Last updated October 1, 2020
WHAT WE COLLECT
We get information about you in a range of ways.
- Information You Give Us. We collect information you directly give us, such as your voice recording when you engage with our intelligent pronunciation coach through the App (“Voice Recordings”), and your name, email address, phone number, password, login credentials to your social network accounts, and demographic information. Please note that we only record Voice Recordings when you engage with our intelligent pronunciation coach through the App – we do not access the microphone of your device at any other time.
- Information That Is Aggregated. “Aggregate data” are data we collect about a group or category of features, services or individuals, from which individual identities have been removed. For example, information about how you use a feature may be collected and combined with information about how others use the same feature, without any personal information included in the resulting data.
- Information We Get from Others. We may get information about you from other sources. We may add this to information we get from the Service. We allow you to access third party services, such as Facebook and Twitter, to import information about who you are connected with on those other services so you can connect with them on the Service. Some of those third party services may also provide us with information from your accounts there to enhance and personalize your use of the Service; you may modify your privacy settings with those other services directly.
- Information Automatically Collected. We automatically log information about you and your computer. For example, when you visit ELSA, we log your computer operating system type, browser type, browser language, pages you viewed, how long you spent on a page, access times, Internet protocol (IP) address, and information about your use of and actions on ELSA. We also collect (a) information stored in your phone, such as advertiser ID, phone brand and model, and default language, (b) your login information (either through email or Facebook), and (c) your approximate location (via IP address).
- Public Content. You can contribute to the Service in a number of different ways that are intended to be viewed by other users, including writing reviews, uploading videos and photos, participating in forums, tagging products, filling out your public profile, and voting on other users’ contributions. We may store these contributions (your “Public Content”), display them to other users, and use them for promotional purposes. Note that if you include personally identifiable information in your Public Content, it can be used and viewed by others. We are not responsible for the information you choose to include in your Public Content.
HOW WE USE PERSONAL INFORMATION
We use your personal information for the following purposes:
- To operate, maintain, and improve our sites, products, and services.
- To analyze your usage of the App for the purpose of improving our App, including analyzing Voice Recordings to improve our intelligent pronunciation coach.
- To find and connect with your friends (when instructed by you).
- To provide custom, personalized advertisements, content, and information.
- To let your friends know about your activity on ELSA.
- To monitor and analyze usage and trends, and to personalize and improve ELSA and your experiences when you use ELSA.
- To respond to comments and questions and provide customer service.
- To send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
- To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
- To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners. The legal bases for our processing of your personal information are (a) our obtaining your consent for the processing of your personal information for the foregoing purposes, and (b) the fact that such processing is necessary for us to render the Service. We retain your personal information to provide the Service to you and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; otherwise, we will delete your personal information immediately after you terminate your account.
SHARING OF PERSONAL INFORMATION
In certain circumstances we may share your personal information with third parties without further notice to you, unless required by the law, as set forth below:
- With your friends on ELSA, according to the preferences set in your account.
- With companies who may offer you products and services. You may opt out of this sharing by contacting us via the channel listed in the “Contact Information” below.
- With certain social networking services, if you allow such sharing through our services.
- With your consent. For example, you may let us share personal information with third parties for their own marketing uses. Those uses will be subject to the privacy policies of such third parties.
- With those who provide services to ELSA, such as sending ELSA email communications, analyzing usage logs and Voice Recordings to improve our intelligent pronunciation coach, and managing ELSA marketing campaigns.
- With educational institutions and other third parties for research purposes.
- In order to help provide the Service at no cost to you, we may sell or license to third parties Voice Recordings that have been stripped of information that could identify you directly (such as your name and contact information).
- For legal, protection, and safety purposes:
- To comply with laws.
- To respond to lawful requests and legal processes.
- In an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
- If and when we negotiate a transaction involving the sale or transfer of all or a part of our business or assets. These transactions can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- If you post Public Content on the Site or the App, we may distribute such Public Content to a wider audience by sharing it (or portions of it) with third parties so that they can publish it on their own websites and media platforms. We allow you to access third party services, such as Facebook and Twitter, to share your selected Public Content with those services.
We may share aggregate data with interested third parties to assist them in conducting research, developing new products, and understanding the interest and usage patterns for certain information, products, services, data, content, services, advertisements, promotions, and/or functionality on the Service.
RETENTION OF PERSONAL INFORMATION
We will retain your personal information for as long as your account is active, and as long as is reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
YOUR PRIVACY RIGHTS AND CHOICES
You have certain rights and may make certain choices regarding our processing of your personal information:
- You may request access to, correction of, or erasure of your personal information by going to https://partner.elsaspeak.com.
- You may request that we restrict processing of your personal information or object to our processing of your personal information by contacting our Data Protection Officer, in which case you will no longer be able to have an account with ELSA.
- You may request that (a) we provide you with your personal information in a structure, commonly used and machine-readable format, and (b) we transmit your personal information to a third party, by going to https://partner.elsaspeak.com. This is referred to as “Data Portability.”
- You may withdraw your consent at any time by deleting your account with us.
- If you reside in the EEA, you have the right to lodge a complaint with the supervisory authority of your member state. For a list of supervisory authorities, please see http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
- You are not obligated to provide any personal information, but (a) if you do not provide your email address, we will not be able to communicate with you, and (b) if you do not provide us with voice recordings, we will not be able to provide you feedback regarding your pronunciation.
- Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
- You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.
- You can typically remove and reject cookies from our Service with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Service works for you.
ADVERTISING AND REMARKETING
LINKS TO OTHER SITES
Consistent with the federal Children's Online Privacy Protection Act of 1998 (COPPA), we do not knowingly collect personally identifiable information from anyone under the age of thirteen (13) without parental consent. Any person who provides their personal information to us through the Site represents that they are 13 years of age or older. We ask for and store users’ date of birth to ensure they are 13 or older, but do not share that information unless the user chooses to share it on the user’s profile. If you believe that we have collected information from an individual under the age of 13, please contact us so that we may take appropriate steps to address the issue.
SECURITY OF YOUR PERSONAL INFORMATION
We take steps to help protect personal information. No company can fully prevent security risks, however. Mistakes may happen. Bad actors may defeat even the best safeguards.
TRANSFER OF PERSONAL INFORMATION TO THE UNITED STATES OR OTHER COUNTRIES
Your personal information will be transferred to, and stored and processed in, the United States, and may in the future be transferred to, and stored and processed in, other countries. All transfers will either (a) be under the European Commission’s model contracts for the transfer of personal information to third countries, or (b) rely on the EU-US Privacy Shield framework.
CONTACT INFORMATION / DATA PROTECTION OFFICER