Linguatorium Research Corporation ("we," "us," "our," or "ours") has developed this Privacy Policy to explain how we may collect, retain, process, share and transfer your personal data when you visit our websites or use the educational services that we provide. If you have an agreement with us, this policy may be incorporated by reference into that agreement.

When you simply visit the website linguatorium.com, we do not collect any data about you beyond the standard data that is normally logged by web servers (such as your IP address, your web browser version, and the page you have visited).

However, when you sign up for or log into your account on the website linguatorium.com, you are trusting us with your personal data, namely:

• Biographical information: name, gender, year of birth, native language(s), citizenship and nationality
• Contact information: postal address(es), email address(es), telephone number(s)
• Activity logs: data about educational activities assigned to and/or completed by you, or other actions that you perform while using our services
• Learner models: computationally summarized data about your performance, knowledge, and skills (for example, information about sounds or words with which you might need additional practice)

We may also collect, store and process any other data that you choose to provide to us. For example, if you decide to tell us about your experience with our services, we may store and process that data as well.

We may make your personal data available to educational institutions or other entities that enroll you in our services. We may transfer your personal data to our contractors, successors or assignees, but only if they agree to follow this policy.

We take special steps to protect your personal data. Our systems and processes are engineered with data protection by design and by default. We will only keep those types of personal data which are necessary to fulfill our duties, such as those stipulated in any agreements that we have with you. We will never sell your personal data, even if you tell us that we may do so. If you are a primary or a secondary student, we will only use your personal data and behavioral information for educational purposes, and we will not advertise to you or your parents.

We may use de-identified data for product development, research, or other purposes. Such de-identified data will have all direct and indirect personal identifiers removed (this includes, but is not limited to, name, any ID numbers, date of birth, and location data). Furthermore, we will not re-identify such de-identified data, and will not transfer it to any third party, unless that party also agrees not to attempt data re-identification.

We will store and process your personal data in accordance with industry best practices. This includes appropriate administrative, physical, and technical safeguards to secure your personal data from unauthorized access, disclosure, and use. We will conduct periodic risk assessments and remediate any identified security vulnerabilities in a timely manner.

If you have a request concerning your personal data (for example, you would like us to fix a problem with your data, give you a copy of your data, or delete your data), please contact our Data Protection Officer via email at [email protected], or via postal mail at: Data Protection Officer, Linguatorium Research Corporation, P.O.Box 1266, Ames, Iowa, 50014-1266, USA.

FERPA. The Family Educational Rights and Privacy Act of 1974 (FERPA) is a United States federal law that protects the privacy of parents and students. We collect personally identifiable data from education records that are subject to FERPA ("FERPA Records"). FERPA Records include, but are not limited to, student names, passwords, identification codes, student submissions of assignments, student grades, and other data. To the extent that such data include FERPA Records, we will be considered a "School Official" (as that term is used in FERPA and its implementing regulations) and will comply with FERPA.

COPPA. The Children's Online Privacy Protection Act of 1998 (COPPA) is a United States federal law that prohibits unfair or deceptive acts or practices in connection with the collection, use, and/or disclosure of personal data from and about children on the Internet. Under COPPA, we are considered an "Operator." If you, as an Instructor, enroll any Learner who is under the age of 13, you agree to be solely responsible for compliance with COPPA, including, but not limited to, obtaining parental consent concerning the collection of the Learner's personal data in connection with the use of our services by you and by the Learner.

GDPR. The General Data Protection Regulation (GDPR) is an important piece of legislation that is designed to strengthen and unify data protection laws for all individuals within the European Union. We are fully committed to compliance with GDPR.

We may modify this policy from time to time (for example, to reflect changes to the law). You should look at this policy regularly. We'll notify you about modifications to this policy on the website linguatorium.com and/or via email. Changes will not apply retroactively and will become effective no sooner than fourteen days after they are posted. However, changes made for legal reasons will be effective immediately. If you continue using our services after this policy has changed, you will be bound by those changes. If you do not wish to consent to the changes, please stop using our services and contact us to discuss your options.

Last updated: September 14, 2022