Transparent Language, Inc. Privacy Policy

This Privacy Policy sets out how Transparent Language, Inc. ("Transparent") uses and protects any information that you give to Transparent when you use Transparent Language Online (the "Application").

Transparent is committed to protecting your privacy. Should our Application ask you to provide any information by which you can be identified, you may be assured that that information will only be used in accordance with this Privacy Policy.

This Privacy Policy covers any use of the Application. Note, however, that the Application may contain links to other websites of interest. As we have no control over such sites, they are not governed by this Privacy Policy and we cannot be responsible for the protection and privacy of any information which you provide to them.

This Privacy Policy is effective May 1, 2018. We reserve the right to change this Privacy Policy from time to time to ensure that it complies with current legal requirements or to implement changes to our services. Should the Policy change, you will be notified within the Application so you can confirm that you have no objections to the changes.

Information Collection

Transparent may collect the following personal information directly or through our order processing agents:

• Username
• Password
• First and last name
• Email address
• Phone number
• Address information
• Country of origin
• Organization name, if applicable
• Age range (15 and younger or 16 and older), as required to comply with regulations
• IP address
• Category of user (personal learner, educator, librarian, company representative, etc.), if you provide such information
• Any answers you provide if you voluntarily choose to participate in customer surveys
• Any additional contact information (such as Skype name, cell phone, fax, etc.) that you voluntarily choose to provide if you interact with Transparent employees, including tutors, instructors, and technical support

The Application also collects the following information related to your usage of the program:

• Native language(s) selected
• Language(s) being learned
• Learning history and other lesson and course interaction

In addition, the following technical information may be collected in an anonymized format, not linked directly to your account:

• Browser type and version used to access the Application
• Operating system used to access the Application
• Referrer URL / Previously visited page

Information Usage

Transparent requires the information we gather to generally understand your needs and to provide you with better service, and in particular for the following reasons:

• To customize your experience with the Application according to your interests
• To enable internal record keeping and reporting
• To improve our products and services
• To periodically send promotional emails about new products, special offers, or other information which we think you may find interesting
• To contact you from time to time for market research purposes

Information Security

Transparent is committed to ensuring that your information is secure. To prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

We also adhere to the principles of purpose limitation and data minimization. Therefore, we only store your personal data for as long as it is necessary to achieve the purposes mentioned here or as long as the storage periods required by law. After discontinuation of the respective purpose or expiry of these deadlines, the corresponding data will be blocked or deleted in accordance with the statutory provisions. Our legal basis for the deletion or blocking of personal data is Art. 5 (1) b) GDPR and Art. 5 (1) c) GDPR.

You have the right to complain about any improper processing of your personal data (such as collection, storage, modification, transfer, deletion, etc.) by us to the proper authorities.

Information Control

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), and to request the deletion or restriction of your information. Transparent will respond to requests about these matters within a reasonable timeframe.

• Accessing, updating, and downloading your information: The User Profile section of the Application gives you the ability to access and update certain information about yourself from within the Application. It also allows you to download a copy of the information that Transparent Language Online stores about you in an electronic file.
• Opting out of communications: You may opt out of receiving communications from us by using the unsubscribe link within each email, by updating your email preferences within the Application, or by contacting Transparent at info@transparent.com.
• Accepting or declining cookies: Cookies are small files which can be placed on your computer's hard drive to allow web applications to respond to you as an individual. With cookies, web applications can tailor their operations to your needs, likes, and dislikes by gathering and remembering information about your preferences. Within the Application, we use traffic log cookies to identify which pages are being used. We only use this information for statistical analysis purposes, then remove the data from our system. The cookies in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Most web browsers automatically accept cookies, but you can change your browser setting to decline cookies if you prefer. Please be aware that if you choose to decline cookies, some or all of the Application may be inaccessible or non-functional.
• Requesting that we forget you: If you no longer wish to use the Application and do not want Transparent to continue storing information about you, you may have your account forgotten by clicking the "Forget Me" link in the User Profile section of the Application and following the instructions on the screen. When we receive such a request, we will retain your user data for 30 days. If you change your mind during this period, you can stop the process of being forgotten by logging into your account. If you haven't logged in within 30 days, your account and all your learning progress will be permanently forgotten. At that point, the action cannot be undone.

Information Sharing

Transparent will not sell, distribute, or lease your personal information to third parties unless we have your permission or are required by law to do so. However, we may use the following sales and marketing products for web analytics, social media marketing, and other services:

• AirTable: AirTable is an online tool that acts like both a spreadsheet and a database. We may use AirTable to keep track of how many live instruction sessions our Transparent Language Connect students have used, how many they have left, and what was covered in each session. Only Transparent's tutors and administrators have access to the information in the databases, which may include student names and email addresses (in order to allow our tutors to identify their students). AirTable is a U.S. company that uses servers in the United States.
• Amazon Web Services (AWS): We may use AWS to host content, send emails and notifications, maintain access logs, and provide support within Transparent authoring tools. AWS encrypts data at rest and uses secret keys to control who can access various data points.
• Appcues: We may use Appcues in the Application to help introduce users to new features and to help new users setup their account. Appcues is a U.S. company based in Boston, Massachusetts.
• BlueSnap: BlueSnap processes Transparent's payment transactions. Transparent also uses a cart hosted by BlueSnap servers to gather customer payment info at purchase time, which means Transparent never has access to that info. After a transaction has taken place between BlueSnap and a Transparent customer, Transparent may view transaction information such as date, customer email, customer name, customer address, amount, payment method, and product purchased, but not payment info. BlueSnap is a U.S. company.
• CloudAMQP: We may use CloudAMQP to host an instance of RabbitMQ, which is used to send data to Transparent servers for processing. Information is not stored by CloudAMQP and is encrypted in transit.
• FastSpring: FastSpring processes Transparent's payment transactions. Transparent also uses a cart hosted by FastSpring servers to gather customer payment info at time of purchase, which means Transparent never has access to that info. After a transaction has taken place between FastSpring and a Transparent customer, Transparent may view transaction information such as date, customer email, customer name, amount, payment method, and product purchased, but not payment info. FastSpring is a U.S. company.
• FeedBlitz: We may use FeedBlitz to send emails to voluntary subscribers to our blogs, Word of the Day, and Phrase of the Day services. FeedBlitz is a U.S. company.
• Google AdWords: If you reach our website via an advertisement sent by Google, Google AdWords sets a cookie on your computer. These cookies lose their validity after 30 days and are not used for personal identification. If you visit certain pages on our website and the cookie has not expired, we and Google may recognize that you clicked on the ad and were redirected to this page. Google is a U.S. company that uses servers in the United States.
• Google Marketing Platform: Google Marketing Platform is a suite of products by Google Inc. that includes Analytics, Optimize, and Tag Manager, all of which may be used by Transparent to anonymously collect usage data and test user preferences in the Application. Google is a U.S. company that uses servers in the United States.
• Google Analytics uses its own cookies to anonymously evaluate Application usage and compile Application activity reports.
• Google Optimize allows Transparent to anonymously test variants of the user interface in order to improve the Application over time.
• Google Tag Manager collects no information directly, but rather allows Transparent to easily deploy changes to scripts and other aspects of the Application in real time, without interrupting service.
• HotJar: We may use HotJar to gather anonymous data about how users interact with the Application. Over time, we may analyze that data to improve the Application's usability and determine the most used features. From a single visitor session, HotJar may create a heatmap; visually recreate the session by replaying mouse movements, page scrolls, and click coordinates; evaluate the user's progress through various steps; and note which fields of a form a user filled out before abandoning it. Visual recreations of sessions will not include sensitive or personal information entered by the user. HotJar attempts to distinguish users by using their IP addresses as identifiers. HotJar also uses cookies to distinguish new users from returning ones to avoid redundant behaviors. HotJar is a U.S. company.
• HubSpot: HubSpot tracks, documents, and manages many interactions on our websites to help us assess the effectiveness of our sales and marketing strategy, in addition to assisting with our technical support case management and knowledge base. HubSpot programs access data collected on our websites from services such as Google AdWords and compile reports that provide information about the demand for our products and our clientele. HubSpot also uses cookies to track website visitors in real time and recognize potential customers among them. Finally, HubSpot email tracking provides a notification when a customer opens an email sent by us and clicks on the link to our offers. We can then respond to the customer with a personal email or an automated answer. HubSpot is a U.S. company that uses servers in the United States, and has signed a data processing agreement with us to keep our data safe.
• HubSpot LiveChat: HubSpot LiveChat is built into our websites to let our users communicate with Transparent employees. HubSpot LiveChat collects access data such as IP address, browser, and operating system type as well as the dial-in location from users of the live chat. In addition, cookies are used to collect further data about user behavior. HubSpot has represented to us that it processes this information solely to improve its own services. HubSpot stores and processes all collected data on servers located in the United States.
• Parlor: With Parlor, we can give certain users previews of upcoming product features and collect their feedback. We then use that information to improve the product. Parlor may appear as a widget in the corner of the Application. Parlor collects user email addresses so it can contact users who have submitted feedback through the widget. Parlor is a U.S. company that uses servers in the United States.
• ScheduleOnce: Our live tutoring sessions are booked and managed through ScheduleOnce, a service owned and operated by OnceHub. Through ScheduleOnce, users can book tutoring sessions with Transparent's tutors. A user is asked to share their name (so tutors can distinguish them from other students) and an email address (so ScheduleOnce can send automated emails related to bookings and tutors can contact them with relevant questions or support). Tutors may also keep session notes in ScheduleOnce. Users cannot see each other's information. OnceHub is a U.S. company that uses servers in the United States.
• SurveyMonkey: SurveyMonkey lets Transparent create surveys that users of the Application may choose to participate in. We may use these surveys to collect user opinions and feedback that helps us improve our products and websites. Surveys are anonymous but may allow users to submit questions along with their email address. SurveyMonkey attempts to distinguish users by using their IP addresses as identifiers. SurveyMonkey is a U.S. company.
• TypeForm: We may use TypeForm to create data input forms that allow users to submit technical support cases and other customer service requests. TypeForm is a Barcelona-based online Software as a Service (SaaS) company that specializes in online form building and online surveys.
• WebPurify: We may use WebPurify by WebFurther, LLC in the Application to ensure that usernames don't contain offensive language. WebFurther, LLC is a U.S. company based in Irvine, California.
• WordPress: We may use WordPress to power our blogs, which may be accessible through the Application. WordPress may collect the name, email address, and IP address of users who voluntarily choose to comment on our blog articles. WordPress is a U.S. company.

Our legal basis for the use of these third-party products is provisions 6 (1) b) and 6 (1) f) of GDPR.