Privacy Policy

realLINGUA General Privacy Policy

Effective Date: January 1, 2020

Last Reviewed on: February 14, 2020

At realLINGUA, we care about your personal data, so we have prepared this Privacy Policy to explain how we collect, use and share it.

This Privacy Policy (“Privacy Policy” or “General Privacy Policy”) details the personal data realLINGUA, Inc. (“realLINGUA”, “we”, “us” or “our”) receives about you, how we process it and your rights and obligations in relation to your personal data. Capitalized terms not defined here have the meanings set forth in the terms of service (the “Terms of Service”), located at https://reallingua.com/privacy 

By using or accessing our website and mobile application (our “Website”) and any other platform on which we provide our language learning platform (collectively, the “Service”), you agree to the terms of this Privacy Policy. We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will notify you by email or by placing a prominent notice on the Website. 

Residents of California and the European Union are afforded certain rights with respect to their personal information. To access realLINGUA Supplemental Privacy Notice for California Residents, visit [LINK]. To access realLINGUA Supplemental Privacy Notice for EU Residents, visit [LINK].

Information We Collect

Personal information means information about an individual from which that individual may be identified. It does not include data that has been aggregated or deidentified. In particular, we collect the following categories of personal information from our consumers: 

  • Identifiers
  • Individual first and last names, username or other similar identifier, and title.
  • Bank account and payment card details, including credit/debit card account numbers, expiry dates, and security codes to be used pursuant to the Payment Card Industry Data Security Standard (PCI DSS).
  • Billing address, delivery address, email address and telephone numbers.
  • Commercial Information
  • Details about types, variety, and use of products ordered, the method of delivery, payments to and from you and other details of products and services you have purchased from us.
  • Network Activity 
  • Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
  • Information about how you use our Service.
  • Communications between you and realLINGUA

We obtain personal information from the following categories of sources:

  • Directly from you. For example, from forms you complete or products you purchase.
  • Indirectly from you. For example, from observing your actions on our Website or on other websites which employ our Cookies. 

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information;

For example, if you share your name and contact information to request a price quote or ask a question about our Service, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase the Service, we will use that information to process your payment and facilitate the transaction. We may also save your information to facilitate subsequent transactions.

  • To provide, support, personalize, and develop our Website and Service;
  • To create, maintain, customize, and secure your account with us;
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud;
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
  • To personalize your experience on our Website and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law);
  • To help maintain the safety, security, and integrity of our Website, Service, databases and other technology assets, and business;
  • For testing, research, analysis, and product development, including to develop and improve our Website and Service;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • As described to you when collecting your personal information; and
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us  about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for the following purposes. When we disclose personal information for these purposes, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We may share your personal information: 

  • with service providers, and other third parties we use to support our business as needed for them to provide us with services that help us with our business activities and promote our Service to you;
  • with Software/IT service providers we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
  • when we believe sharing is necessary to protect our rights, preserve safety, investigate fraud or other wrongdoing;
  • when required by law, which includes complying with any court order, law, or legal process, including responding to a government or regulatory request;
  • in connection with the sale, transfer or financing of our business or its assets;
  • to enforce or apply our agreements, including for billing or collection purposes; and
  • for any other purpose disclosed by us when you provide the information.

Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use. We use cookies for the following purposes:

  • authentication - we use cookies to identify you when you visit our website and as you navigate our website
  • status - we use cookies to help us to determine if you are logged into our website
  • personalisation - we use cookies [to store information about your preferences and to personalise the website for you
  • security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
  • advertising - we use cookies to help us to display advertisements that will be relevant to you
  • analysis - we use cookies to help us to analyse the use and performance of our website and services
  • cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally

Our service providers use cookies and those cookies may be stored on your computer or other device when you visit our Website.

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://policies.google.com/privacy.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. If you block cookies, you will not be able to use all the features on our website.

Protection of Information

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorised access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. 

realLINGUA does its utmost to secure communications and data storage in order to protect confidentiality of your Information against loss and interception by third parties. However, it is important to know that there is no zero-risk against loss or interception by others of your Information. You are responsible for maintaining the security and confidentiality of your account’s username and password.

Storage of Information

We save your personal information in our database in order to improve our Service and our Website’s end user experience. If you wish that your personal information be permanently deleted from our database when you stop using our Service, please notify us at privacy@realLINGUA.com. realLINGUA is a United States (US) company. If you are located outside the US and choose to provide information to us, realLINGUA transfers your Information to our servers in the US. The US may not have the same data protection laws as the country in which you initially provided the Information. When we transfer your Information to the US, we will protect it as described in this Privacy Policy. By visiting our Website or providing realLINGUA with your Information, you fully understand and unambiguously consent to this transfer, processing and storage of your Information in the US. 

Data Retention

We retain your personal information for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law.

Children

We do not knowingly collect or solicit personal information from anyone under the age of 16.

In the event we learn that we have collected personal information  from a child under the age of 16 without verification of parental consent, steps will be taken promptly to remove that information. If you believe that we have or may have information from or about a child under 16 years of age, please contact us at privacy@realLINGUA.com.

Changes to Our Privacy Policy

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated Privacy Policy on our website and update the Privacy Policy’s effective date. You should check this page occasionally to ensure you are happy with any changes to this Privacy Policy. Your continued use of our Website or Service following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which realLINGUA collects and uses your personal information described here, your choices and rights regarding such use, or wish to exercise any rights which may be provided by your local data protection laws, please do not hesitate to contact us at:

Phone: ‪(734) 273-9232

Website: https://www.realLINGUA.com

Email: privacy@realLINGUA.com

Postal Address

realLINGUA

Attn: Privacy Officer

4951 N. Dixboro Rd.

Ann Arbor, MI 48105

 

 


realLINGUA Supplemental Privacy Notice for EU Residents

Effective Date: January 1, 2020

Last Reviewed on: February 14, 2020

This Privacy Notice for European Union Residents (“Supplemental Notice”) supplements the information contained in realLINGUA's General Privacy Notice https://reallingua.com/privacy (“General Privacy Notice”) and applies solely to all visitors, users, and others who reside in the European Union (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway). We adopt this notice to comply with the General Data Protection Regulation (GDPR) and any terms defined in the GDPR have the same meaning when used in this Privacy Notice. 

realLINGUA, Inc. is the data controller for your Personal Data. Our registered office is located at:

4951 N. Dixboro Rd.  Ann Arbor, MI 48105

Unless separately defined within this Supplemental Notice, the terms defined in the General Privacy Notice https://reallingua.com/privacy will be applicable to this Supplemental Notice. “Personal Data,” as used within this Supplemental Notice, is defined as any information relating to an identified or identifiable natural person. Personal Data includes “personal information” as defined and described within the General Privacy Notice

Information We Collect, How We Collect It, and How We Share It

Please visit our General Privacy Notice https://reallingua.com/privacy to learn more about our practices regarding Personal Data:

  • What Personal Data we collect
  • How we collect Personal Data 
  • Who we share Personal Data with
  • The purposes for which we share Personal Data

Lawful Bases for Processing

  • Safety and security. We use Personal Data about you and your use of the Service to verify accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies.
  • To protect our legitimate business interests and legal rights. Where required by law or where we believe it is necessary to protect our legal rights, interests, and the interests of others, we use Personal Data about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger, or sale of a business.
  • Contractual necessity. We process your Personal Data when it is necessary for the entry into, or performance of, a contract with you. The terms of our contractual agreement can be found at https://reallingua.com/terms
  • With your consent. We process Personal Data about you where you have given us consent to do so for a specific purpose not listed above. 

Data Storage, Protection and Retention

Please visit our General Privacy Notice https://reallingua.com/privacy to view the details of our data storage, data protection, and data retention practices. 

Your Rights

Subject to EU law, you have the following rights in relation to your Personal Data. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Right of access. 

If we are processing your Personal Data you may request a copy of that Personal Data by contacting us. 

Right to rectification. 

If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. You can also do this yourself via your user settings. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.

Right to erasure. 

You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). You can also do this yourself via your user settings. If we shared your data with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.

Right to restrict processing. 

You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.

Right to data portability. 

You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Right to object. 

You may ask us at any time to stop processing your Personal Data, and we will do so:

If we are relying on a legitimate interest (described under the “How We Use Data” section above) to process your Personal Data -- unless we demonstrate compelling legitimate grounds for the processing; or

If we are processing your Personal Data for direct marketing.

Rights in relation to automated decision-making and profiling. 

You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.

Right to withdraw consent. 

If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.

Right to lodge a complaint with the data protection authority.

You have the right to file a complaint concerning our processing of your personal data with your national (or in some countries, regional) data protection authority.   The EU Commission has a list here:  http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identifiers, Commercial Information, and Network Activity, as defined within the General Privacy Notice, to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have purchased the Service from us, if you were on a marketing list before May 25, 2018, or if you signup to receive marketing communications from us and in each case, you have not opted out of receiving that marketing.

You can ask us by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a Service transaction.

How to Exercise Your Rights

You may contact us to exercise your rights at: 

Phone: ‪(734) 273-9232

Website: https://www.realLINGUA.com

Email: privacy@realLINGUA.com

Postal Address

realLINGUA

Attn: Privacy Officer

4951 N. Dixboro Rd.

Ann Arbor, MI 48105

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child. Your request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. 

Making a request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Data associated with that specific account.

We endeavor to respond to each request within one month from the date on which they are received.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Changes to Our Privacy Notice

We reserve the right to amend this Supplemental Notice at our discretion and at any time. When we make changes to this Supplemental Notice, we will post the updated Supplemental Notice on our website and update the Supplemental Notice’s effective date. You should check this page occasionally to ensure you are happy with any changes to this Supplemental Notice. Your continued use of our Website or Service following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Supplemental Notice, the ways in which realLINGUA collects and uses your information described here, your choices and rights regarding such use, or wish to exercise any rights which may be provided by your local data protection laws, please do not hesitate to contact us at:

Phone: ‪(734) 273-9232

Website: https://www.realLINGUA.com

Email: privacy@realLINGUA.com

Postal Address

realLINGUA

Attn: Privacy Officer

4951 N. Dixboro Rd.

Ann Arbor, MI 48105


realLINGUA Supplemental Privacy Notice for California Residents

Effective Date: January 1, 2020

Last Reviewed on: February 14, 2020

This Privacy Notice for California Residents (“Supplemental Notice”) supplements the information contained in realLINGUA's General Privacy Notice https://reallingua.com/privacy (“General Privacy Notice”) and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this Supplemental Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Supplemental Notice. 

Unless separately defined within this Supplemental Notice, the terms defined in the General Privacy Notice https://reallingua.com/privacy will be applicable to this Supplemental Notice. 

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months: 

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements. 

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. 

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from purchasing the Service.
  • Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes: 

  • To fulfill or meet the reason you provided the information;

For example, if you share your name and contact information to request a price quote or ask a question about our Service, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase the Service, we will use that information to process your payment and facilitate the transaction. We may also save your information to facilitate subsequent transactions.

  • To provide, support, personalize, and develop our Website and Service;
  • To create, maintain, customize, and secure your account with us;
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud;
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
  • To personalize your experience on our Website and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law);
  • To help maintain the safety, security, and integrity of our Website, Service, databases and other technology assets, and business;
  • For testing, research, analysis, and product development, including to develop and improve our Website and Service;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • As described to you when collecting your personal information; and
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us  about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, realLINGUA has disclosed the following categories of personal information for a business purpose: 

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties: 

  • Service providers.

Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

Deletion Request Rights 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. 

Authorized Agents

Only the consumer or an Authorized Agent may make a verifiable consumer request related to their Personal Information.  An “Authorized Agent” is a person, or a business entity that is registered with the California Secretary of State, that consumers have authorized to act on their behalf or an individual granted authority under a written power of attorney issued pursuant to California Probate Code sections 4000 to 4465.  

If you are an Authorized Agent who wishes to submit a request to know, a request to delete, or a request to opt-out on behalf of another consumer, please submit to us sufficient information to allow us to verify your identity to a reasonably high degree of certainty and either: 

  1. proof of authorization to submit the request, written and signed by the consumer; or 
  2. a power of attorney pursuant to Probate Code sections 4000 to 4465.

We may deny a request from an Authorized Agent who does not submit adequate proof that they have been authorized by the consumer to act on the consumer's behalf. We may also contact the consumer directly to confirm their identity and that they provided you permission to submit the request on the consumer's behalf. 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time (up to 45 more calendar days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Personal Information Sales Opt-Out and Opt-In Rights

Under California law, if you are 16 years of age or older, you have the right to opt-out of the sale of your personal information at any time (the "right to opt-out"). Consumers between age 13 and age 16 and parents of consumers under age 13 must give affirmative authorization (the right to “opt-in”) for any personal information sales. Consumers who opt-in to personal information sales may opt-out of future sales at any time. realLINGUA does not sell the personal information of its consumers, including any minors under 16 years of age.  

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to Our Privacy Notice

We reserve the right to amend this Supplemental Notice at our discretion and at any time. When we make changes to this Supplemental Notice, we will post the updated Supplemental Notice on our website and update the Supplemental Notice’s effective date. You should check this page occasionally to ensure you are happy with any changes to this Supplemental Notice. Your continued use of our Website or Service following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Supplemental Notice, the ways in which realLINGUA collects and uses your information described here, your choices and rights regarding such use, or wish to exercise any rights which may be provided by your local data protection laws, please do not hesitate to contact us at: