• Cookies (or browser cookies). “Cookies” are small text files that are placed on your device by a Web server when you access our Services. Please see our Cookie Notice privacy@diglossia.net for more details.

• Web Beacons. Pages of the Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

• Do Not Track. Please note that our Services does not currently respond to browser- based “do not track” signals. We will respond to any similar signals in the future as may be required by applicable law.

What information do we collect when you voluntarily provide it?

We collect Personal Information from and about you when you voluntarily provide it to us, in addition to Personal Information and other data we collect automatically when you visit the Services. Depending on the website you have accessed, or the other ways in which you interact
with us, we may collect different types of information as outlined below.

Website Users

Some of our Services enable you to register to create an account. If you do this, we will collect your name, username, email address, and password you provide. On some Services we may also request additional Personal Information associated with your account (such as your company name, school, or other data). We use this information in connection with your account and your use of our Services and services. We may also use this information to send you emails regarding other Company products and services we believe would be of interest to you.

• Any user of our Services wishing to obtain support must provide an email address. Without this information we cannot answer your questions. When submitting a support question to us you must not only provide a valid email address, but also first and last name, US state if applicable, country, role, and your specified request. Some of our Services offer multiple levels of access, some of which may require users to register or purchase a subscription, and others which are available without registration or subscription. Differences between levels of access may require corresponding differences in data collection practices.

• If you are a subscriber to one of our Services, you must provide a valid email address and password. Some Services may additionally require role (educator, parent, researcher), country, US state, and company.

Services Form Inquiry

Certain pages on some of our Services enable you to submit inquiries or requests to us. These Services collect Personal Information when users complete an inquiry or request for more information using our online form. These forms typically collect the following information: first and last name, phone number, email address, organization name, organization type, areas of interest. We may share this information with our third-party service providers, including storing the information in cloud-based contact management systems, and providing the information to third parties who assist us with our email marketing and other communications.

Children’s and Adult Information Collected

We may receive data provided by a teacher regarding a child, or by a state, school district or other school administrator containing information regarding a child or groups of children. We do not otherwise collect information directly from a child. If you believe that we have collected yours or the Personal Information directly from a child under the age of 13 without following proper procedures, please notify us immediately via email to privacy@diglossia.net.

What information do we collect from other sources?

We may collect limited data from schools with which we have a relationship, public databases, marketing partners, and other outside sources (“third parties”). All Personal Information that you provide on or to such third party sources or that is collected by a third party is provided directly to the controller, owner or operator of the third party and is subject to the owner’s or operator’s privacy policy. We do not monitor or control any data you provide to such Third Parties. Thus, we are not responsible for the content, privacy or security practices of a third party. To assure
the protection of your Personal Information, we recommend that you carefully review the privacy policies of any third party you access. You assume the risk of providing any information you provide to a third party.

Do we sell your Personal Information?

No. We do not sell your Personal Information, and as such you do not have to Opt-in or Opt-out of any sale of information requirements under the law. However, as noted below, we do share Personal Information with our Services Providers and with certain third parties under very limited circumstances.

What and how do we share with Services Providers?

In order to operate our Services it may sometimes be necessary to disclose Personal Information with contractors and other service providers. For example, we may share Personal Information with the companies that host our Services (such as AWS), provide analytics and other functionality on our Services, host or provide our database of current and potential customers, help us send emails and other communications, or provide other services to us. In addition, we may share Personal Information with individual contractor scientists and software developers as may be required.

As noted above, we use third-party service providers to analyze audio recordings. When the recording is submitted to the third party for processing, no other personal identifiers are shared. Results from the third party are combined with our own processes to calculate the reader’s proficiency results. In doing so, we connect the proficiency results with the Personal Information you provided.

All Services Providers are bound by a legal contract to keep Personal Information confidential. They can use Personal Information only for the purposes for which we disclose it.

Please check this Privacy Policy regularly for updates Services Providers that may be used in connection with the Services or contact us at privacy@diglossia.net for the most recent list of our Services Providers with whom we share your information.

What and how do we share with other third parties?

Fulfilling your requests. Some of our Services include the ability for you to share content or information with third parties you designate. If you give us an email address to use the “share” feature within a tool, we will transmit the contents of that email and your email address to the recipients.

Affiliated entities and corporate transactions. We may share Personal Information with our current or future subsidiaries and affiliates in order to streamline provision of services or for other business purposes. In addition, if we contemplate a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, it is possible that we would need to share Personal Information with another organization during the due- diligence process, following the transaction, or otherwise in connection with a corporate event.

Legal proceedings. We may also share Personal Information to comply with a court order, law or legal process. This includes a government or regulatory request. Before we do that, we would provide the user with notice of the requirement. If the user so chooses, a protective order or another remedy could be sought. If after providing that notice we still must share the demanded Personal Information, we will share no more than that portion of Personal Information which, on the advice of our legal counsel, the order, law or process specifically requires us to share. Note, some of these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Information as your home jurisdiction. We may, in our sole discretion (but without any obligation) object to the disclosure of your Personal Information to such parties.

Other parties. We may share Personal Information with third parties as we deem appropriate in order to enforce or apply our Terms of Use or other agreements, including for billing and collection purposes, to prevent fraud, and to obtain advice about legal and financial matters.

How long do we keep Personal Information?

In general, we keep Personal Information as long as it is reasonably necessary in connection with the purpose for which it was provided. For data collected through our Services we will keep Personal Information for as long as you maintain registration and or subscription in good standing. Once those registrations or subscriptions lapse or terminate, unless a written agreement between us and a member provides otherwise, we may keep Personal Information for as long as needed only to meet regulatory requirements or business requirements. Any kept Personal Information will remain subject to the restrictions on sharing and use outlined in this Policy for as long as it resides with us.

What is the Company’s legal basis for processing?

We process your Personal Information in accordance with applicable data protection laws. If you are subject to the GDPR, we process Personal Information in accordance with one of the required legal bases. For example, when you voluntarily provide Personal Information to us, we primarily process it with your consent, or in order to fulfill a contract with you. Information we collect automatically is typically processed in accordance with legitimate business interests, such as to improve our Services or fulfill our contractual requirements. We may also process certain Personal Information to the extent required by applicable legal requirements.

How can you exercise rights in your Personal Information?

Regardless of where you live, and subject to our obligations under applicable laws, you may have certain rights and choices regarding your Personal Information. For example, in addition to choices described elsewhere in this Privacy Policy, you may have some or all of the following rights and choices in general:
General Regional Rights

• Access Rights: You may have the right to receive certain information, such as the following (these rights, and the applicable types of data and time periods, will vary depending on the laws applicable to the state or country in which you reside):

1. 1. 1. The categories of Personal Information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting your Personal Information; and the categories of third parties with whom we shared Personal Information.

      2. Access to and/or a copy of certain Personal Information we hold about you.

      3. In some circumstances, you may have the right to obtain certain Personal Information in a portable format.

• Erasure: You may have the right to request that we delete certain Personal Information we have about you. We may either decide to delete your Personal Information entirely, or we may anonymize or aggregate your Personal Information such that it no longer reasonably identifies you. Certain Personal Information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide our Services to you, we may be required to retain certain information for legal purposes, and there may be other reasons we may need to keep certain Personal Information under various applicable laws. In addition, if you ask us to delete your Personal Information, you may no longer be able to access or use some of our Services.

• Correction: You may have the right to request that we correct certain Personal Information we hold about you.

• Limitation of Processing: Certain laws may allow you to object to or limit the manner in which we process some of your Personal Information, including the ways in which we use or share it. For example, you may have these rights if the processing was undertaken without your consent in connection with our legitimate business interests (although we may not be required to cease or limit processing in cases where our interests are balanced against your privacy interests).

• Regulator Contact: You may have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Information. To do so, please contact your local data protection or consumer protection authority.

• Postings by Minors: Users of our Services under the age of 18 in certain jurisdictions have the right to require that we delete any content they have posted on one of our Services.

• Other: You may have the right to receive information about the financial incentives that we offer to you, if any. You may also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. If you believe that you have specific rights under your jurisdiction and you would like to exercise any of these rights, please submit a support request through our website or email us at privacy@diglossia.net. Other than marketing opt-out you will be required to verify your identity before we fulfill your request. In certain jurisdictions, you may be able to designate an authorized agent to make a request on your behalf, subject to certain requirements of your applicable law. We may require that you provide the email address we have on file for you (and verify that you can access that email account) as well as an address, phone number, or other data we have on file, in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf, and we may be required to take additional verification measures under applicable law. 

Important Information for European Union and United Kingdom Users

If you are a user from the European Union or United Kingdom you should be aware that we are the controller of your Personal Information (Data Controller) under the EU General Data Protection Regulation (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”), and such similar laws promulgated in the various EU countries.

You may have certain additional rights regarding your Personal Information (as defined in the GDPR and UK GDPR, for instance), including the right to:

• access your information;

• rectify your information if it is incorrect or incomplete;

• have your information erased (“right to be forgotten”) if certain grounds are met;

• withdraw your consent to our processing of your information at any time, if our processing is based on consent;

• object to our processing of your information, if our processing is based on legitimate interests;

• object to our processing of your information for direct marketing purpose; and

• receive your information from us in a structured, commonly used, and machine-readable format, and

• the right to transmit your information to another controller without hindrance from us (data portability).

There is no charge for any of these requests. To make a request, please contact us at privacy@diglossia.net. We try to respond to such requests in a timely manner, but in no event longer than one month.

When we collect your Personal Information, we maintain and store it for as long as we determine reasonably necessary to provide our services to you, unless you exercise your right to erasure described above, or to comply with applicable legal requirements.

If you are a citizen of the European Union or United Kingdom, when we process your Personal Information, we will only do so in the following situations:

• We have a contractual obligation.
• You have provided your consent. You are able to remove your consent at any time, and you may do this by contacting us at privacy@diglossia.net.
• We have a legal obligation.
• We have a legitimate interest in processing your Personal Information. For example, we may process your Personal Information to send you marketing communications, relevant content, products or events invitations, or to communicate with you about changes to our services, and to provide, secure, and improve our services.

You should be aware that Personal Information that you provide to us may be transferred out of the country in which you reside to servers in a country that may not guarantee the same level of protection as the one in which you reside. We do this for a legitimate business purpose in providing the Services as permitted under UK and EU privacy laws, and therefore specific consent is not required under the EU and UK legal schema. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely in accordance with this Privacy Policy, and no transfer of your Personal Information will take place to a third party unless there are adequate controls in place to protect your Personal Information and/or you have provided contractual consent by becoming a client.

If you are a user in the European Union or United Kingdom and have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

What data security measures do we take?

We have reasonable safeguards to help prevent unauthorized access to, disclosure of, or misuse of your Personal Information. However, we cannot guarantee that your Personal Information will never be shared or otherwise processed in a manner inconsistent with this Privacy Policy (for example, as a result of unauthorized acts by third parties that violate applicable law or our Terms of Use www.diglossia.ae/terms).

If you register for our Services, you will be randomly assigned a password to help protect your Personal Information. You then have the option to change your password, which we encourage you to do. These passwords help us verify your identity before granting access or making corrections to any of your Personal Information. You should never share your password with anyone. The Company will never ask you for your password in a phone call or email. You are responsible for maintaining the secrecy of your passwords and any account information.

Kindly direct any issues or concerns to our support community for further guidance at privacy@diglossia.net.

Finally, the computers/servers in which we store Personal Information are kept in a secure environment. However, please note that to the extent your Personal Information is shared with a Service Provider or other third party, we cannot guarantee, nor will we be responsible for, the security measures of those third parties.

How should you track changes to this Privacy Policy?

It is our policy to post any changes we make to this Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page or App. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page or App. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website or App and this Privacy Policy to check for any changes.

Where should you direct questions to us about this Privacy Policy?

If at any time you have questions or concerns about our privacy practices in general or this Privacy Policy in particular, please feel free to contact us by sending an email to privacy@diglossia.net, or contacting us at Diglossia, PO Box 769469, Yas Creative Hub, twofour54, Abu Dhabi, UAE.