Privacy Policy

This statement details how we handle personal data here at GledLingvo. We are respectful of the data that is shared with us by our members and take protecting it very seriously.

GledLingvo is made in Cyprus and as a company based in the European Union we are firmly committed to meeting and often exceeding European data protection standards for all our members wherever possible.

Please take the time to read these details to fully understand how we handle your data and keep it safe.

Contact
ABRUE TRADING LIMITED
Kennedy 12, Kennedy Business Centre, 2nd floor, 1087, Nicosia, Cyprus
You can reach out to us directly via support@GledLingvo.com.
Personal Data
Personal data refers to any information about personal or factual circumstances of an identified or identifiable person. This includes information and details such as your name, age, gender, mobile device identifiers, telephone number and also your email address.
Legal Basis
Your data is handled according to the following legal provisions:

With regard to data communicated in forms, etc. with your consent, Art. 6(1) (a) GDPR;
With regard to services you use for the performance of a contract, Art. 6(1) (b) GDPR;
Otherwise, with particular regard to statistical data and online identifiers based on legitimate interests, Art 6(1)(f) GDPR (see below).
Legitimate Interests
When handling your data, we pursue the following legitimate interests:

Improving our service;
Protecting against misuse;
Statistics and service analytics.
Data Sources
Unless otherwise specified, we obtain the data from you (including via devices used by you).
Data Transfer to Third Countries
GledLingvo is a worldwide service. Data is transferred to third countries outside your home country and outside the European Union. This is done on the basis of contractual regulations stipulated by law that ensure appropriate protection of your data and that are available for you to view on request.
Retention Period
We retain your data:

If you have consented to this as part of processing, until such time as you withdraw your consent (e.g. asking us to delete your account, indicating the reason for the deletion);
If we need the data to fulfil an agreement, until such time as the contractual relationship with you ceases or legal retention periods expire;
If we use the data on the basis of a legitimate interest, until such time as your overriding interest obliges us to delete or anonymize them.
Purposes of Use
Personal data will only be collected by us to the extent and for the purpose for which you provide the data to us, e.g. for registering an account.
We use and store your personal data as part of our services for the following purposes and only if you have provided us with your express consent:

To create a public user profile for you on GledLingvo;
To provide a curated community just for language learners, where access is restricted to members only. We take best efforts to prevent abuse and ban offenders, as soon as we are made aware;
To send information relevant to the service, e.g. via email or push notification (e.g. updates on your membership status, missed calls/messages, new followers);
To target ads in the app (this can be turned off in settings);
To find GledLingvo partners nearby;
To understand how GledLingvo is used and optimize the service
We use your personal information only within the company and forward it only to those companies that are involved in performing the contracts concluded with you or otherwise involved in providing the relevant service.
Otherwise, your personal information will not be forwarded to third parties unless you have given your express consent for this or unless we are obliged to disclose it – for example, at the direction of a court or administrative authority.
We forward the following customer data to third parties:

To analyze how GledLingvo is used by our members and optimize the service and design, anonymous usage and personal data is shared with Google Analytics, Firebase Analytics, New Relic, Facebook Analytics and Rubylight Limited.
To communicate information relevant to the service via email or push notification, names, device IDs, email addresses and other personal information may be shared with OVH (OVH SAS).You can control what type of messages you receive in the profile settings, switch off push notifications for GledLingvo completely in your device settings and unsubscribe from email notifications in each individual email.
To make ads more personal, we may share personal but anonymized information, such as age and gender as well as device identifiers with MoPub, InMobi, MyTarget, Admob by Google, Facebook Audience Network, Ad Xchange and Fyber. iOS and Android devices have a resettable advertising identifier that companies can use to target ads based on the apps you use.
Both iOS and Android devices allow you to opt out of the use of mobile advertising identifiers for purposes of showing you targeted ads. For iOS, go to your iOS device settings and turn on the “limit ad tracking” setting. For Android, turn on “opt out of ads personalization” in your Android device settings.
We create GledLingvo member profiles based on your login data and also use these profiles and the information they contain, provided by you, for the following purposes:

We create a public member profile for you on GledLingvo so that members can find the most relevant language exchange partners to communicate with. While some elements of your profile, including your first name, age, profile picture, language settings, profile answers, current city, time zone and Topics are public, only community members can contact you via the GledLingvo app. We never show your email address, exact location, last name or any information you have chosen not to share in your profile settings to other members.
In order to keep GledLingvo a safe place for language learners, we take violations of our community rules very seriously. Therefore, we retain anonymous personal identities of banned users for 18 months and might prevent access to the community on this basis during this period.
To control target group-related advertising, we record information about activities on our apps and websites (e.g. advertising banners clicked, screens viewed, and pages visited, etc.) This is recorded under a pseudonym and we may use this to provide our customers’ users with advertising targeted to their interests.
For this purpose, a cookie may be stored on your device. Cookies are small text files that are stored on your computer’s hard drive. They enable recognition of your computer but do not permit you to be personally identified.
If you do not want cookies to be installed, you can opt out using your browser settings. On mobile devices you can opt out of sharing advertising identifiers.
You can edit, hide and delete personal data in the My Profile settings within the GledLingvo app. Also, you can request the deletion of your account or ask for certain profile information to be changed via GledLingvo’s customer support (support@GledLingvo.com).
Data Protection
We have taken extensive technical and organizational measures to secure your data against potential risks, such as unauthorized login or access, unauthorized perusal, amendment or distribution, and against loss, deletion or misuse.
In order to protect your personal data against unauthorized access by third parties when being transmitted, we secure data transmissions, if necessary, using SSL and TLS encryption. This is a standard encryption procedure for online and mobile services, particularly for the Internet. Encryption is not supported in China.
Regarding video and audio chats: we will not monitor, record or broadcast video and audio chat sessions at any time. However, we cannot prevent your chat partners from broadcasting live or recorded chat sessions without your or our permission through third party websites or services. We recommend that you exercise caution in disclosing any information, personal or otherwise, during a video or chat session.
Video and audio communication in Gledlingvo is provided through Voximplant, a cloud-based communication platform for business and developers. Privacy Policy -  - https://voximplant.ru/legal/privacy
For bulk SMS/MMS messaging, Gledlingvo uses two service provider - Bulksms and SMS-Traffic.
Our Policy on Children’s Information
Children under 13 are not allowed to use GledLingvo. If you are based in the European Economic Area (EEA), you may only use GledLingvo if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of GledLingvo has been provided to us. If you are a parent and you learn that your child is using GledLingvo and you don’t want them to, please contact support@GledLingvo.com.
Cookies
Cookies are small files that your browser stores on your device in a directory designated specifically for this purpose. These cookies can be used for example to find out whether you have already visited a website. Most browsers accept cookies automatically. Nevertheless, you can change the settings in your browser, so that no cookies are stored or so that your explicit agreement is required before any cookies are stored. You can also delete previously set cookies at any time. Please note that disabling cookies may result in your use of our website being restricted.
We need cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) to provide and monitor the effectiveness of our Service; (d) to monitor and aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) to diagnose or fix technology problems; (f) to help you efficiently access your information after you sign in; (g) to provide advertising, which may be tailored to your interests, and (h) to keep the GledLingvo community safe for members.
Registration and Authentication
By registering or authenticating, users allow GledLingvo to identify them securely and give them access to its services. Depending on what is described below, third parties may provide registration and authentication services. In this case, GledLingvo will be able to access some data stored by these third-party services for registration or identification purposes, with the user’s explicit consent:

Facebook Authentication (Facebook, Inc.): Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network. The personal data collected is various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy https://www.facebook.com/policy.php
Firebase Authentication (Google Inc.): Firebase Authentication is a registration and authentication service provided by Google Inc. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform. Personal Data collected: phone number. Place of processing: United States – Privacy Policy https://policies.google.com/privacy
Google OAuth (Google Inc.): Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network. Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy http://tools.google.com/dlpage/gaoptout?hl=de
Weibo (Sina.com): Weibo is a registration and authentication service provided by Sina.com and is connected to the Sina Weibo social network and SDK. Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: China  –  Privacy Policy https://www.weibo.com/overseas
WeChat (Tencent Inc.): WeChat Auth is a registration and authentication service provided by Tencent Inc. and is connected to the WeChat network and SDK. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: Canada and Hong Kong. Privacy Policy https://www.wechat.com/mobile/en/privacy_policy.html

Hosting and Backend Infrastructure
This type of service has the purpose of hosting data and files that enable GledLingvo to run and be distributed, as well as providing a ready-made infrastructure to run specific features or parts of GledLingvo. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where personal data is stored.
OVH (OVH SAS)— Internet service provider providing dedicated servers, shared and cloud hosting, domain registration and VoIP. Privacy Policy - https://us.ovhcloud.com/legal/privacy-policy
Amazon Web Services (AWS) (Amazon Web Services, Inc.): Amazon Web Services is a hosting and backend service provided by Amazon.com Inc. Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy https://aws.amazon.com/ru/legal/?nc1=f_cc
Google Cloud Platform (Google Inc.): Google Cloud Platform is a hosting and backend service provided by Google Inc. Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy https://policies.google.com/privacy
Handling Payments
Payment processing services enable GledLingvo to process payments, e.g. for Tutor lessons. To ensure greater security, GledLingvo does not process or store credit card details, and uses only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to you, such as emails containing invoices or notifications concerning the payment.
CardPay (CardPay Inc.) - is an e-Commerce company, a major member of MasterCard Europe, Visa Europe and UnionPay International, which accepts and processes online payments. Place of processing: Cyprus – Privacy Policy https://www.cardpay.com/site/assets/files/1079/cp_privacy_notice_v_01.pdf
PayPal - is a payment service that allows users to make payments through their PayPal accounts. Personal data to be collected: different types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy https://www.paypal.com/webapps/mpp/ua/privacy-full
Android Pay (Google Inc.): Android Pay is a payment service provided by Google Inc., which allows users to make payments using their mobile phones. Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy https://policies.google.com/privacy.
Apple Pay (Apple Inc.): Apple Pay is a payment service provided by Apple Inc., which allows users to make payments using their mobile phones. Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy https://www.apple.com/ru/legal/privacy/
Stripe (Stripe Inc): Stripe is a payment service provided by Stripe Inc. Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy https://stripe.com/en-US/privacy
The minimum amount of withdrawal from your GledLingvo account is $50. Until this amount is on the tutor's balance, it is impossible to make a withdrawal request.
Gladlingvo processes tutor requests for withdrawals from the platform within 72 hours. During the specified time, funds are transferred according to the payment details and amounts specified by the tutor in his request.
Infrastructure Monitoring
This type of service allows GledLingvo to monitor the use and behavior of its service components, so its features, performance, operation, maintenance and troubleshooting can be improved. Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of GledLingvo.
Crashlytics (Google Inc.): Crashlytics is a monitoring service provided by Google Inc. to enable GledLingvo to improve the stability of the app and reduce app crashes. Personal Data collected: geographic position, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and various types of data as specified in the privacy policy of the service. 
Adjust  (Adjust GmbH) - This service uses, among other things, the "adjust" assay technology to analyze the IP and Mac addresses of users, but only on an anonymous basis In this case, the identification of a particular person is impossible. By using this website/application for the purpose of analysis, you consent to the processing of data collected on an anonymous basis by the above method and for the aforementioned purpose. Data collection and storage using "adjust" technologies can be canceled at any time with effect in the future. For this purpose, please click on the following link: https://www.adjust.com/opt-out/