PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy explains how Contextual Technologies Ltd, trading as Caruso Languages ("Caruso," "we," "us," or "our"), collects, uses, shares, and protects your personal information when you use our language learning application and related services (the "Services").

We are committed to protecting your privacy and being transparent about our data practices. This policy complies with the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

2. INFORMATION WE COLLECT

2.1 Personal Data You Provide to Us

When you interact with our Services, we collect information that, alone or in combination with other information, could be used to identify you ("Personal Data").

Account Information:

• Name and email address
• Username and profile picture (if provided)
• Learning preferences and goals
• Language proficiency level

Social Media Registration:

If you register through social media accounts (Facebook, Google Sign-in), we may receive information according to those platforms' privacy policies and your settings. This may include seeing which of your friends use our Services.

Payment Information:

When you purchase a subscription, payment information (including payment card details) is collected by our payment service providers (Apple App Store, Google Play Store). We do not store complete payment card information on our servers.

Learning Data:

• Test answers and learning scores
• Progress within courses and lessons
• Learning pathway selections and preferences
• Voice transcriptions from pronunciation exercises (we do not store actual voice recordings)

Communications:

• Information you provide in support requests
• Survey responses
• Any content you submit through "free text" boxes in our forms

Non-Personal Information:

• Time zone and language preferences
• Device settings and preferences

2.2 Automatically Collected Information

Log Data:

Information your browser or app automatically sends when you use our Services, including:

• IP address (to understand your country location)
• Browser type and settings
• Date and time of requests
• How you interact with our Services

Device Information:

• Device type and operating system
• Device settings and unique identifiers
• Network information
• App version and performance data

Usage Information:

• Types of content you view or engage with
• Features you use and actions you take
• Time, frequency, and duration of activities
• Learning patterns and progress metrics

3. HOW WE USE YOUR INFORMATION

We use your personal data for the following purposes:

3.1 Service Provision

• Providing and maintaining our language learning Services
• Creating and managing your account
• Delivering personalized learning experiences
• Processing payments and managing subscriptions
• Providing customer support

3.2 Service Improvement

• Analyzing usage patterns to improve our Services
• Developing new features and content
• Conducting research and analytics
• Testing and debugging our Services

3.3 Communication

• Sending service-related notifications
• Providing customer support responses
• Sending marketing communications (with your consent)
• Notifying you of updates to our Terms or Privacy Policy

3.4 Legal and Security

• Complying with legal obligations
• Protecting against fraud and abuse
• Enforcing our Terms of Service
• Protecting the security and integrity of our Services

3.5 Legal Basis for Processing

Under UK GDPR, we process your personal data based on:

• Contract performance: To provide our Services
• Legitimate interests: For service improvement and security
• Consent: For marketing communications and optional features
• Legal obligations: For compliance with applicable laws

4. HOW WE SHARE YOUR INFORMATION

4.1 We Do Not Sell Your Data

We do not sell, rent, or trade your personal information to third parties.

4.2 Service Providers

We may share your information with trusted third-party service providers who assist us in operating our Services:

AI and Technology Providers:

• Third-party AI services for language processing (data used functionally only, not stored by providers)
• Cloud hosting and infrastructure providers
• Analytics and performance monitoring services

Payment Processors:

• Apple App Store and Google Play Store for subscription management
• Payment security and fraud prevention services

Support Services:

• Customer support platform providers
• Email communication services

4.3 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes or government requests
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users
• Investigate potential violations of our Terms of Service

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, subject to the same privacy protections.

5. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication measures
• Employee training on data protection
• Secure data center facilities

However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

6. DATA RETENTION

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy:

6.1 Retention Periods

• Active accounts: Duration of account plus 3 years after last activity
• Deleted accounts: 30 days to complete deletion (allowing for recovery requests)
• Payment data: 7 years (UK tax and accounting requirements)
• Support communications: 3 years from last contact
• Marketing data: Until consent is withdrawn or 3 years of no engagement

6.2 Account Deletion

When you delete your account, we will:

• Remove your personal data within 30 days
• Retain certain data if required by law
• Anonymize any data used for research or analytics

7. YOUR PRIVACY RIGHTS

Under UK data protection laws, you have the following rights:

7.1 Right of Access

Request a copy of the personal data we hold about you.

7.2 Right to Rectification

Request correction of inaccurate or incomplete personal data.

7.3 Right to Erasure ("Right to be Forgotten")

Request deletion of your personal data in certain circumstances.

7.4 Right to Restrict Processing

Request limitation of how we process your personal data.

7.5 Right to Data Portability

Request transfer of your data to another service provider.

7.6 Right to Object

Object to processing based on legitimate interests or for direct marketing.

7.7 Right to Withdraw Consent

Withdraw consent for processing that relies on your consent.

7.8 How to Exercise Your Rights

To exercise any of these rights, contact us at support@caruso-languages.com. We will respond within one month of receiving your request.

8. INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to and processed in countries outside the UK. When we do this, we ensure appropriate safeguards are in place, such as:

• Adequacy decisions by the UK government
• Standard contractual clauses approved by UK authorities
• Binding corporate rules or certification schemes

9. CHILDREN'S PRIVACY

9.1 Age Restrictions

Our Services are intended for users aged 13 and above. We do not knowingly collect personal data from children under 13.

9.2 Parental Consent

Users between 13-17 should obtain parental or guardian consent before using our Services.

9.3 Discovery of Underage Users

If we become aware that we have collected personal data from a child under 13, we will take steps to delete such information promptly.

10. COOKIES AND TRACKING TECHNOLOGIES

10.1 Cookies We Use

We use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze how you use our Services
• Provide personalized content and features
• Ensure security and prevent fraud

10.2 Cookie Management

You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our Services.

10.3 Analytics

We may use analytics services to understand how our Services are used. These services may use cookies and similar technologies.

11. THIRD-PARTY LINKS AND SERVICES

Our Services may contain links to third-party websites or integrate with third-party services. This privacy policy does not apply to those external services. We encourage you to review the privacy policies of any third-party services you use.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our practices or applicable laws. We will:

• Notify you of material changes via email or through our Services
• Post the updated policy with a new effective date
• Provide additional notice for significant changes affecting your rights

Your continued use of our Services after changes become effective constitutes acceptance of the updated policy.

13. CONTACT US AND COMPLAINTS

13.1 Privacy Questions

For questions about this Privacy Policy or our data practices, contact us at:

13.2 Complaints

If you believe we have not handled your personal data properly, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):

14. DATA PROTECTION OFFICER

While we are not required to appoint a Data Protection Officer, our privacy team is responsible for overseeing data protection compliance. Contact us at support@caruso-languages.com for any data protection matters.