posting notice on the program descriptions and terms linked to above, so check them regularly.
  Each financial incentive or price or service difference related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty. We calculate the value of the offer and financial incentive by using the expense related to the offer.

6. Notice at Collection (California)

• List of categories of personal information collected:
  •  Identifiers, such as your name, e-mail address, date of birth, or other similar identifiers.
  •  California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birth date, contact information, and payment information.
  •  Protected Classification Characteristics, such as age and gender.
  •  Commercial Information, such as payment information and purchase history.
  •  Internet/Network Information, such as device information, logs, and analytics data.
  •  Geolocation Data, such as location information from your device or generated based on IP address or Wi-Fi.
  •  Profession/Employment Information, such as your employer if your subscription is tied to an account managed by your employer.
  •  Sensitive Personal Information, such as precise geolocation, account log-in and password. Sensitive Personal Information is used for the limited purposes specified under the CCPA that do not require a corresponding opt-out right, such as the provision of goods or services reasonably expected by the consumer requesting such goods or services. For example, the User’s age or similar information may be used to provide and register for services; precise geolocation may be used for suggesting local events, and native language may be used to suggest recommended digital contents.
• The purposes for which the categories of personal information are used (but see above for Sensitive Personal Information):
  •  To provide our products or services, including our Online Services, for example in connection with scheduling individual sessions or booking classes or delivering digital contents;
  •  To communicate with you about our products or services, including our Online Services (or to communicate with you about products or services of third parties), such as in connection with updating your account information, or informing you about new offerings from us or third parties;
  •  To better understand User’s use of, and improve, our products and services, including our Online Services (or the products or services of third parties), such as through internal research and generation/analysis of analytics data and usage trends;
  • To target you or others with advertising and to measure the effectiveness of such advertising campaigns, such as:
    1. To market the Platform’s products or services to you (or the products or services of third parties) including through marketing emails or text messages, where applicable, and to alert you to special promotions, discounts, offers, and the like;
    2. To match your use or purchase of products and services with your online activity on our Online Services (for example, we may connect your native language with activity on our Online Services or share the personal information you provide when you register with advertising/marketing and analytics partners to facilitate or track the effectiveness of advertising campaigns);
  •  To assist with customer service or otherwise respond to requests;
  •  To distribute surveys and collect feedback;
  •  To facilitate transactions;
  •  To coordinate sweepstakes and contests;
  •  To protect the safety, security, and integrity of our Users and Online Services;
  •  To monitor and prevent fraud;
  •  To recognize you and your devices (for example, such as when you use our Online Services);
  •  To support internal training;
  •  To conduct audits; and
  •  To fulfill contractual obligations or otherwise take steps to effectuate or defend our rights.
•  The following categories of personal information are “sold” or “shared” (as such terms are broadly defined under the CCPA) to our advertising/marketing and analytics partners for the purposes of advertising/ marketing and analytics services: Identifiers, Commercial Information, Geolocation Data, and Internet/Network Information. You may opt-out of these “sales” and “shares” by emailing us at learn2speaklive@gmail.com .
•  Data Retention: We retain the categories of personal information above as reasonably necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. In many situations, we must obtain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.
•  Please see the rest of our privacy policy, such as the section on Collection of Personal Information and Disclosure of Personal Information to Third-Party Recipients for more information regarding the sources of collection of personal information and the categories of third-party recipients to whom we disclose such personal information, respectively

Acceptance of Privacy Terms and Conditions

Your access to and use of the Platform’s Online Services is subject to this Privacy Policy and all applicable laws. Your use of our Online Services is further subject to our Terms and Conditions. By accessing, using or browsing our Online Services, you accept, without limitation or qualification, this Privacy Policy. The Platform reserves the right to at any time revise this Privacy Policy without prior notice. If the Platform changes its privacy practices, an updated Privacy Policy will be posted to reflect those changes and the effective date of the revised Privacy Policy (i.e., the “Last Updated” date above) will be set forth therein. You are bound by any such revisions and should therefore periodically visit this Privacy Policy. If you have questions about our privacy practices, or if you would like to request to opt out of future communications from a Platform business or a particular program, please contact us via our Contact Page.