Last updated October 1, 2020
“Company”) collect, use and share personal information of users of the ELSA mobile application (“ELSA” or
the “App”), this website (the “Site”) and other services provided by the Company (the App, the Site, and
such services shall be collectively referred to as the “Service”). This Policy also applies to any of our
other mobile applications or websites that post this Policy. This Policy does not apply to websites that
post different statements.
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
- 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).
- Cookies. We may log information using "cookies" for the sole purpose of improving our Service.Cookies
are small data files stored on your hard drive by a website. Cookies help us make our Service and your
to our Service.
- 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
- With educational institutions and other third parties for research purposes.
- 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
- 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
- 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
We may allow other companies, called third party ad servers or ad networks, to serve advertisements within
the Site or the App. These third party ad servers or ad networks use technology to send, directly to your
browser, the advertisements and links that appear on the Site. They automatically receive your IP Address
measure the effectiveness of their advertisements and to personalize their advertising content. Further,
these advertisers may also serve ads to you on other websites (including ads for our products and services)
based on information collected from you while using the Site. For example, we may use Google’s “remarketing”
service to target our ads to you based on your prior use of the Site or the App when you visit on other
sites in Google’s content network.
You should be aware that advertisers may target advertisements to users based on certain user
characteristics. If you respond to this type of targeted advertisement, the advertiser or ad server may
apply to, and we cannot control the activities of, such ad servers, ad networks, or their advertiser
LINKS TO OTHER SITES
The Site may contain links or references to external websites. These are provided for your convenience only,
and we do not have control over the privacy or security practices and policies of third party sites. Any
personal information you provide on linked pages is provided directly to that third party and is subject to
external websites before providing them with personal information.
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
our Data Protection Officer at the following email address: [email protected]
disclosure of personal information that you have provided to us, the new policy will not apply to
information collected prior to the change unless we obtain your consent. We encourage you to periodically