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Privacy Policy

At LinguaNova Online, we are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, store, and protect your information in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

1. Data Controller

Linguist GmbH Bergmannstrasse 102-103 10961 Berlin, Germany Operational Office: Giorgi Brtskinvale St., 109–111 Batumi 6010, Georgia Managing Director: [Name] Email: info@linguanovaonline.com Phone: +995 568 814 480 Website: linguanovaonline.com We are the data controller responsible for processing your personal data.

2. Data Protection Officer

For privacy-related inquiries, please contact our Data Protection Officer at: dpo@linguanovaonline.com. If we are required to appoint a DPO under GDPR, their contact details will be listed here.

3. What Personal Data We Collect

We collect the following types of personal data: (a) Account Information: name, email address, phone number, country of residence, preferred language, date of birth (for age verification); (b) Payment Information: billing address, payment method details (processed securely by our payment processors); (c) Course Data: course enrollment, attendance records, progress, assignments, grades, teacher feedback; (d) Communication Data: messages exchanged via our platform, Telegram chat, or email; (e) Technical Data: IP address, browser type, device information, cookies, usage patterns, log files; (f) Marketing Preferences: your consent to receive promotional communications.

4. How We Collect Your Data

We collect data: (a) Directly from you when you create an account, enroll in courses, make payments, or contact us; (b) Automatically through cookies and similar technologies when you use our website; (c) From third parties such as payment processors, social media platforms (if you choose to sign in via social login), and analytics providers.

5. Legal Basis for Processing

We process your personal data based on: (a) Contract Performance: to provide our educational services, manage your account, and process payments; (b) Legitimate Interests: to improve our services, ensure platform security, prevent fraud, and conduct analytics; (c) Legal Obligations: to comply with tax, accounting, and other legal requirements; (d) Consent: for marketing communications and optional data processing (which you can withdraw at any time).

6. How We Use Your Personal Data

We use your data to: (a) Provide and deliver our language courses; (b) Manage your account and enrollments; (c) Process payments and prevent fraud; (d) Communicate with you about courses, schedules, and platform updates; (e) Provide customer support; (f) Send marketing communications (with your consent); (g) Improve our services through analytics; (h) Comply with legal obligations; (i) Ensure platform security and prevent unauthorized access.

7. Data Sharing and Third Parties

We may share your data with: (a) Teachers and Course Instructors: to deliver educational services; (b) Payment Processors: to handle transactions securely; (c) Communication Platforms: such as Telegram for course-related communications; (d) Analytics Providers: to understand platform usage (anonymized where possible); (e) Cloud Service Providers: for data storage and hosting; (f) Legal Authorities: when required by law or to protect our rights. We do not sell your personal data to third parties.

8. Data Retention

We retain your personal data for as long as necessary to: (a) Provide our services and maintain your account; (b) Comply with legal, accounting, and regulatory requirements (typically 7-10 years for financial records); (c) Resolve disputes and enforce our agreements. After the retention period, we will securely delete or anonymize your data.

9. Your Rights Under GDPR

You have the right to: (a) Access: request a copy of your personal data; (b) Rectification: correct inaccurate or incomplete data; (c) Erasure: request deletion of your data ("right to be forgotten"); (d) Restriction: limit how we process your data; (e) Data Portability: receive your data in a structured, machine-readable format; (f) Object: object to processing based on legitimate interests or for marketing purposes; (g) Withdraw Consent: at any time, without affecting prior processing; (h) Lodge a Complaint: with your local data protection authority. To exercise these rights, contact us at privacy@linguanovaonline.com.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to: (a) Enable essential website functionality; (b) Remember your preferences and settings; (c) Analyze website traffic and user behavior; (d) Deliver personalized content and advertisements. You can manage cookie preferences through your browser settings. For more details, see our Cookie Policy.

11. Data Security

We implement appropriate technical and organizational measures to protect your data, including: (a) Encryption of data in transit and at rest; (b) Secure access controls and authentication; (c) Regular security audits and vulnerability assessments; (d) Employee training on data protection. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

12. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). We ensure adequate protection through: (a) EU Standard Contractual Clauses; (b) Adequacy decisions by the European Commission; (c) Other legally recognized transfer mechanisms. We assess the laws of recipient countries to ensure your data remains protected.

13. Children's Privacy

Our services are intended for users aged 16 and above. If you are under 16, you may only use our services with parental or guardian consent. We do not knowingly collect data from children under 13. If we discover such data has been collected, we will delete it promptly.

14. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects. Any automated processing (e.g., spam filtering, course recommendations) is limited and does not impact your rights or freedoms.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or through a prominent notice on our website. Your continued use of our services after changes take effect constitutes acceptance of the updated policy.

16. Contact Us

For questions, concerns, or to exercise your rights, contact us at: Email: info@linguanovaonline.com Privacy inquiries: privacy@linguanovaonline.com Address: Linguist GmbH Bergmannstrasse 102-103 10961 Berlin, Germany Operational Office: Giorgi Brtskinvale St., 109–111 Batumi 6010, Georgia Phone: +995 568 814 480

17. Supervisory Authority

You have the right to lodge a complaint with your local data protection authority. In Germany, this is: Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59–61, 10555 Berlin, Germany. Phone: +49 (0)30 13889-0. Email: mailbox@datenschutz-berlin.de.

Effective Date: October 31, 2024