Privacy Policy

1. Introduction
2. Information We Collect
3. Purposes for Processing Your Data
4. Children’s Privacy
5. How We Disclose the Information We Collect
6. Retention of Your Data
7. Security of Your Data
8. Your Choices and Rights
9. Additional Information For Residents Of California, Colorado and Nevada
10. Contact Us

 

1. Introduction

Lingokids is an interactive learning app and universe that surrounds your child with a modern curriculum to help them thrive in today’s changing world. At Monkimun Inc. and Monkimun Labs S.L. (collectively as data controllers “Lingokids,” “we,” “us,” or “our”), we are firmly committed to your privacy as well as the privacy of your child. We want you, as a parent and/or legal guardian (collectively “Parent(s)”) to feel safe and have full confidence in our handling of your data, whether you use our mobile application (“App”), our websites, which include our main website at https​://lingokids.com, our merchandising store at store.lingokids.com and microsites and landing pages (“Sites”) or other services or otherwise interact with us (collectively referred to here as our “Services.”). We’ve prepared this Privacy Policy to explain how and why we treat the personal information we collect, and how you can exercise your rights. We encourage you to read the Privacy Policy carefully, and if you have any questions, please contact us as set forth in “Contact Us” below. We may modify this Privacy Policy in accordance with applicable law at any given time. We try to always keep the Privacy Policy up to date. If we make a material change to the Privacy Policy, we’ll provide you with appropriate notice in accordance with legal requirements, such as by email. Also, we will solicit and obtain verifiable parental consent if our privacy practices change in a way that such consent becomes needed. WHAT YOU NEED TO KNOW

• Parents are in control. Parents download our App and set up an account for their children as part of our initial setup process. We make it easy to see what your child is doing when they use our App.
• The App is a closed ecosystem. Our Services are not designed to allow children to access the wider internet or share any personal information with anyone other than their parent.
• No ads. We do not display any advertising within our Services.
• Our promotional and store Sites are designed for adults, and we use standard web tracking technology on these Sites to support our advertising and analytics efforts. We may partner with third parties, who use industry-standard technologies such as cookies to track visitors to our adult-oriented Sites. These third parties use this data to encourage adults to purchase our products and Services, including on other websites. As an adult, you can control this tracking by managing your cookie settings (for instance by using the cookie banner that appears on our promotional website) or otherwise by contacting us, as described in more detail below. We do not use data collected from children as part of our marketing efforts.
• We strive to collect only the information we need to make our Services work. The App does not collect any biometric identifying information such as facial geometry or voice prints. While we may invite you to take part in more in-depth research sessions (with your consent), the App will not ask for your physical location or other sensitive information, such as race, sexual orientation, or health information.

2. Information We Collect 

At Lingokids, we generally collect and obtain information, including personal information, in three ways: directly from our users, automatically through your use of our Services, and from third parties in some situations. More details for each category can be found below.

A. Information You Provide to Us Directly:

Account Creation. We may collect the following personal information when you sign up for our Services (either the free version or our Plus version paid plans) or create an account on our website:

• Contact information
  • Adult’s e-mail address.

Player information

• • Child’s first name or nickname (optional)
  • Child’s age (optional)
  • Child’s interests (optional)

• Payment information

We do not directly collect or store any payment card information entered through our Services, and instead rely on third-party payment processors (such as Apple or Google) to handle these payments. However, if you make a purchase on our website or subscribe to our paid plans (Plus version) of the App, we may receive certain information about your purchase, such as:

• • Payment method (e.g. whether you used a Credit Card/PayPal),
  • Full name of bank card or PayPal cardholder;
  • Shipping and/or Billing address;
  • Record of payment information for future purchases, with your consent.

Interactive Features  When you use our Services, we and others who use our Services may also collect personal information that you share directly through our interactive features (e.g., comments you may post on our social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced in this Privacy Policy. Please exercise caution before revealing any information that may identify you in the real world to other users. The interactive features are not present within the child-directed properties of our Services. Optional microphone, camera and speech recognition permissions  On the App, parents can optionally allow microphone, camera and speech recognition permissions. These permissions are not mandatory, and the App can be used even if you do not agree to grant them, although certain features may be limited. No images, videos or speech data is shared with Lingokids or any third parties. This data is transmitted off the device or collected by Lingokids, and Lingokids does not store and cannot access audio or visual recordings that are saved locally on the user’s device. The App includes certain interactive games for which spoken responses are required to advance and complete activities. If microphone or speech recognition access is not enabled, these specific features may not function, but the rest of the App remains available. Although our speech recognition technology records and recognizes the user’s answers in order to correctly develop the activity or game and its functionalities, the technology does not collect any information that would identify individual speakers, such as a voice print. Moreover, the recording is only stored on your devices. This information does not travel and is not stored on our systems or servers, nor can it be accessed, played or broadcast by us. You can check and manage permission settings at any time in your device settings. You may refuse or withdraw these optional permissions, but please note that certain features or functions of the App may not work properly if access to the microphone, camera or speech recognition is disabled. Feedback Data We may collect additional personal information when Parents or other adults voluntarily complete a customer survey, participate in our customer forums and panels, or provide feedback on any of our Services. Product and Content Research and Development Activities On occasion, we may contact you to ask you to participate in optional interviews, surveys, or qualitative research sessions. These surveys will be conducted with your express consent only, and the categories of personal information we collect and the purposes for which they are gathered will be disclosed to you in advance of each session. We will never contact your child directly without your consent. Your Communications with Us When you contact us, such as to request customer support or to partner with us, we may collect your name and surname, email address, and any other information you provide us during our communication. Sweepstakes or Contests We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information (such as names and addresses) of sweepstakes and contest winners. This section does not apply to children. Conferences, Trade Shows, and Other Events We may collect personal information from individuals when we attend or host conferences, trade shows, and other events. Business Development and Strategic Partnerships We may collect personal information from individuals and third parties to assess and pursue potential business opportunities. 

B. Information Collected Automatically

We collect certain information automatically when you use our Services. This information may vary, but primarily includes the following: App and Sites activity and usage data

• Types of content viewed, downloaded, or interacted with
• Functions used and actions performed
• Information on when a user takes a screenshot within the app (note that we cannot see the contents of the screenshot)
• Frequency of use and duration of the activities and games
• Progress and achievements: activities completed, curriculum progress, grades, and progress reports (Plus version)
• Age of the account (account tenure)
• Activation of notifications, including push notifications (collected only from users who have completed the onboarding process)
• Session duration
• Total time spent actively using the App
• Device and other mobile identifiers, including cookies
• Device language
• IP address
• General device location data (derived from IP address)
• Internet service provider
• User settings

Crash Reports. If you provide crash reports, we may collect personal information related to such crash reports, including detailed diagnostic information about your device and the activities that led to the crash. Cookies and Other Tracking Technologies We and our service providers also collect data through cookies, pixel tags, web beacons, and other technologies (“Technologies”). These technologies collect information about your use of our Services. For information about our automatic information collection practices, please see our Cookie Policy (https​://lingokids.com/cookie-notice).

C. Data We Collect from Third Parties and Other Sources

We also obtain and receive information about you from our vendors and other third parties with whom we have relationships, both from your use of our App and from other interactions you have with us on other platforms.  Third-Party Services and Sources. We may obtain personal information about you from third-party services and organizations. For example, if you access our services through a third-party login service such as your Apple ID, we may collect personal information about you from that third-party application or service that you have made available via your privacy settings. Third-Party Analytics. We use web analytics tools and services provided by our vendors and partners to support our marketing and user acquisition efforts for adults. These tools allow us to know and track audiences of adult users and potential users by looking at their interactions and visits to our Sites, the App, publications, and content on our profiles on social networks and platforms (Facebook, Instagram, TikTok, Twitter, Pinterest, Spotify). We may also receive information from third parties regarding the ads adults view and click on YouTube or the Internet.  Third-party Survey Platforms. Also, when we contact you to conduct research sessions or when you participate in interviews or surveys as a Parent, your contact information (email) may be provided to us by third party platforms or agencies from user dashboards generated from databases in which you voluntarily enrolled.

3. Purposes for Processing Your Data 

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

1. Managing your information and accounts;
2. Providing access to certain areas, functionalities, and features of our Services;
3. Evaluating the child’s use of the app, as well as the child’s participation, to provide you with regular reports on your child’s progress
4. Answering requests for customer or technical support;
5. Communicating with you about your account, activities on our Services, and policy changes;
6. Processing your financial information and other payment methods for products or Services purchased and refunds;
7. Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
8. Debugging to identify and repair errors with our Services;

Additional information for EU residents: The legal basis for the above processing activities is the performance of a contract between you and Monkimun.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

1. Pursuing our legitimate interests such as direct marketing of similar products and services, requesting customer feedback, network and information security, and fraud prevention;
2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
3. Measuring interest and engagement in our Services;
4. Short-term, transient use, such as contextual customization ads;
5. Improving, upgrading, or enhancing our Services;
6. Developing new products and services;
7. Ensuring internal quality control and safety;

Additional information for EU residents: The legal basis for the above processing activities is the legitimate interest of our Company, taking into account your fundamental rights and freedoms with respect to your personal data.

C. Legal Obligations

We use your information to comply with applicable legal obligations, such as:

1. Auditing relating to interactions, transactions, and other compliance activities;
2. Enforcing our agreements and policies; and
3. Carrying out activities that are required to comply with our legal obligations.

Additional information for EU residents: The legal basis for the above processing activities is Article 6(1)(c) GDPR as it is necessary for compliance with a legal obligation to which our Company is subject.

D. Marketing and Advertising our Products and Services

We do not market or advertise to children in the Services or otherwise use information collected from children or within child-directed properties of our Services of advertising. In some cases, we may partner with third-party ad networks, publishers, and other advertising companies (“Ad Vendors”) to display our ads on other sites and apps. These ads are displayed on sites and apps based on their type or content or are displayed to certain adult audience segments (e.g. adults in a certain, estimated location or adults that use a certain operating system like iPadOs). We may use certain personal information (e.g. IP address) collected on such third-party sites or apps and later recorded within our systems when an adult user takes certain actions within our app (e.g. installs the app or starts a free trial) to measure the effectiveness of our marketing campaigns. We may also use certain personal information of adults to help determine who should see our ads. We do not use any personal information from the child-directed properties of our Services for such ads.

If you are a Parent, we may use your personal information, including your email, to send you promotional content for our Services via email messages (newsletter and offers) and if you use our App, we may also send you promotional content via push notifications, and in-app messages. The frequency of these messages and the decision to send them may depend on certain actions you as an adult take in relation to our Service (e.g. starting a trial), as well as on certain in-app or other activities, such as when you last opened the newsletter or the app. You may decide not to receive and opt out of these communications at any time and without any charge.

Finally, we use cookies or similar technologies on our Sites for technical purposes and for other purposes as specified in our Cookie Policy (https​://lingokids.com/cookie-notice). We do this with your consent where required by applicable law. We do not use cookies or similar technologies in the App for advertising purposes, however. We never disclose your personal information to third parties for their own advertising. Additional information for EU residents: The legal basis for the above processing activities, if ever conducted, would be your consent.

E. With Your Consent

In addition to our marketing activities described above, we may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, or with your separate consent.

F. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

• De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information (for example, aggregate reports detailing the total number of users we have in a given jurisdiction).

4. Children’s Privacy

We know that children deserve special, enhanced privacy protections. That’s why we develop our App and Services to ensure that parents, caregivers, and guardians are in control. We require an adult to register their child and provide the child’s information to establish an account; in particular, we collect the child’s first name (optional) so that you can easily distinguish between different profiles and the child’s age (optional) so that we can customize App content for the child. Once the parent has created the child’s account, then we strive to collect only as much information about a child player as is reasonably necessary for the child to participate in the educational activities in our Services. We do not condition a child’s use of our Services on their disclosure of more information than is reasonably necessary. How We Use Your Child’s Information. We use the information we collect to improve our App and to deliver a better and more personalized experience. For example, we may use your child’s information to:

• Estimate our customer size and usage patterns.
• Store information about the child’s preferences regarding the activities played in our App and context (such as language), allowing us to customize the content according to individual interests.
• Generate regular reports on your child’s progress, using artificial intelligence, so that you can be part of your child’s learning journey, see your child’s strengths and areas for improvement and explore other resources inside and outside the app to support your child’s learning progress. You can object to this processing of your child’s data at any time through the channels provided.
• Speed up your searches.

Our Practices for Disclosing Children’s Information. We do not share, sell, rent, or transfer children’s personal information other than as described in this section:

• If a Parent opts to share content from the app (e.g., achievements) we will provide the content via shareable links with secure tokens.
• We may disclose aggregated information about many of our users, and information that does not identify any individual.

In addition, we may disclose children’s Personal Information:

• To vendors we use to support the internal operations of our App, or data processors, and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
• If we are required to do so by law or legal processes, such as to comply with any valid court order or subpoena or to respond to any valid request from a governmental, regulatory, or law enforcement entity.

  Accessing and Correcting Your Child’s Personal Information. At any time, you may review the child’s Personal Information maintained by us, require us to correct or delete the Personal Information, and/or refuse to permit us from further collecting or using the child’s Personal Information. You can review, change, or delete your child’s personal information by sending us a request here: https​://help.lingokids.com/hc/en-us/requests/new or emailing us at dpo​@lingokids.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections. If we learn that we mistakenly collected any personal information from a child (as defined based on the minimum age for data collection in their jurisdiction), we will delete it immediately, unless we have a legal obligation to retain it, and then disable the child’s account. Lingokids is audited and certified by the kidSAFE Seal Program (https​://www.kidsafeseal.com/aboutourprogram.html), and complies with its standards and requirements for online security and privacy. You can see Lingokids’ certification by visiting its page (https​://www.kidsafeseal.com/certifiedproducts/lingokidsenglish_app.html).

5. How we Disclose the Information We Collect

If you are a Parent, we may disclose your information to third parties as set out below. For information on how we disclose children’s information, see Section 4 above.

A. Vendors

We may use a variety of vendors to help provide the services.  This includes companies providing IT services, business tools or IT infrastructure such as hosting providers, CRMs, emailing service companies, and payment processing, customer service, services that process and administer consumer surveys and related services. Such companies are data processors of Lingokids and we have proper data processing agreements in place with them. We take appropriate contractual, legal, technical, and organizational measures designed to ensure that your personal information is treated securely.

B. Business Partners

If you are a Parent, we may disclose your personal information with our business partners when necessary to provide a product or service you have requested. We may also disclose your personal information with partners with whom we jointly offer products or services, based on appropriate legal grounds (where applicable). Finally, if you request a refund through a third party, like Apple, we may disclose to Apple the necessary information to help analyze and process that request. We do not disclose information collected from children to business partners.

C. Advertising Partners

If you are a Parent, we may also disclose your personal information to third-party advertising partners, under appropriate legal bases (where applicable), to advertise the Services on third-party sites or apps and to assist in measuring the effectiveness of our marketing campaign. In addition to information collected within our App we may share directly, third-party advertising partners may set Technologies and other tracking tools on our Sites to collect information regarding your activities on our Sites and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). As an adult, you can control this tracking by managing your cookie settings (for instance by using the cookie banner that appears on our Sites) or otherwise by contacting us, as described in more detail below. These advertising partners may use this information to show our advertisements to you on other websites and applications and help us measure the effectiveness of our marketing campaigns.    Note that we do not disclose information collected from children or within child-directed properties of our Services to our advertising partners. 

D. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity, as permitted by Law.

E. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in an actual or proposed merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred in connection with such a transaction, as permitted by law and/or contract, to the extent permitted by law.

6. Retention of Your Data

We will retain your information for as long as needed to provide you with our Services, and after that, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, and during the statute of limitations for legal actions.

7. Security of Your Data

We have implemented appropriate security measures designed to ensure the security of your personal information and prevent its alteration, loss, and treatment and/or unauthorized access. While we have implemented measures designed to secure your data, no website or Internet transmission is completely secure and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information. By using our Services or providing personal information to us and to the extent permitted by law, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

8. Your Choices and Rights

• Account Information: You may update, correct, or modify information about you at any time by logging into your account or emailing us at dpo​@lingokids.com.
• Email communications: You can opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at dpo​@lingokids.com. If you choose to opt-out, we will still send you non-promotional communications, such as those about your account.
• “Do Not Track” / “Global Privacy Control”: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Additionally, some browsers or plug-ins use a “Global Privacy Control” (“GPC”), which you can learn more about at https​://globalprivacycontrol.org/. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, to the extent that we engage in any disclosures covered by the GPC, we will abide by the GPC’s opt-out preference signals. Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them.

The laws of your jurisdiction may provide you with certain rights regarding personal data. Depending on the laws where you live, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information;
• Request Correction of your personal information where it is inaccurate, incomplete, or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion, Anonymization or Blocking of your personal information;
• Request Restriction of or Object to our processing of your personal information if processing is non-compliant;
• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.
• Request data portability and receive an electronic copy of the personal information that you have provided to us;
• Be informed about third parties with which your personal information has been shared; and
• Request the review of, or opt-out of, certain decisions taken exclusively based on automated processing.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information to comply with a legal obligation. You may exercise your rights by contacting us as set forth below, or using the following form: https​://help.lingokids.com/hc/es/requests/new. We may take reasonable steps to verify your identity prior to responding to your request.  You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law. The law of your jurisdiction may provide you with the right to appeal a denial of your request. Supervisory Authority. If your personal information is subject to the applicable data protection laws of Australia, Brazil, the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law:

• Office of the Australian Information Commissioner (https​://www.oaic.gov.au/)
• Autoridade Nacional de Proteção de Dados (ANPD)- (gov.br/anpd/pt-br).
• EEA Data Protection Authorities (DPAs) (edpb.europa.eu/about-edpb/board/members_en).
• Swiss Federal Data Protection and Information Commissioner (FDPIC) (edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html).
• UK Information Commissioner’s Office (ICO) (ico.org.uk/global/contact-us/).
• Spanish Data Protection Agency (AEPD) (sedeagpd.gob.es/sede-electronica-web/vistas/infoSede/tramitesCiudadano.jsf;jsessionid=Fgz0Cspuoge-HthivBLLXLNcfKVuU6iY9Vrn_ajq.agpdsedred01n).

9. Additional Information for Residents of California

This section applies only to personal information about California residents, as that term is defined in the California Consumer Privacy Act (“CCPA”), and it supplements the information in the rest of our Privacy Notice.

A. Personal Information We Collect And Disclose

The information we have collected within the last twelve (12) months about you, as well as the categories of third parties with whom we have disclosed this information, are described in the table below.

Category of Personal Information Collected by Monkimun	Processing Purposes	Category of Third Parties Personal Information is Disclosed to for a Business Purpose
Identifiers.  Parents: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, other similar identifiers. Child Users: First name, unique personal identifier, online identifier, Internet Protocol address, other similar identifiers.	Parents: Providing the Services (as further described in Section 3.A.) Direct marketing to adults (via email, push notifications, and in-app messaging) Internal administrative purposes such as; requesting customer feedback; network and information security, fraud prevention; detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; measuring interest and engagement in our Services; short-term, transient use, such as contextual customization ads; improving, upgrading, or enhancing our Services; developing new products and services; ensuring internal quality control and safety. Complying with applicable legal requirements. Measuring the effectiveness of our marketing campaigns to Parents and other adults. Child Users: Estimate our customer size and usage patterns. Store information about the child’s preferences, allowing us to customize the content according to individual interests. Generate regular reports on your child’s progress, using artificial intelligence, so that you can be part of your child’s learning journey, see your child’s strengths and areas for improvement and explore other resources inside and outside the app to support your child’s learning progress. Speed up your searches.	Parents: Advertising partners (IP address, unique personal identifier and device identifier, email address) Data analytics providers (IP address, unique personal identifier and device identifier, email address) Child Users: Service providers Data analytics providers
Parents: A name, address, financial information. Child Users: Name	Parents:  Providing the Services (as further described in Section 3.A.) Internal administrative purposes such as direct marketing to adults (via email, push notifications, and in-app messaging); requesting customer feedback; network and information security, fraud prevention; detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; measuring interest and engagement in our Services; short-term, transient use, such as contextual customization ads; improving, upgrading, or enhancing our Services; developing new products and services; ensuring internal quality control and safety. Complying with applicable legal requirements. Measuring the effectiveness of our marketing campaigns to Parents and other adults. Child Users: Estimate our customer size and usage patterns. Store information about the child’s preferences, allowing us to customize the content according to individual interests. Generate regular reports on your child’s progress, using artificial intelligence, so that you can be part of your child’s learning journey, see your child’s strengths and areas for improvement and explore other resources inside and outside the app to support your child’s learning progress. Speed up your searches.	Parents: Service providers Child Users: Service providers
Protected classification characteristics under California or federal law Parents: Age If participating in optional surveys: national origin, citizenship, medical condition, physical or mental disability, sex (including gender) Child Users: Age	Parents: Internal administrative purposes such improving, upgrading, or enhancing our Services and developing new products and services. Complying with applicable legal requirements. Child Users: Estimate our customer size and usage patterns. Store information about the child’s preferences, allowing us to customize the content according to individual interests. Generate regular reports on your child’s progress, using artificial intelligence, so that you can be part of your child’s learning journey, see your child’s strengths and areas for improvement and explore other resources inside and outside the app to support your child’s learning progress. Speed up your searches.	Parents: Service providers Data analytics providers Child Users: Service Providers
Commercial information Parents: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Child Users: N/A	Parents: Providing the Services (as further described in Section 3.A.) Internal administrative purposes such as direct marketing to adults (via email, push notifications, and in-app messaging); requesting customer feedback; network and information security, fraud prevention; detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; measuring interest and engagement in our Services; short-term, transient use, such as contextual customization ads; improving, upgrading, or enhancing our Services; developing new products and services; ensuring internal quality control and safety. Complying with applicable legal requirements. Measuring the effectiveness of our marketing campaigns to Parents and other adults Child Users: N/A	Parents: Service providers Advertising partners Data analytics providers Child Users: N/A
Internet or other electronic network activity Parents: Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement. Child Users: Information on a consumer’s interaction with an application.	Parents: Providing the Services (as further described in Section 3.A.) Internal administrative purposes such as direct marketing to adults (via email, push notifications, and in-app messaging); requesting customer feedback; network and information security, fraud prevention; detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; measuring interest and engagement in our Services; short-term, transient use, such as contextual customization ads; improving, upgrading, or enhancing our Services; developing new products and services; ensuring internal quality control and safety. Complying with applicable legal requirements. Measuring the effectiveness of our marketing campaigns to Parents and other adults. Child Users: Estimate our customer size and usage patterns. Store information about the child’s preferences, allowing us to customize the content according to individual interests. Generate regular reports on your child’s progress, using artificial intelligence, so that you can be part of your child’s learning journey, see your child’s strengths and areas for improvement and explore other resources inside and outside the app to support your child’s learning progress. Speed up your searches.	Parents: Service providers Advertising partners (consumer interaction with an application) Data analytics providers Child Users: Service providers Data analytics providers
Sensory data Parents: N/A Child Users: Audio, electronic, visual, or similar information (on device only).	Parents: N/A Child Users: Provide the Services	Parents: N/A Child Users: N/A
Inferences drawn from other personal information to create a profile about a consumer Parents: N/A Child Users: Profile reflecting a consumer’s preferences.	Parents: N/A Child Users: Store information about the child’s preferences, allowing us to customize the content according to individual interests. Generate regular reports on your child’s progress, using artificial intelligence, so that you can be part of your child’s learning journey, see your child’s strengths and areas for improvement and explore other resources inside and outside the app to support your child’s learning progress.	Parents: N/A Child Users: Service providers
Sensitive Personal Information Parents: Account log-in and password, financial data, or other credentials allowing access to your account. Child Users: N/A	Parents: Providing the Services (as further described in Section 3.A.) Internal administrative purposes such as network and information security, fraud prevention; detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; improving, upgrading, or enhancing our Services; developing new products and services; ensuring internal quality control and safety. Complying with applicable legal requirements. Child Users: N/A	Parents: Service providers Child Users: N/A

B. SALES/SHARING OF PERSONAL INFORMATION

Lingokids does not “sell” personal information as the term “sell” is commonly understood. That said, we may disclose information collected from Parents to third-party advertising partners for the purpose of promoting our Services, specifically to determine who should see our ads and measure the effectiveness of our marketing campaigns,as described above. This information includes identifiers (like IP addresses and email addresses), internet or other electronic network activity information (like information regarding an individual’s browsing interactions on our Services), and commercial information (like the fact that a browser visited a page directed to people who are considering using our Services). You may limit such disclosures by following the instructions found above in the section titled “Your Choices and Rights,” or by contacting us as set forth in “Contact Us” below. The CCPA also requires businesses that “share“ personal information to provide an opt out from such sharing. Under the CCPA,” sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites. We “share” information collected from Parents for these purposes to provide more relevant and tailored advertising to you regarding the Services. As part of this advertising, we may “share“ identifiers (like IP addresses and email addresses), internet or other electronic network activity information (like information regarding an individual’s browsing interactions on our website), and commercial information (like the fact that a browser visited a page directed to people who are considering purchasing the Services) with advertising platforms and advertising networks. You may limit such disclosures by following the instructions found above in the section titled “Your Choices and Rights,” or by contacting us as set forth in “Contact Us” below. We do not have actual knowledge of any “sale” or “share” of personal information of minors under 16 years of age.

C. SENSITIVE INFORMATION

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA

D. YOUR RIGHTS AND CHOICES

If you are a resident of California you may have the following rights:

• To Know and Access: to obtain a copy of the specific pieces of Personal Information we have collected about you. (Note that this right only applies to Personal Information relating to you, and not to any other user.)
• Deletion: to request that we delete your Personal Information. This right may be limited to the extent that we are permitted or required by applicable law to retain certain information. (Note that if you request deletion of your Personal Information, you may no longer be able to use or access the Services. If you decide to use or access the Services again, we may consider this a new account, and may collect Personal Information associated with that account in accordance with this Privacy Policy.)
• Correction: to request the correction of inaccurate Personal Information that we may have on file about you.

We will not discriminate against you, in terms of price or services that we offer, if you exercise any of the rights listed above. Verification and Appeal Process: We are required by law to take reasonable steps to verify your identity prior to responding to your request. Please note that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). If we are unable to process your request via you authenticating yourself on the Services, we may verify your request by asking for information sufficient to confirm your identity, such as your name, email address, and phone number. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and as permitted by applicable law. Where required by applicable law, we will notify you if we reject your request, and notify you of the reasons we are unable to honor your request. The process for that appeal will be sent to you separately if your request is denied. Authorized Agent: You may designate an authorized agent to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a user to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the user, you must be able to demonstrate that you have the requisite authorization to act on behalf of the user. If you are an authorized agent trying to exercise rights on behalf of one of our users, then you can make a request on the user’s behalf by contacting us as set forth below in the “Contact Us” section: Such requests must include the following information: (1) a written authorization from the consumer that includes the consumer’s full name, address, telephone number and valid email address used by the consumer to interact with us, that is signed by the consumer and clearly bestows upon the agent the proper authority; and (2) a certificate of good standing with your state of organization.  Alternatively, an acting agent can provide a valid power of attorney signed by the consumer on the agent’s behalf and a valid email address used by the consumer to interact with us.  The email address of the consumer will be used to separately verify the agent’s authority with the consumer. Refer-a-Friend, Promotions, and Similar Incentive Programs: We may offer referral programs, promotions such as sweepstakes, or other incentivized information collection programs. We may offer incentives to you such as discounts or promotional items or credit in connection with these programs, wherein you provide Personal Information regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) Alternatively, we may ask you to provide your Personal Information in exchange for a reward or participation in a promotion. These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your information to us depends on how you ultimately use our Services, whereas the value of the referred party’s information to us depends on whether the referred party ultimately uses our Services. Said value will be reflected in the incentive offered in connection with each program. You may withdraw from the incentives at any time. In order to withdraw from the financial incentive, please contact us as described below. De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law. Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in Contact Us below or logging into their account and removing the content or information using our self-service tools.

E. DATA RETENTION

Please see the “Retention of your Data” section above.

F. SUPPLEMENTAL NOTICE FOR COLORADO RESIDENTS

For disclosures required by the Colorado Privacy Act (CPA) regarding the categories of personal information, processing purposes, and information regarding personal information that we sell, please see the “Personal Information We Collect And Disclose” and “Sales/Sharing of Personal Information” sections above.

G. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at dpo​@lingokids.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.  Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below. “Shine the Light” Disclosure The California “Shine the Light” law gives residents of California the right under certain circumstances to request information about whether we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes.  We do not engage in such practices.

10. Contact Us

If you have questions or concerns regarding this Privacy Policy, you should contact us by email at dpo​@lingokids.com or using our webform at https​://help.Lingokids.com/hc/es/requests/new. Mailing address: Monkimun Inc. 2810 N Church St., PMB 42597, Wilmington, DE 19802-4447, USA Telephone: +34 914 51 13 43 Monkimun Labs S.L. C/San Bernardo 17, 5ª, Dcha.  28015 Madrid (Spain) Teléfono: +34 914 51 13 43 CIF B-8737934