Last modified: July 1st 2020
Lingoly, Inc. ("Company" or "we") respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (the "Policy"). This Policy describes the types of information we may collect from you or that you may provide when you visit the website, www.lingoly.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This Policy applies to information we collect: (1) on this Website; (2) in email, text, and other electronic messages between you and this Website; (3) through mobile and desktop application you download from this Website, which provide dedicated non-browser-based interaction between you and this Website; and (4) when you interact with our advertising and applications on third-party websites and services, only if those applications or advertising include links to this Policy.
It does not apply to information collected by: (1) Us offline or through any other means, including on any other website operated by Company or any third party; or (2) any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
Table of Contents
By visiting and using this Website, you are agreeing to be bound by the terms and conditions of this Policy, as well as our Terms of Use, all disclaimers, and other terms and conditions that appear elsewhere on our Website. Your use of this Website, therefore, constitutes your affirmative consent to our collecting, use, and disclosure of information, including, without limitation Personal Information (as defined below) as detailed in this Policy.
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification or parental or legal guardian consent, we will delete that information. If you believe we may have any information from or about a child under 16, please contact us at team@lingoly.com.
California residents under 16 years of age may have additional rights regarding the collection and sale of their Personal Information. Please see Your Rights and Choices for more information.
We collect several types of information from and about users of our Website, including 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, household, or device ("Personal Information"). Personal information does not include: (a) publically available information from government records; (b) de-identified or aggregate consumer information; or (c) information excluded from the scope of the California Consumer Privacy Act (CCPA).
The CCPA identifies eleven (11) categories of Personal Information and requires online businesses to disclose which of those categories have been collected from their consumers within the preceding twelve (12) months. Accordingly, our Website has collected the following categories of Personal Information from its consumers within the last twelve (12) months:
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.
YES
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
Directly from you when you provide it to us on or through our Website, for example, when you create a user profile page that includes your photograph or image, information describing yourself, etc.
Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, for example, Stripe (payment and payout processor), Google Analytics (application programming interface (API) for tracking and reporting website traffic), Twilio Sendgrid (API for email delivery), and Twilio (API for messaging).
The collection of information, including Personal Information, is necessary for us to process and complete any transactions between our translators and the clients, who subscribe to our Website. The information we collect on or through our Website may include:
Information that you provide by filling in forms on our Website. This includes Personal Information provided at the time of registering to use our Website, subscribing to our service, creating a user profile, posting translation jobs or bidding upon them, verifying your identity, rating the translators after job completion, or requesting further services. We may also ask you for information when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Transactional details that you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information (such as those listed in Category B above) through our third-party payment processor before placing an order through our Website.
Your search queries on the Website.
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of this Website and connected with this Website such as Company’s social media platforms, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
Information about your online activities over time and across third-party websites or other online services The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
Estimate our audience size, usage patterns, and trends.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.
Track users’ movements around the Website.
Administer the Website.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Your Rights and Choices.
Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Some Internet browsers incorporate a "Do Not Track" feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates "Do Not Track" signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and website, we do not respond to "Do Not Track" signals at this time. As the technology and communication between browser and website improves, we will reevaluate the ability to honor "Do Not Track" signals and may make changes to our policy. For more information about "Do Not Track," please visit the Future of Privacy Forum, an industry-supported Washington, D.C. think tank and advocacy group, located at www.allaboutdnt.com.
Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Rights and Choices.
We use or disclose information that we collect about you or that you provide to us, including any Personal Information for one or more of the following purposes:
To present our Website and its contents to you.
To create, maintain, customize, and secure your account with us, and provide notices in regards thereto.
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
To provide you with information, products, or services that you request from us.
To provide, support, personalize, and develop our Website, products, and services.
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 provide you with newsletters, marketing, or promotional materials and other information that may be of interest to you.
To personalize your Website experience 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).
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
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 Website users is among the assets transferred.
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
To notify you about changes to our Website or any products or services we offer or provide though it.
In any other way we may describe when you provide the information.
To fulfill any other purpose for which you provide it.
For any other purpose with your consent.
We may also use your information to contact you about third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Your Rights and Choices.
We currently do not display advertisements from non-affiliated third parties upon which you can click or otherwise interact.
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.
If you supply us with your email address and/or mobile phone number, you may receive periodic email or text messages, electronic newsletters, and/or promotions from us with information specific to your use of this Website if allowable by applicable law. Specifically, we may send you information about our services, contact you about certain transactions or information requests, or to learn more about your preferences. If you do not wish to receive promotional offers from us, you may elect to opt-out by following the unsubscribe instructions contained in the delivered content, submitting a support ticket on our Website, or by emailing us at team@lingoly.com with "Opt-Out" in the subject line. Certain communications, such as those associated with important account information, may not be affected by the Opt-Out. Please be mindful that such requests may take several days to process after its receipt.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Information that we collect or you provide as described in this Policy for the following business purposes:
To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business (collectively, "Service Providers"). For example, for credit card clearance, credit reference, order fulfillment, delivery, data analysis, or customer support.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Lingoly, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Lingoly, Inc. about our Website users is among the assets transferred.
To fulfill the purpose for which you provide it (such as posting a job or submitting a bid).
For any other purpose disclosed by us when you provide the information.
With your consent.
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. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
We may also disclose your Personal Information:
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use, _________________, and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Lingoly, Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
In the preceding twelve (12) months, we have 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.
Category G: Geolocation data.
Other than the foregoing disclosures, in the preceding twelve (12) months, we have not rented, sold, or shared Personal Information with other people or nonaffiliated companies for their direct marketing purposes in any of the abovementioned categories found at ___________.
Consumer’s online privacy rights vary from jurisdiction to jurisdiction. Given that our principal place of business is Los Angeles, California, we follow CCPA and applicable federal laws, rules, and regulations that provides specific rights and choices regarding Personal Information. This section describes those rights and how you may exercise those rights.
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following direct control over your information:
Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website and the Privacy Controls page in Google Analytics. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own products or services, you can opt-out by sending us an email stating your request to team@lingoly.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI’s website.
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 twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you: (a) the categories of Personal Information we collected about you; (b) the categories of sources for the Personal Information we collected about you; (c) our business or commercial purpose for collecting that Personal Information; (d) the categories of third parties with whom we share that Personal Information; (e) the specific pieces of Personal Information we collected about you (also called a data portability request); and/or (f) if we disclosed your Personal Information for a business purpose, we will identify the Personal Information categories that each category of recipient obtained. Please note that we do not provide these access and data portability rights for business-to-business Personal Information.
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 (see Exercising Access, Data Portability, and Deletion Rights below), 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 Providers to: (a) 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; (b) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (c) debug products to identify and repair errors that impair existing intended functionality; (d) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (e) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (f) 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; (g) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (h) comply with a legal obligation; and/or (i) make other internal and lawful uses of the Personal Information that are compatible with the context in which you provide it. Please note that we also do not provide these deletions rights for business-to-business Personal Information.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending a request to the following address:
Lingoly Inc.
Attn: Lingoly Account Update
21171 S. Western Ave.
Suite 2701
Torrance, California 90501
email: team@lingoly.com
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: (a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include: (i) providing your mobile number, full legal name, and/or date of birth; and (b) describing your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) 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 useable 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 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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or different level or quality of goods or services. 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.
You may review, update, or modify your or your account information directly on the Website by logging into your account profile page or by submitting a support ticket through the Website’s Help function. You may also send us an email at team@lingoly.com to request access to or correct any Personal Information that you have provided to us. If you email us, please put "Review of Account Information" in the subject line. Please note that we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We reserve the right to retain your as necessary for recordkeeping and other compliance purposes to the extent allowed by applicable law, subject to your right of deletion of information.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls; we also engage in at-rest AES 256-bit encryption technology. Any payment transactions are performed through a third-party payment processor, Stripe, which data security practices may be found here https://stripe.com/privacy.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
When you use the Website, information, including Personal Information, will be stored (to the extent allowable by applicable law) and processed by our Service Providers in the United States as we are a California based company. As such, when you use your Lingoly account, you consent to the collection and processing in the United States of the information, including Personal Information, as described above. Please note that our Service Providers may process information, including Personal Information, in the United States and elsewhere whose laws may materially differ from the jurisdiction in which you reside. When we transfer your information, including Personal Information, we will protect said information as described in this Policy.
Our Policy does not apply to the practices of other websites that are not owned, operated, or controlled by us or our affiliates or people that we do not employ or manage. Accordingly, this Policy is only applicable to this Website, and not to any other websites that you may be able to access from here including, without limitation, any links to third party websites, each of which may have data collection, storage, and use practices and policies that differ materially from this Policy. As such, when you leave this Website via a link or enable a third party service, such online services may collect Personal Information about you. According, if you use any of these links, you will leave this Website and enter a third-party website entirely at your own risk. Please review the privacy policies for all third-party websites for more information about those privacy policies that apply to your use of those third-party websites. We do not and cannot control the websites, applications, or other services that are operated by these third parties. We are not responsible for the privacy practices or the content of any other website but our own. Thus, you should check the privacy policy of the applicable third-party service. We therefore disclaim all liability for third party actions, including, without limitation, actions relate to the use or disclosure of Personal Information by third parties, and, likewise, cannot be held liable or responsible for any third-party website, its materials, content, or information contained thereon.
We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated privacy policy on the Website and update the privacy policy’s effective date at the top of the page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
To ask questions or comment about this Policy and our privacy practices, contact us at:
Lingoly Inc.
Attn: Privacy Policy
21171 S. Western Ave.
Suite 2701
Torrance, California 90501
email: team@lingoly.com