1. Who we are
Lingua Clara is a service of [COMPANY LEGAL NAME], [ADDRESS], [COUNTRY] ("Lingua Clara", "we", "us"). We are the controller of your personal data.
If you have a question about privacy, send an email to [PRIVACY EMAIL]. [IF APPLICABLE: You can also contact our data protection officer at [DPO EMAIL].]
2. Data that we collect
We collect only the data that we need to give you our service.
- Waitlist data: your email address and the languages that you select.
- Account data: your name, email address, password (we keep only an encrypted hash) and the languages that you learn.
- Contact form data: your name, email address, the topic and your message. If you write to us from the page for creators, also the link to your channel.
- Usage data: the videos that you watch, the time that you watch, your level and your progress.
- Payment data: your plan and your billing history. Our payment provider, [PAYMENT PROVIDER], processes your card data. We do not keep full card numbers.
- Technical data: IP address, device type, browser, operating system, language settings and log data.
3. How we use your data
- To give you access to the videos and to your account.
- To count your hours and show your progress on the roadmap.
- To tell you when Lingua Clara opens, if you joined the waitlist.
- To reply to your messages.
- To process payments and to send invoices.
- To make the service better, with statistics that do not identify you.
- To keep the service safe and to stop fraud and abuse.
- To obey the law, for example tax law.
- To send you news and offers, but only if you agree. You can unsubscribe at any time.
4. Legal bases
Under the General Data Protection Regulation (GDPR), we use these legal bases:
- Contract (Art. 6(1)(b) GDPR): to give you the service that you asked for.
- Consent (Art. 6(1)(a) GDPR): for the waitlist, news emails and analytics cookies. You can withdraw your consent at any time.
- Legitimate interests (Art. 6(1)(f) GDPR): to keep the service safe and to make it better.
- Legal obligation (Art. 6(1)(c) GDPR): to keep records that the law requires.
7. International transfers
Some service providers are outside the European Economic Area (EEA). In that case, we use legal safeguards, for example the Standard Contractual Clauses of the European Commission. You can ask us for a copy.
8. How long we keep data
- Waitlist data: until the launch plus [PERIOD], or until you unsubscribe.
- Account and usage data: while your account is open. We delete it [PERIOD] after you close your account.
- Contact messages: [PERIOD] after we reply.
- Payment records: as long as tax law requires ([PERIOD]).
9. Your rights
You have these rights:
- Get a copy of your personal data (right of access).
- Correct data that is wrong (right to rectification).
- Delete your data (right to erasure).
- Limit how we use your data (right to restriction).
- Get your data in a machine-readable format (right to data portability).
- Object to processing that uses legitimate interests (right to object).
- Withdraw your consent at any time.
- Make a complaint to a data protection authority, for example [SUPERVISORY AUTHORITY].
To use your rights, send an email to [PRIVACY EMAIL]. We reply within one month.
10. Children
Children under [MINIMUM AGE] must have permission from a parent or guardian to use Lingua Clara. If we find that we collected data from a child without this permission, we delete it.
11. Security
We protect your data with technical and organizational measures, for example encryption in transit (TLS), encrypted passwords and limited access for our staff. No system is fully safe. If a data breach occurs, we will tell you and the authorities as the law requires.
12. Changes to this policy
We can change this policy. The date at the top shows the last change. If a change is important, we tell you by email or with a notice on the website before the change applies.
13. Contact
[COMPANY LEGAL NAME]
[ADDRESS]
[COUNTRY]
Email: [PRIVACY EMAIL]