This privacy policy (“Privacy Policy”) explains how information about you is collected, used and disclosed by italki HK Limited and their affiliates including Lingbe, S.L. (“italki,” the “Company”, “we”, “our” or “us”). This Privacy Policy applies to information we collect when you use our websites https://www.italki.com/ and https://www.italki.cn/ (the “Sites”), mobile applications, including our WeChat mini program, and other online products and services (collectively, our “Services”).

When we offer the Services in the United States (“US”), we may be subject to the data privacy laws, if any, of the state in which you are located. If you are located in the United States, please refer to your state’s data privacy laws to understand your rights.

When we offer the Services in the European Economic Area (“EEA”), we are subject to the European Union’s (“EU”) General Data Protection Regulation (“GDPR”), which applies across the entire European Union. Our data representative in the EEA is Joseph Izundu, who you can reach at [email protected]. In addition, our data protection officer may be reached at [email protected]

When we offer the Services in the United Kingdom (“UK”), we are subject to the UK General Data Protection Regulation Act and the Data Protection Act 2018.

By downloading, accessing, using and/or interacting with our Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Terms of Service available at www.italki.com/tos (our “Terms of Service”) and is subject to the provisions of the Terms of Service. Capitalized terms used but not defined in this Privacy Policy shall have the meaning ascribed to such terms in our Terms of Service. If you have any concerns about providing information to us or the use of that information as described in this Privacy Policy, you should not use our Services.

Modifications

Because we are always looking for new and innovative ways to help you achieve your goals in connection with the use of our Services, this Privacy Policy may change over time, so please review it frequently. The effective date at the top indicates the last time this Privacy Policy was modified. If we modify any material terms of this Privacy Policy, we will notify you by email, push notification, and/or by posting a notice on our website thirty (30) days prior to the effective date of the changes and seek your consent for any such changes. If we are required by applicable data protection laws to give you enhanced notice, we will do so. You can see when this policy was last updated by checking the “last updated” date displayed at the top of this policy. Any revised Privacy Policy will supersede all previous privacy policies.

Contact Us

If you have any questions about this Privacy Policy, please contact us as follows:

For users accessing the Services or the Site, please email us at [email protected] or request online support at https://support.italki.com.

For users accessing applications and websites operated by Lingbe, S.L., please email [email protected].

1. Personal Information We Collect

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household or natural person:

2. How We Collect Information

We collect information that you chose to provide to us, for example, when you create an account, manage your user profile, participate in any interactive features of our Services, request our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support or otherwise communicate with us. In some cases, information may be automatically collected from you when you interact with our website or Services. We only collect personal information that is necessary for providing our products and services in accordance with the principles of legitimacy, legality, necessity and good faith. We collect device information, software information, use information, and cookies from you automatically when you use the Services.

In addition to personal information, we automatically collect, you may share your personal information with us in the following ways:

• Identifiers and User-Generated Profiles and Content. You may share personal information when you create an account with us and as you use and communicate through our Services.

  We may process information provided by you (including content and messages) that you post through the Services, including personally identifiable information. By sharing personal information, you acknowledge that any information you share through the Services will be available to us and to other users (including students and teachers) of the Services. You also acknowledge that some of the content you share cannot be deleted from the Service as it may be connected to lessons created by you and used by other users. We will retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use the Services in a manner inconsistent with the Terms of Service.

  We may also process your lesson recordings when you use the Services to participate in individual lessons or group class lessons. This is used to generate personalized learning content, practice exercises, and recommendations. You may choose to turn this feature off.

  When sharing your personal information with other users, always remember that users with whom you communicate or share such information may store or reshare your information with other third parties on and off our Services.

• Customer Support and Other Communications. When you contact us for customer support or otherwise communicate with us, you may provide us with information related to your use of our Services, including copies of your messages, any contact or identifying information, or any other information you deem helpful. This includes surveys and online forms you fill out on the Services, questions or comments left in the Q&A section of the Site, and any feedback you provide us with.
• Payment Information. We process the details of transactions you carry out through the Services, such as user identifiers and the dates and times of transactions.
• Service Use. When you use our Services and Products, we monitor and analyze web traffic and keep track of your behavior. Please refer to our Cookie Policy for further details as to our use of cookies and similar technologies.
• Language Assessment. We may process your personal data to assess your level of language proficiency and learning progress for your reference. Such an assessment may take place before or after you register with us to use the Services.
• Sales Calls, Events, and Webinars.With your consent, we may record you in videos for internal training purposes when you participate in sales calls or attend our webinars and other events.
• Professional or Employment Related Information (Teachers Only) . We may request educational certificates, curriculum vitae (CV), or background information related to teachers’ teaching experience and history.

• Financial Information.To comply with the applicable tax and accounting legislation, we may be required to submit various tax documentation containing your personal data. For example, a federal tax form 1099 or such other required tax form(s) necessary to receive a sweepstakes prize or withhold taxes. For submitting tax documentation, we may process your personal data, including, but not limited to, your full name, country of citizenship, permanent residence address, mailing address, date of birth, U.S. taxpayer identification number, or foreign tax identifying number.

  The Directive (EU) 2021/514 (DAC7) requires us as a digital platform operator to collect, verify, and report data and information on teachers who are EEA residents and provide teaching services for students using the Services. To comply with our reporting obligations under DAC7, we may process your first name, last name, primary address, date of birth, tax identification number (TIN), VAT number, and financial account identifier (e.g., bank account).

• AI-Powered Features. When enabled by you, the Services employ advanced generative artificial intelligence (“AI”) technology to enhance your experience on the Services and for AI data training purposes. If you give consent, we may use your text prompts, voice recordings, audio recordings, lesson recordings, lessons transcripts to provide personalized learning recommendations, generate summaries and learning content, offer grammar explanations, vocabulary cards or messages, suggest exercises and homework, assess language proficiency levels, and enable chatbot functionality for vocabulary practice and grammar inquiries.

  During your lessons, we may analyze your microphone activity and measure the volume of the sound. We do this to provide you with an overview of your speaking activity and to let you know how active you were during the lesson; voice data is not used to personally identify you. You may choose to turn this feature off.

  You can control your messages, video, and voice content sharing directly in our Services via your settings.

In addition to the information that we collect directly from you, we also collect certain information from our third-party sources listed below (our “Third Party Sources”):

• App Stores or Distribution Channels. Our Services that are distributed through app stores or distribution channels, such as the Apple App Store, Google Play, and China-based Android app stores, may also request permission to automatically collect other information from your mobile or other device. Our Services may only collect such information with your authorization in accordance with your device operating system’s permission process.
• Apple App Store。 . Our Services that are distributed through the Apple App Store may also request permission to automatically collect other information from your mobile or other device. The Apple App Store may collect information regarding customer activity on the Apple App Store and aggregate that information to understand which part of Apple’s services are of most interest to you. More information on Apple’s privacy policy can be found here. Our Services may only collect such information with your authorization in accordance with your device operating system’s permission process.
• Google Play. Our Services that are distributed through Google Play may also request permission to automatically collect other information from your mobile or other device. Google Play may collect device-specific information to help the user decide on which devices the user would like purchases to be available for use. In mobile applications, Google Play may use identifiers specific to your device to serve you more relevant advertisements. More information on Google’s privacy policy can be found here. Our Services may only collect such information with your authorization in accordance with your device operating system’s permission process.
• Mobile Platforms. If you play or purchase our Services on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information includes your username and/or device ID and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide. Our mobile products also may request additional personal information from you, such as push notification tokens, and we will collect this information only if you give us your explicit consent.

• Third Party Account Registration Services. You may log in to our products or Services through a third party service. In the event you log in to our product or Services through a third party service, after your authorization, we will collect personal information provided to us by the third party. For example, if you create or log into your account through a social media site (such as Facebook and WeChat), we might have access to certain information from that site, such as your name, profile picture, phone number, and email address, in accordance with the authorization procedures determined by such social media site.

  We have identified the names of some third party services that allow you to register for and log in to our products or Services. Please see the links below to learn more about the personal information practices of such services and the personal information collected from the associated third party.

  Third Party	Privacy Policy	Personal Information We Receive
  Apple Inc.	Link	AppleID, avatar, name, and email address
  Google LLC	Link	Avatar, name, and email address
  Meta Platforms, Inc.	Link	Avatar, name, and email address
  VKontakte	Link	VK ID, avatar, name, mobile phone number, and email address
  WeChat (Tencent International Service Pte. Ltd.)	Link	WeChat ID, avatar, name, mobile phone number, and email address
  Naver Corporation	Link	NAVER ID, avatar, name, and mobile phone number

• Third Party Payment Channels. You may conduct transactions on our Services using a third party payment channel. In the event you conduct financial transactions on our Services using a third party payment channel, after your authorization, we will collect personal information provided to us by the third party payment channel.

  We have identified the names of some third party payment channels that you may use to conduct transactions on our Services. Please see the links below to learn more about the personal information practices of such payment channels and the personal information collected from the associated third party.

  Third Party	Privacy Policy	Personal Information We Receive
  Alipay	Link	Commercial information
  WeChat	Link	Commercial information
  Paypal	Link	Commercial information
  Skrill	Link	Commercial information
  Payoneer	Link	Commercial information
  Webmoney	Link	Commercial information
  Strip	Link	Commercial information
  Ebanx	Link	Commercial information
  Briantree	Link	Commercial information
  AllpayX	Link	Commercial information
  AirWalex	Link	Commercial information

• Third Party Services and User Information. We may allow third parties to serve advertisements in connection with our Services, to provide analytics services and provide you with other services, such as social media, rewards programs and tournaments. These third parties may use cookies, web beacons, your account information (that you provide to such third parties) and other technologies to collect information about you on our Services and other websites and online services, such as your name, profile picture, email address, your internet protocol addresses, identifiers associated with your mobile device or applications on the device, the browsers you use to visit our Services, pages viewed, time spent on pages, links clicked and conversion information. Some of such third party analytics and advertising services may offer you a choice to opt-out of the collection and/or sharing of this information. Links to the opt-out mechanisms for the third parties that offer such a choice can be found in the following section. This Privacy Policy does not apply to, and we are not responsible for, third party cookies, web beacons, or other tracking technologies.

  We have identified the provider names of some of the third-party analytics and advertising services we use. Please find a complete list of these services in our Cookie Notice(<a href='https://www.italki.com/en/cookienotice' rel='noopener noreferrer'><u>https://www.italki.com/en/cookienotice</u></a>)

  Additionally, the Services utilize YouTube application programming interfacing services (“API Services”) as a third party service, which teachers may use for lessons or to provide examples of their lessons. By accessing the Services you agree to be bound by YouTube’s Terms of Service (https://www.youtube.com/t/terms), Privacy Policy (http://www.google.com/policies/privacy), and API Services Terms of Service (https://developers.google.com/youtube/terms/api-services-terms-of-services) when engaging with YouTube’s API Services.

In particular, and in the past twelve (12) months, we collected the following categories of personal information by:

3. How And Why We Use Your Personal Information

We will only use your personal information for achieving the purposes listed in this Privacy Policy.

The personal information you permit us to collect and process allows us to provide you with the Services, give you notice regarding the Services, carry out our obligations and enforce our rights in connection with the Services, and fulfill any other purpose for which you provide it.

The internet, device, software, use, and other technical information we collect helps us to improve the Services and deliver a better and more personalized experience by allowing us to estimate our audience size and usage patterns, improve features in the Services, and recognize when you use the Services.

Before using your personal information beyond the purposes outlined in this Privacy Policy, we will inform you in a timely and reasonable manner, obtain your consent, and explain why we would like to use your personal information.

We will only use sensitive personal information with your explicit consent. With respect to other types of information, we only use your personal information when we have a proper reason for doing so, such as when you have given us your consent.

We may use your personal information as part of the performance of our contract with you or to take steps at your request before entering into a contract, including to provide the Services to you; to update and enhance our customer records; to receive payments from you; process and deliver contest entries and rewards; respond to your comments, questions, requests, and provide customer service.

In some cases, we may use your personal information for our legitimate interests or those of a third party, including to prevent unauthorized access and modification to our systems, to update and enhance our records, for our operational reasons, such as improving efficiency, training, and quality control, to ensure the confidentiality of commercially sensitive information, for statistical analysis to help us manage our business, to conduct external audits and quality checks.

In rare cases, we may need to use your personal information to comply with our legal and regulatory obligations, including to screen for financial and other sanctions or embargoes, to comply with privacy, financial, and other regulations, to conduct audits or engage in inquiries or investigations by regulatory bodies, to prevent unauthorized access and modifications to our systems, to update and enhance our records, to file statutory returns, to conduct external audits and quality checks.

Because we are continuously improving our products and Services, we may launch optimization functions from time to time which may increase or change the scope, purpose and/or method of collecting and using your personal information. In the event any optimization functions increase or change the scope, purpose, and/or method of collecting and using your personal information, we will clearly explain it to you by updating this Privacy Policy, provide for a pop-up window, on-site notification, or email notification, and give you the option to agree. You have the right to refuse to agree, but we may not be able to continue to provide you with the Services and/or updated functions.

We may process your personal information for the purposes of targeted advertising. We will only process your personal information for the purposes of targeted advertising with your explicit consent.If you have previously given us permission to process your personal information for the purposes of targeted advertising and now wish to revoke such permission, please see Section 10 (Your Controls) below.

In particular, and over the past twelve (12) months, we collected and used the below types of personal information in the following contexts for the following reasons:

4. Who We Share Your Personal Information With

You may ask us to share your personal information in a portable format with a third party of your choosing by submitting a verifiable request in accordance with Section 9 (How to Exercise Your Rights) of this Privacy Policy.

In certain circumstances, we may share(i.e., share, release, disclose, disseminate, make available, transfer, or otherwise communicate) personal information with others for our operational and business purposes. We will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and will only share the personal information necessary to provide the Services. At the same your personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures. Except as described in this Privacy Policy, we will not share your personal information with any other third parties. In particular, we may share personal information with:

Our affiliates, Lingbe S.L. and Qianyan Information Technology (Shanghai) Co., Ltd., are subject to the processing scope and purpose of this Privacy Policy. If an affiliate wants to change the processing purpose for your personal information, we or the affiliate will request your authorization again.

Our service providers, who work on our behalf for the purposes described throughout this Privacy Policy and receive and process personal information for our business purposes. All of our service providers are contractually obligated to protect personal information to the highest degree required under the law. If you refuse to allow our service providers to collect the personal information necessary for providing specific services, you may not be able to use such service on our platform. Our service providers are not authorized to use your personal information for any other purpose. Our service providers include:

We also may share personal information with any competent law enforcement body, regulatory body, government agency, court or any other third party where we believe disclosure is necessary as a matter of applicable law or regulation, to exercise, establish, or defend our legal rights, to protect your vital interests or those of any other person, or in response to lawful requests by public authorities or as otherwise required by law.

In case of a merger, acquisition, bankruptcy, or liquidation of our Company where the transfer of personal information may be involved, we will require new companies and/or organizations that come into possession of your personal information to continue to be bound by this Privacy Policy. If the new company or organization wishes to change its practices with respect to the collection and processing of your personal information and as outlined in this Privacy Policy, such new company or organization will ask for your consent before doing so.

We do not sell or share personal information for commercial purposes.

5. Where Your Personal Information Is Held

For users based outside of China, we store your personal information on servers on servers primarily located in the United States and Spain. The data protection and other laws of United States and Spain and/or other countries might not be as comprehensive as those in your country. By submitting your data and/or using our Services, you acknowledge that your data might be transferred, stored and processed in and to United States and Spain and other countries where we may choose to store data. In addition, when we disclose to your information to third parties, we implement appropriate safeguards to ensure that such protection is maintained and is not undermined as a result of that disclosure.

For users based in China, we store your personal information only on servers located in China. We will not process, store, share and disclose your personal information in cross-border business, or transmit your personal information abroad except as otherwise described in this Privacy Policy.

From time to time, and in accordance with the terms of this Privacy Policy and applicable privacy laws, we may transfer personal information to a recipient located outside of the jurisdiction in which you are located.

Some regions we operate in have specific laws relating to the transfer of personal information outside of the region. If you are a user located in one of such regions, before we transfer your personal information outside of the region in which you are located, we implement certain measures required by the laws of your jurisdiction.

6. How Long Your Personal Information Is Kept

Typically, we will keep your personal information while you have an account with us or while we are providing Services to you. Thereafter, we will keep your personal information for as long as is necessary to respond to your questions, complaints, claims or as required by law, or, with regard to personal information that you share which is connected to lessons created by you and used by other users, for as long as is necessary to respond to other users’ questions, complaints, or claims with regard to such lessons. We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete and/or anonymize it. In the event the jurisdiction in which you are located has personal information retention legal requirements that differ with those listed in this Privacy Policy, the rules and regulations of such jurisdiction with respect to personal information retention shall control. Generally, different retention periods apply for different types of personal information as follows:

7. How Your Personal Information Is Kept Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. These security measures may include practices such as keeping your sensitive data on a secured server behind a firewall, and transmitting sensitive information (such as a credit card number) entered while using the Services using secure socket layer technology ("SSL"). Notwithstanding the security measures that have been taken and the legal requirements that have been implemented, we still cannot guarantee the security of your personal information when communicating through unsafe channels. Therefore, you should also take measures to ensure the security of your personal information, such as changing your account password regularly. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

8. Your Personal Information Rights

You have specific rights regarding your personal information, which are described in this section. You or an authorized agent acting on your behalf may exercise your personal information rights by submitting a verifiable request or through our platform (see Section 9 (How To Exercise Your Rights) below).

If an authorized agent submits a request to know or delete your personal information, we require you to (i) provide your authorized agent with signed permission to exercise your rights and choices, (ii) verify your identity directly with us, and (iii) directly confirm with us your authorized agent has the permission to submit the request.

9. How To Exercise Your Rights

To easily access, view, update, correct, delete or port your personal data, or to update your subscription preferences, please sign into your account and visit “Settings” > “Privacy.” Where we rely on consent to collect and use information about you, you can withdraw your consent at any time. If you make a request to delete your personal data and that data is necessary for the Services you or another user have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

To exercise the access, data portability, correction, and deletion rights described above please submit a verifiable request to us by emailing us at [email protected].

Only you, or a person authorized by law to act on your behalf, may make a verifiable request related to your personal information.

You may only make a verifiable request for access or data portability twice within a twelve (12) month period. The verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

If your account is lost, you can verify through SMS or contact customer service to reset your password. However, in this process, you need to provide some personal information to verify your identity. When retrieving your password, we may need you to provide frequent login location, frequent login device, frequent listening content, registration time and city information. If necessary, we may also verify your true identity through face recognition.

Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

We will send you confirmation of our receipt of any verifiable request within ten (10) business days of its receipt. We endeavour to substantively respond to any verifiable request within fifteen (15) days of its receipt. If we require more time, we will inform you of the reason and extension period required in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by the method you submitted your request.

If we cannot comply with a verifiable request, we will explain our reasons to you in writing, if applicable. Where we inform you that we cannot comply with a verifiable request, you may submit an appeal to us within a reasonable period of time following your receipt of our decision to refuse to process your request. In the event you submit an appeal, we will respond to you in writing within forty-five (45) days and disclose any action taken or not taken in response to your appeal and an explanation of our decisions. In some US states, you may have the right to submit your concerns with the result of the appeal to your attorney general.

For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another without hindrance.

Typically, you will not have to pay a fee to access your personal information or to exercise any of your privacy rights. However, except in relation to consent withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request. We may also refuse to comply with your request in such circumstances.

We may decline to comply with your request under the following circumstances, and in accordance with applicable laws and regulations:

• Where it is related to our obligations under law and/or regulation
• Where it is related to national security and national defense security
• Where it is related to public safety, public health and major public interests
• Where it is related to criminal investigation, prosecution, and trial
• Where there is sufficient evidence to show that you have subjective malice or abuse of rights
• Where responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations
• Where trade secrets are involved
• Other conditions stipulated by laws and regulations

10. Your Controls

We give you control over our use and collection of your personal information. In this section, we detail your controls.

We will not discriminate against you for exercising any of your controls or rights over your personal information. Unless otherwise permitted and as described in this Privacy Policy, when you exercise your controls or rights over your personal information, we will not deny you products or services, charge you different prices or rates for products or services, including through discounts or other benefits, or by imposing penalties, provide you a different level of quality of products or services, or suggest that you may receive a different price or rate for products or services or a different level of quality of products or services.

11. Financial Incentives

We may offer certain permitted financial incentives related to the collection and/or retention of your personal information, such as contests. These may be deemed a financial incentive, loyalty program, or price or service difference under applicable law. We are providing you with the information contained in this section so that you may make an informed decision on whether to participate in our programs, such as:

• Limited-Time Promotions, Contests, or Sweepstakes: From time to time, we may offer certain financial incentives limited to a specific time period, such as limited-time sweepstakes, contests, and other promotions. In exchange for participation in these promotions, you may be offered a financial incentive, such as a prize. As part of these limited-time promotions, contests, or sweepstakes, we may collect your personal information such as your username, name, email address, or phone number. Participation in a limited-time offer or promotion is governed by the applicable terms and conditions for the program.
• One-Time Promotions: We may offer you one-time promotions from time-to-time, and may collect your personal information related to the one-time promotion, such as your username, name, email address, or phone number. Participation in a one-time promotion is governed by the applicable terms and conditions for the program.
• Surveys: We may also offer users the opportunity to participate in surveys. In exchange for participation you may be offered a financial incentive. As part of these surveys we may collect personal information, such as your name, username, email, phone number, preferences, experiences, beliefs, opinions, and other responses to the survey questions.
• Referrals: We may offer you certain financial incentives when you refer a friend to use our Services. To make a referral, we may require you to provide us with your username, name, telephone number, and/or email address.

Such financial incentives may not be available at all times. The amount and terms of such financial incentives will be presented to you at the time of the offer. The monetary value of any financial incentive will be based on our good-faith estimate of the benefit we receive when you accept our financial incentive offer. We calculate that monetary value by comparing our costs to offer you the financial incentive to the benefit we receive when you accept our offer.

By participating in any of our promotional programs, you agree that the benefits are reasonably related to the value of your personal information collected and retained. Participation in any promotional program is always optional, and you can terminate your participation by contacting us here.

12. Permission Authorizations

In order to provide you with convenient and high-quality services, we may request some permissions on your device. When you use the corresponding function, you will see a pop-up reminder requesting your authorization to access certain device functions. You can choose to turn off some or all permissions in the setting function of the client or device. The methods for granting or withdrawing permissions may be different in different devices.

13. How We Respond to Do Not Track Signals

Because consumers are often unaware that their Do Not Track beacons are active, Do Not Track signals frequently do not reflect the actual preferences of our users. We currently do not respond to Do Not Track signals. In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings or by using a universal opt-out mechanism in your browser. For more information, please see Section 10 (Your Controls) above.

14. Our Policies Regarding Children

As set out in our Terms of Service (available at www.italki.com/tos), you must be at least 18 years old or have the requisite power and authority to access and/or use our Services. If you are still a minor (i.e., under 18 years old), you must obtain the consent of your parent or legal guardian to use our Services.

If you are the legal guardian of a minor, please pay attention to whether the minor uses our Services or provides his or her personal information after obtaining your authorization and approval. If you have questions about the personal information of the minor under your guardianship, please contact us here.

Filing a Complaint

We hope that we can resolve any query or concern you raise about our use of your personal information. If you would like to make a complaint regarding our privacy practices, please contact us at [email protected] or [email protected]. We will reply to your complaint as soon as we can. If you feel that your complaint has not been adequately resolved, you may be able to lodge a complaint with a supervisory authority or other authority local to you.

15. Extra Help

If you would like this Privacy Policy in another format (e.g., audio, large print, braille, et cetera) please contact us here.