Privacy Policy

This Privacy Policy explains how Lngual collects, uses, shares, and protects personal information in connection with the Lngual mobile application and any related websites, features, content, and services (together, the "Services"). It applies to all users of the Services, on any device or platform.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use the Services.

1. Who We Are

The organisation responsible for your personal information is LNGUAL, 60 Paya Lebar Road, #6-28 Paya Lebar Square, Singapore 409051 ("Lngual", "we", "us", or "our").

You can reach us about any privacy matter, and contact our Data Protection Officer, at [email protected].

2. Information We Collect

2.1 Information You Provide to Us

• Account information: your email address and password, or the account details shared by a third-party sign-in provider, and the languages you speak and are learning together with your stated proficiency.
• Profile information: your name, date of birth, gender, country, profile photograph, background image, gallery images, biographical description, interests, and topics you select. You control whether your date of birth is displayed to other users.
• Photographs and images: images you choose from your device or capture for your profile, gallery, posts, or chats. Images are compressed on your device before upload.
• Voice messages: audio you record and send in chats. Recording only begins when you start it, and the microphone is not accessed at any other time.
• Content and contributions: posts, comments, replies, reactions, events you create or join, event group chat messages, gifts you send, and other materials you submit.
• Communications: direct messages exchanged with other users, and messages you send to us such as support enquiries or feedback.
• Reports and complaints: the content of reports you submit about other users or content.

2.2 Information We Collect Automatically

• Usage information: actions you take in the Services, content you view or interact with, features you use, session frequency and duration, learning progress, experience points, streaks, and achievements.
• Device information: device model, operating system and version, application version, mobile network information, device and installation identifiers, screen resolution, language, and time zone.
• Log and diagnostic information: application logs, crash reports, performance data, and error reports.
• Location information: when you use map or nearby-event features and grant permission, we request your device location at approximately city or district level of accuracy. We do not track your location in the background and we do not store a location history. Location is also derived from information you enter, such as the address of an event you create.
• Purchase information: records of Lngual Plus subscriptions, coin purchases, and other in-app purchases, including purchase tokens, product identifiers, and subscription status. Payments are processed by the app store; we never receive your card or bank details.
• Advertising identifiers: the Google Advertising ID and similar identifiers used to deliver and measure advertising, subject to your device settings and to the choices in Section 6.
• Notification tokens: a push notification token issued by the messaging service so we can deliver notifications to your device.

2.3 Information from Third Parties

• Authentication providers: if you sign in with a third-party service, that provider may share your name, email address, profile photograph, and other identifying information in line with its own settings and policies.
• App stores: confirmation and status of purchases and subscriptions.
• Other users: information about you contained in reports, content, or communications they submit.

3. How We Use Your Information and Our Legal Bases

Where the EU or UK General Data Protection Regulation applies, we rely on the legal bases set out below. Where it does not, the "purpose" column still describes how we use your information.

Where we rely on consent, you may withdraw it at any time, in the app's Settings or through your device settings. Withdrawing consent does not affect processing carried out before the withdrawal.

4. Translation of Your Content

The Services include an on-demand translation feature. When you tap to translate a message, a post, or other content, the text of that content is sent from your device to a third-party translation service operated by Google in order to produce the translation. This includes the text of private messages when you choose to translate them.

Translation happens only when you request it. Translated results may be cached on your device so the same content does not need to be sent again. If you do not want content sent to the translation service, do not use the translation feature.

5. How We Share Your Information

We do not sell your personal information for money. We share it only as described below.

5.1 With Other Users

Information you make available through the Services, including your profile information, posts, comments, events, and other public contributions, is visible to other users. Direct messages are visible to the participants in that conversation. Event group chat messages are visible to the host and participants of that event. Consider carefully what you share.

5.2 With Service Providers

We use the following providers to operate the Services. They act on our instructions and are bound by confidentiality and security obligations.

5.3 For Legal, Regulatory, and Safety Reasons

We may access, preserve, or disclose information where we believe in good faith that it is necessary to comply with applicable law, regulation, legal process, or a governmental request; to enforce our terms; to detect, prevent, or address fraud, security, or technical issues; or to protect the rights, property, or safety of Lngual, our users, or the public.

5.4 In Connection with a Corporate Transaction

If we are involved in a merger, acquisition, restructuring, financing, sale of assets, or similar transaction, or in the event of insolvency, your information may be transferred as part of that transaction, subject to customary confidentiality protections.

5.5 With Your Consent or at Your Direction

We may share your information for any other purpose disclosed to you and with your consent, or at your direction.

5.6 Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information that does not identify you.

6. Advertising

The Services include advertising served through Google AdMob. Advertising partners receive limited information, including advertising identifiers, device information, and general usage information, in order to deliver and measure advertisements. Advertising in the Services is limited to content rated suitable for teen audiences.

If you are in the European Economic Area, the United Kingdom, or another jurisdiction where consent is required, we ask for your consent to the use of advertising identifiers and related processing when you first open the app. You may withdraw or change your consent at any time from in-app Settings.

You may also control advertising identifiers through your device settings:

• Android: Settings, then Privacy, then Ads, where you can delete or reset your advertising ID or opt out of personalized advertising;
• iOS: Settings, then Privacy & Security, then Tracking and Apple Advertising.

Disabling personalized advertising does not remove advertising from the Services; it limits the use of your information to personalize it. Subscribing to Lngual Plus removes advertising entirely.

7. Local Storage and Similar Technologies

The Services are provided primarily through a mobile application and do not use traditional browser cookies. We and our providers use device identifiers, software development kits, and on-device storage to keep you signed in, cache images and translations so they do not need to be downloaded repeatedly, remember your preferences, and analyze how the Services are used. Clearing the app's storage or uninstalling the app removes locally cached data from your device.

8. Data Retention

We keep personal information only as long as necessary for the purposes described in this Policy, unless a longer period is required or permitted by law. In particular:

• Account and profile information is retained while your account is active.
• Deleted accounts enter a 30-day grace period during which you can restore the account by signing in again. After 30 days, the account and its associated personal information are permanently deleted.
• Incomplete registrations that are never finished are removed within approximately 24 hours.
• Media shared in chats, including images and voice messages, is retained for up to 180 days and then removed from storage.
• Safety and moderation records, including records of reports and of accounts suspended or banned for policy violations, are retained for as long as needed to keep the Services safe and to meet legal obligations.

When determining other retention periods we consider the nature and sensitivity of the information, the purposes of processing, the risk of harm from unauthorized use or disclosure, and applicable legal, accounting, and reporting requirements. Aggregated or de-identified information that no longer identifies you may be kept indefinitely.

9. Security and Breach Notification

We implement administrative, technical, and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, loss, or destruction. These include encryption of data in transit, encryption at rest by our infrastructure providers, row-level access controls in our database, restricted administrative access, and periodic review of our practices.

No method of electronic transmission or storage is completely secure, so we cannot guarantee absolute security. Please use a strong, unique password and tell us promptly about any suspected unauthorized activity on your account.

If a personal data breach occurs, we will notify the competent supervisory authority and, where the breach is likely to result in significant harm or a high risk to your rights, affected users, within the deadlines set by applicable law.

10. Your Rights and Choices

At any time, within the Services, you can:

• Access and update most of your account and profile information;
• Adjust your privacy and visibility settings, including whether your date of birth is shown;
• Block or report other users;
• Manage notification preferences in the app or through your device settings;
• Revoke the location, microphone, photo, and notification permissions through your device settings;
• Delete individual posts, comments, images, and other content;
• Delete your account from in-app Settings, as described on our Account Deletion page.

Depending on where you live, you may also have the right to request access to, correction of, or deletion of your personal information; to object to or restrict certain processing; to withdraw consent; to request data portability; and to lodge a complaint with your data protection authority. To exercise any of these rights, contact us using the details in Section 19. We may need to verify your identity, will respond within the period required by applicable law, and may decline a request to the extent the law permits.

11. Additional Information for the EEA and the UK

If you are in the European Economic Area or the United Kingdom, the legal bases on which we rely are set out in Section 3. You have the rights described in Section 10, including the right to object to processing based on our legitimate interests, and the right to lodge a complaint with your national supervisory authority. Our identity and, where applicable, our representative's details are in Section 1. Information about transfers outside your region is in Section 16.

12. Additional Information for California

This section applies to California residents and uses the categories defined in the California Consumer Privacy Act, as amended.

We collect these categories from you, from your device, and from the third parties listed in Section 2.3, and we disclose them for business purposes to the providers listed in Section 5.2. Retention is described in Section 8.

We use sensitive personal information only to provide the Services you request and for the purposes permitted under section 1798.121(a) of the California Civil Code. We therefore do not offer a separate right to limit its use.

We do not sell personal information for money and we do not knowingly sell or share the personal information of consumers under 16 years of age. Advertising in the Services may be personalized using advertising identifiers, which may constitute "sharing" for cross-context behavioural advertising under California law. You can opt out at any time by resetting or deleting your advertising ID in your device settings, by turning off personalized advertising in your device settings, by contacting us at [email protected], or by subscribing to Lngual Plus, which removes advertising entirely.

California residents have the rights to know, delete, correct, and opt out described above, and the right not to receive discriminatory treatment for exercising them. You may use an authorized agent to submit a request on your behalf.

13. Additional Information for Singapore

We are established in Singapore, and the Personal Data Protection Act 2012 applies to our handling of personal data.

Under that Act you may withdraw consent to our collection, use, or disclosure of your personal data, request access to personal data we hold about you and information about how it has been used or disclosed in the past year, and request correction of an error or omission. Send any such request to our Data Protection Officer at [email protected]. We will respond within the timeframes set by the Act, and we will tell you if a request cannot be met in full and why. Withdrawing consent may mean we can no longer provide parts of the Services to you.

Where a data breach is assessed to be notifiable, we notify the Personal Data Protection Commission as soon as practicable and in any case within 3 calendar days of that assessment, and we notify affected individuals as required by the Act.

If you are not satisfied with how we have handled your personal data, you may lodge a complaint with the Personal Data Protection Commission of Singapore.

14. Automated Processing, Ranking, and Moderation

We use automated systems to order and recommend content, such as which profiles appear in Discover and which posts and events are shown to you. These systems use information such as the languages you speak and are learning, your country, your activity in the app, and whether a post has been boosted.

We also use automated checks together with human review to detect spam, abuse, and content that breaks our rules. Decisions that meaningfully affect your account, such as suspension or removal of content, are subject to human review, and you may contest them by contacting [email protected]. We do not make decisions producing legal effects concerning you based solely on automated processing.

15. Minimum Age

You must be at least 16 years old to create an account. The Services are not directed at children, we do not knowingly collect personal information from anyone under 16, and registration is refused where the date of birth provided indicates an age under 16.

If we learn that we have collected personal information from someone under the minimum age, we will take reasonable steps to delete it. A parent or legal guardian who believes a child has provided personal information through the Services may contact [email protected] to request review and deletion.

16. International Data Transfers

We operate using infrastructure that may be located outside your country, and your information may be transferred to, stored in, and processed in other jurisdictions, Singapore, where our database and file storage are hosted. Some of our providers, including those listed in Section 5.2, process information in other countries such as the United States. The data protection laws of those countries may differ from those of your own. Where required, we rely on lawful transfer mechanisms, including the European Commission's standard contractual clauses, the UK international data transfer agreement, and contractual measures requiring a standard of protection comparable to the Singapore Personal Data Protection Act 2012, to safeguard those transfers.

17. Third-Party Links and Services

The Services may link to, or interact with, websites, applications, and services operated by third parties. We are not responsible for their privacy practices or content, and this Policy does not apply to information they collect. Review their policies before providing information to them.

18. Changes to This Privacy Policy

We may revise this Privacy Policy to reflect changes in our practices, the Services, or applicable law. When we do, we will update the "Effective" date above. If the changes are material, we will give reasonable notice through the Services or by other appropriate means before they take effect. Please review this page from time to time.

19. Contact Us

For questions, comments, or concerns about this Privacy Policy or our handling of personal information, or to exercise any of your rights, contact our Data Protection Officer at [email protected], or write to us at LNGUAL, 60 Paya Lebar Road, #6-28 Paya Lebar Square, Singapore 409051.