Privacy Policy

This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage of Personal Data (as defined below) made by SpeakingPal Ltd (“SpeakingPal”, “Company”, “we” or “us”).

SpeakingPal is the developer, owner and developer of a mobile and web applications and the services made available therein (respectively “SpeakingPal App” and “Services”), offered to be used by Individual Users or as our Partner’s Users, all as further detailed and defined under our Terms of Use (“Terms”). This Privacy Policy constitutes an integral part of our Terms and definitions used herein used but not defined herein shall have the meaning ascribed to them in the Terms.  

This Privacy Policy governs our collection and processing of Personal Data practices in connection with:  

• Individuals who access and use our website are available at: https://www.speakingpal.com (respectively “Website” and “Visitors”);
• Users who have installed and are interacting with our SpeakingPal App and Services as Individual Users. 
• Our Partner’s Users, using the SpeakingPal App under the Partner’s designated account.

Each of the Visitors, Individual Users and Partner’s Users shall also be referred to herein as “user” or “you”.  

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below). 

The types of Personal Data we receive and collect depend on your interactions with us, including which Services you use and how you use them. Any Personal Data you provide is made at your free will and consent (where required under applicable data protection legislation), and you acknowledge that you are not under any statutory obligation to provide us with Personal Data. However, we must collect or receive some Personal Data to provide certain Service, and if you will not provide us with such Personal Data, we will not be able to fulfill certain purposes, for example, provide certain Services or enable certain use of our Website - all as described under Section (4) below - “Data We Collect & Purpose of Collection and Use“ which details the purposes for which each Personal Data set is collected.

This Privacy Policy further includes or incorporates specific information required under applicable data protection laws for residents of certain jurisdictions, among others:

If you are a located in the EEA or UK – this Privacy Policy further details our lawful basis for processing Personal Data, information regarding cross border data transfer and your rights, as well as additional information we are required to disclose to you under the EU/UK General Data Protection Regulations (“GDPR”). This will apply in the event our Services are offered to Customers located in the EEA or UK.    

If you are a US resident – please review Section 14 of this Privacy Policy “Additional Notice for Us Residents”, which further details certain information and disclosures under applicable US state laws, including your rights.

If you are Partner User:

Except for processing of certain online usage data and device identifiers we process internally for our needs, we process Partner Users Personal Data only on behalf of the Partner, as its service provider and data processor and accordingly, the Partner determines which Personal Data will be disclosed to us by the Partner and is responsible for the processing of your Personal Data and the Partner’s own privacy policies and privacy practices will govern the processing of your Personal Data. This Privacy Policy governs solely our data processing practices. However, given the above and providing transparency to any end users interacting with our SpeakingPal and Services, this Privacy Policy further provides information regarding the Personal Data that might be collected with regards to any such Partner Users use of the Apps, however, solely directly related to the SpeakingPal Apps functionalities. You should further review the Partner’s policies as they independently apply to its data collection and processing practices, as well as contact the Partner, on behalf of which you use or interact with the SpeakingPal Apps and Services, in connection with a request to exercise your rights related to your Personal Data.

We reserve the right to update or amend the Privacy Policy, from time to time, as we find needed and applicable and at our sole discretion. The last revision date will be reflected in the “Last Update” heading located at the top of the Privacy Policy. In the event required under applicable laws, or if we implement any changes that substantially change our privacy practices, we will provide notification of such updates or changes, using reasonable means. Any amendments to our privacy practices described under this Privacy Policy will become effective when we publish the modified Privacy Policy, unless otherwise required under applicable laws. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.  

SpeakingPal Ltd. is the data controller of the Personal Data collected with regards to Visitors, SpeakingPal App Individual Users and certain information related to Partner Users as specifically detailed below.

If you are a Partner User, the Partner acts as an independent controller with respect to any Personal Data it collects through the SpeakingPal App or the Services. We do not control, monitor or bear responsibility with regard to the Partner privacy practices which are governed by its own policies. 

Contact Information: 

Questions, comments, requests, and complaints regarding this Privacy Policy and our privacy practices are welcome and should be addressed to us by using the contact details below. All requests will be dealt with promptly and efficiently.  

SpeakingPal -  privacy@SpeakingPal.com

You will find below information regarding the types of data we collect, the purposes for which we process your Personal Data as well as our lawful basis for processing (where the GDPR applies to your Personal Data).

We may collect aggregated, non-personal, and non-identifiable information which may be made available or gathered via your use of the Website SpeakingPal Apps and Services (“Non-Personal Data“). This may include technical information regarding your device or browser, type of operating system, and aggregated usage information. We are not aware of the identity of the individual from which the Non-Personal Data is collected. Also, we may process and anonymize or aggregate Personal Data in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified individual or device. Non-Personal Data may be used and disclosed by us without limitation and for any purpose, including for commercial, research, or statistical purposes. Some of this information may be considered “de-identified” under U.S. privacy laws (i.e., data that is no longer linked or reasonably linkable to an identified or identifiable consumer). Where we rely on data that has been “de-identified” as defined by U.S. privacy laws, we will take reasonable measures to ensure that the de-identified information cannot be associated with an individual, household, or device.

When you interact or use our Website, SpeakingPal App and Services, we collect individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information” as defined under applicable law). This may include online identifiers, names, emails, etc., subject to applicable law.

If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.  

We have included below information about the Personal Data we collect, how and for which purposes we process and use your Personal Data and the lawful basis for which we do so (subject to the GDPR, if applicable).  

Please note that the actual processing operation for each purpose of use and lawful basis detailed below may differ, and we are only responsible for the Personal Data we collect and process as the controller of the Personal Data. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the “Cross Border Data Transfer” Section below, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce our agreements, terms and policies, as well as to protect the security or integrity of our databases, SpeakingPal App and Services, and to take precautions or defend against legal liability and claims. Such processing is based on our legitimate interests.

1. Online Identifiers & Device and Usage Data. 
2. Personal Data Sets: 

When you access or interact with our Website, SpeakingPal Apps and Services (including Visitors browsing our Website and Individual Users or Partner Users downloading, accessing or using our SpeakingPal Apps and Services), certain information regarding your access and use is processed, including information that is automatically collected and generated through use of our, or our third-party service providers’ and marketing partners’, cookies and tracking technologies (see the “Cookies and Tracking Technologies” Section of this Privacy Policy).

This information includes online identifiers associated or transmitted from the user’s browser and device, such as Internet Protocol (IP) address, cookie identifiers, user agent, mobile app identifiers, and similar unique online identifiers, etc. (“Online Identifiers”). Online Identifiers, such as IP address, are further used to generate certain information, for example, extract your approximate location (e.g., country and Zip). 

In addition, when you access our Website or use any of our SpeakingPal Apps and Services, we collect information regarding your browser and device (for example, type of device, operating system, etc.) as well as information regarding your use and interactions with the Website or use any of our SpeakingPal Apps and Services that may be automatically collected. This information may include session durations time and date stamp, the content viewed on our Website or Services, your interactions within the SpeakingPal Apps and Services including user-interface click crash data, how often you use the SpeakingPal Apps and Services, the URL or advertising campaign from which you have reached our Website, language preferences, etc. (“Device and Usage Data”). If the Device and Usage Data is associated with an Online Identifier it is processed by us as Personal Data.

We collect and use Online Identifiers and Device and Usage Data for the following purposes:  

Our Website, SpeakingPal Apps and Services functionality, operation, security and fraud prevention, debugging and to resolve technical issues and errors;

To customize the Services based on your approximate location (i.e., to present you with the webpages applicable to your territory, etc.);

Internal analytics and statistics, used to enhance and improve our Website, SpeakingPal Apps and Services, and the way we offer them, etc. for example, we analyze how users use our SpeakingPal Apps or the most used feature;

Processing Online Identifiers and Device and Usage Data for security and necessary operational purposes and processing Device and Usage Data related to Services obtained based on our records, etc., for customizations, internal analytics and improvements is based on our legitimate interests. Processing Online Identifiers and Device and Usage Data through our use of cookies for analytic purposes is based on your consent - where required under applicable laws. You may withdraw consent, opt-out or otherwise change your preferences regarding our use of cookies at any time using your browser and device settings.

2. Contact Information & Communications Data. 
3. Personal Data Sets:

We process Visitors and other Individual Users and Partner Users contact information, such as, as applicable to the communication, name, email address, phone number (“Contact Information”), if you contact us with any inquiries or request to connect, be provided with information regarding our SpeakingPal Apps and Services, contact our support team  etc., by sending us an email or by any other means of communication we make available.

We may further process and store the contacts of communications with you, including email correspondence and may also process data related to such communications such as interactions with email communications (access time and date), etc. (“Communications Data”). 

We collect and use Contact Information and Communications Data for the following purposes:  

For responding to your inquiries or request or send you the information and materials you have requested to receive. 

Communications Data may be processed and stored by us in order to have records of our communications, to improve our marketing efforts, and in the event we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable). 

Processing Contact Information and Communications Data to reponed to your inquiry or request in the event you have contacted us or send you information or materials you have requested to receive, is based on your consent. For other purposes set forth above, Contact Information and Communications Data are processed and stored subject to our legitimate interests.   You can opt-out or withdraw consent, as applicable, from receiving our marketing communications, at any time using the “unsubscribe” or other option we provide within the body of the message. 

3.  Registration, Account & Transactions 
4. Personal Data Sets: 

If you are or wish to become SpeakingPal App Individual User of the Services, upon or prior to installing the App, you may be required to create an account or provide certain information which may include your name; email address; phone number (“Account Information”). If you choose to obtain the features of our Services which are subject to payment (for example in-app or Subscription payments), you will provide certain payment information, however we do not collect access or store your full payment method details. Payments that are made through in-app purchase are subject to Google Play or Apple Store terms and payments made through other third-party payment processors are further subject to their terms and policies. We only process commercial transaction data such as records of purchases and prices; payment method identifier (can be a token or 4 digits, etc.) address , approximate location (country, etc.), telephone number and email address (“Transactions Data”).

If you are Partner’s User, in order to use the SpeakingPal App, the Partner will provide us with certain information, the scope of which is subject to the Partner’s sole discretion (this may include name, ID number, email address, etc.), in order to create a designated account for you to use the SpeakingPal App, as the data processor on behalf of the Partner. Please note we will receive this data solely for account creation and management, and we will not use this data for any other purposes. 

We collect and use Account Information and Transactions Data for the following purposes:  

To create and designate your account, to secure your account including authentication and validation purposes;

Account management and administration; 

To provide the Services, including to enable access to features subject to Subscriptions, process payments and maintain records of transactions for record keeping purposes; 

To communicate with you and send you transactional and operational messages (for example, billing, invoices, and other operational notices such your shipment status) as well as promotional offers (for example, to send you customer success and relation communications, marketing communications, materials, and other information regarding our Services). We enable you to change your preferences at any time, including to opt-out and unsubscribe from marketing communications. However, please note that even in case you have opted-out from our marketing communication, we may still use your contact details to send you service-related and operational communications;

Processing Account Information and Transactions Data to designate your account, process payments and to provide the Services, is based on contract necessity. Processing these data sets for security and authentication purposes, for marketing communications, analytics and customization purposes, and for record keeping and compliance with applicable laws (such as tax laws, etc.) is based on our legitimate interest, or, where required under applicable laws, based on your consent, and you will be entitled to withdraw your consent any time.

4. Service Usage Data

When you install SpeakingPal App and use our Services, we collect certain information related to such usage, as follows: 

Subject to the apps’ permissions you enable through your devices, SpeakingPal may collect the recorded audio you upload to use the Services, however such us store only for a short period of a few days . We will further collect and process the performance insights provided to you as part of the Services (i.e., improvement in your English skills, corrections, performance score, etc.) (collectively “Services Usage Data”).

We collect and use Services Usage Data for the following purposes:  

To provide you with the Services; 

To improve the SpeakingPal App and Services, including related technology. 

Processing Service Usage Data to provide you with the Services designate your account, process payments and provide you with the Services, is based on contract necessity. Processing these data sets to improve our Service is based on our legitimate interest, or, where required under applicable laws, based on your consent, and you will be entitled to withdraw your consent any time. Access to certain device settings is based on your consent, provided through your device permission (for example, access to audio files or microphone).

Depending on the nature of your interaction with the us, we may collect information as follows:

• Provided by you voluntarily – we will collect information if you choose to provide us with the information, such as through registration or contact us communications, etc. all as detailed in this Privacy Policy.
• Provided by our Partner – our Partners using our SpeakingPal App provide us with certain Personal Data regarding Partners’ User such as name, email address etc., to create users account and send the needed link to access and download SpeakingPal App. 
• Automatically – we may use cookies and certain tracking technologies such as pixels, tags, SDKs, etc. (as elaborated in the section below) to gather some information automatically such as online identifiers and usage data.

Similar to many other online services, we use cookies and similar technologies such as pixels, SDKs, etc., (ours or of our third-party service providers and partners) in our Website and SpeakingPal Apps for various purposes, including to operate, manage, maintain and secure our Websites, SpeakingPal App and Services, to improve your experience and for internal analytic purposes.

The categories and types of such technologies we use are, among others:  

Google Analytics – used for analytics and marketing purposes. 

React Native – used for development any analytics.

Google Firebase – used for security, debugging and analytics. 

Also note that certain their party cookies used for analytics marketing purposes (e.g., Google) may independently, as a data controller, collect and use certain Personal Data through our use of cookies, and combine it with other information obtained from your online activities on other digital assets, for the purpose of enhanced targeting functionality and delivering personalized ads. These third parties collect and use data under their own policies and are responsible for their practices. 

Managing Cookies and Opting Out: 

Other than cookies classified as essential or strictly necessary for functionality purposes, you can always configure your preferences and opt-out from use of certain or all cookies or tracking technologies at any time, through your browsers’ or device’s settings. In some cases, certain services, features and functionality may not be available to you or work properly if you disable cookies and similar technologies. 

We share your Personal Data with third parties, including our affiliated companies and subsidiaries, Partners and service providers that help us provide our Services. The categories of such third-party recipients are as follows.:  

• Sharing Data with our Partners - as explained above, if you are our Partner’s User, we will share your Personal Data with the Partner providing you with the services. The use of your Personal Data by the Partner is subject to its practices and policies, which may differ from ours, and we do not monitor, nor shall we bear any responsibility for the Partner’s practices, all are subject to the direct engagement between you and the Partner.
• Service Providers- we share your Personal Data with third parties that perform services on our behalf (e.g. storage and computing infrastructure, customer service, tracking, servers, service functionality, security, etc.). These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services. Note however that payment processors we use will process Personal Data subject to their practices aligned with applicable financial regulations.
• Affiliated Companies & Corporate Transaction - we may share Personal Data within our company group in accordance with the terms of this Privacy Policy for the purpose of providing the Services. We may further share your Personal Data in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation, or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy. 
• Legal Requirement, Enforcement and Defense - we will share your Personal Data in situations we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.). We may further share Personal Data, solely to the extent needed to enforce our policies and agreements; investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues; defend from legal claims you may have and establish or exercise our rights; or protect your or third parties’ vital interests, rights and safety. 

Subject to applicable laws, we retain the Personal Data we  collect for as long as needed for the purpose its was collected, as set forth under this Privacy Policy, where we are permitted under applicable laws to retain Personal Data, or, until you exercise your applicable rights (such as for data deletion, as detailed in the “Your Rights Under Privacy Protection Laws” paragraph below). 

We may retain Personal Data for additional periods, in the following circumstances: 

• Where we are required in accordance with our legal, regulatory, tax, or accounting requirements; 
• To maintain accurate records of your or the applicable engagement with us in the event of any complaints; or 
• If we reasonably believe there is a prospect of litigation relating to your Personal Data.

Except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

If you are a Partner’s User, your Personal Data will be retained by us in accordance with the Partner’s instructions and policies. 

We have implemented physical, technical, and administrative security measures for the SpeakingPal Apps and Services in accordance with applicable laws, to protect Personal Data from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.  

Note that, the transmission of information via the Internet and online data processing cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee, and we make no warranty that, we will always be able to prevent security incidents and will not be held responsible for unauthorized access or use beyond our reasonable control. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user's name and passwords, please make sure to respond appropriately to protect this information

Please contact us at: support@speakingpal.com, if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. Subject to applicable laws requirements, we will notify you and the appropriate authorities if we discover a security incident related to your Personal Data.

Due to our global business operation, your Personal Data may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different to the laws of your country. However, in all cases, we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer, in accordance with relevant and applicable law.

Specifically, if and where Personal Data collected within the UK or EU are transferred outside these territories to countries which were not granted with an adequacy, such transfer is subject to and made pursuant with an approved transfer mechanism such as the Standard Contractual Clauses or data privacy framework. 

Under applicable privacy protection laws, individuals have certain rights and controls regarding their Personal Data we process and maintain. Depending on your relationship with us, your jurisdiction and the privacy laws that apply to the processing of your Personal Data, the principal rights might include:  

• Right to be informed – you have the right to be provided with information regarding our Personal Data collection and privacy practices. All is detailed under this Privacy Policy. If you have any additional questions, please contact us at: privacy@SpeakingPal.com
• Right to access/inspect your Personal Data - you have the right to ask us to confirm whether or not we collect and use your Personal Data, and if so, you have the right to know which Personal Data we specifically hold about you ask for a copy of your Personal Data or access it;
• Right to correct/rectify your Personal Data - you have the right to ask us to correct or update any of your Personal Data that is incorrect, after verifying the accuracy of the data first, taking into account the nature of the processing and the purposes (or request deletion for inaccurate Personal Data).  
• Right to erase your Personal Data (the right “to be forgotten”) - you have the right to request the erasure of certain Personal Data, if specific conditions are satisfied, for example, if you think  we no longer need to use it for the purpose we collected it from you, in case the process of your Personal Data was based on your consent, where we have used it unlawfully, or where we are subject to a legal obligation to erase  your Personal Data. any request for such erasure will be subject to our rights and obligations under applicable law (e.g., legitimate interests such as record keeping with regards to our engagements, completing transactions, providing a good or service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, fulfilling the terms of a written warranty, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities; debugging products to identify and repair errors that impair existing intended functionality; exercising right provided for by law; engaging in public or peer-reviewed scientific, historical, or statistical research in the public interest, etc.). You are not required to create an account with us to submit a deletion request;
• Right to restrict our processing of your Personal Data - you have the right to ask us to restrict or limit the purpose for which we process your  Personal Data in certain circumstances and where certain conditions are satisfied (such as where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data; where the processing is unlawful and you oppose the erasure of the Personal Data; where we no longer need the Personal Data for the purposes of the processing).;  
• Right to object to how we use your Personal Data - you can object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information; 
• Right to withdraw consent/opt-out - when the lawful basis for processing your Personal Data is your consent, you may withdraw such consent at any time or opt-out from other data collection based on permissions. We do not profile you in a manner that has a significant effect on you or other individuals, therefore there isn’t an opt-out option.
• Data portability right - you have the right to ask us to provide a copy of your Personal Data in a portable format and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Data to another entity without hindrance. We will select the format in which we provide your copy;  
• Right to appeal or lodge a complaint - If we decline to take action on your request, we will inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the GDPR you have the right to lodge a complaint with the applicable Data Protection Authority in the EU or the Information Commissioner in the UK. 

Note that, not all those rights apply in every jurisdiction. 

For US Residents, please further review the “Additional Notice for US Residents” paragraph below - to learn more about your rights under applicable US law.

You may exercise any or all of your above rights in relation to your Personal Data contacting us at: privacy@SpeakingPal.com

We will respond and fulfill your request within the timeframe required under applicable laws. 

Certain rights can be easily executed independently by you without the need to contact us, and for example: 

• If you are a SpeakingPal App’ user, you can exercise your right to request account and data deletion through the SpeakingPal App menu; 
• You can opt-out from in-app permission through your account settings. 

Our App, Services, and Website are not available, offered or intended for use by children, as defined under applicable laws. If you are a SpeakingPal App Individual User under the age of consent as defined by applicable law or majority, you may create an account with us only by or with the approval of a parent or legal guardian. If you are using SpeakingPal App and Services as a Partner User (i.e., under a Partner’s designated account), it is the responsibility of the Partner to obtain any required parental or legal guardian consent for your use of the SpeakingPal App and Services and the collection and processing of your Personal Data. Please contact us if you have reason to believe that a child has shared Personal Data with us without the necessary consent or not in accordance with the above.

Our Website and Services may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-parties’ practices and are not responsible for their privacy statements.

Residents of certain U.S. states (depending on the applicable state law, acting in an individual or household context and not in a commercial or employment context or as a representative of business), may have additional rights under applicable privacy laws and be entitled to additional disclosures. 

"Personal Data" or “Personal Information” under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope, such as: HIPAA, GBPA, non-profit entities, etc.)

“Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal Data collected from a known child; Precise geolocation data. 

We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.

Categories of Personal Data & Categories of third parties with whom Personal Data is shared: 

Under the paragraph “Data We Collect and Purpose of Collection and Use” of this Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collecting and processing, and the purposes for which Personal Data is processed, stored or used. 

Additionally, under the paragraph “Sharing Data with Third Parties” of this Privacy Policy, we detail and disclose the categories of third parties we share Personal Data with for business purposes. We will not collect additional categories of Personal Data or use the Personal Data we collected for a materially different, unrelated, or incompatible purpose without obtaining your consent. 

“Sale” of Personal Data:

Under US privacy laws, in principle, the term “sale” is referring to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment however, subject to the definition of the term “Sale” under US privacy laws, we may “sell” the following categories of Personal Data when we use cookies or other third-party advertising services: 

Identifiers – online identifiers such as IP and Cookie ID; 

Internet and electronic network activity information – such as your engagement with our Website. 

Geolocation data - derived from IP (country level).

Consumer Rights:

Residents of certain U.S. states, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:

• Access - the right to confirm whether we are processing their Personal Data and to obtain a copy of their Personal Data in a portable and, to the extent technically feasible, readily usable format.
• Delete - the right to delete their Personal Data provided to or obtained by us.
• Correct - the right to correct inaccuracies in their Personal Data, taking into account the nature and purposes of the processing of the Personal Data.
• Opt-Out - to opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Data; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Data for purposes of making decisions that produce legal or similarly significant effects.

The paragraph “Your Rights Under Privacy Protection Laws” provides additional information regarding your principal rights. 

Exercising Your Privacy Rights: 

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by contacting us at: privacy@SpeakingPal.com. 

When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

Authorized agents may initiate a request on behalf of another individual by contacting us at privacy@SpeakingPal.com; authorized agents will be required to provide proof of their authorization, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.   

If we decline to take action on your request, we will inform you without undue delay, within the timeframe set out under applicable law. Our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your jurisdiction.