TONGO PRIVACY POLICY

Last updated 23 July, 2020

Please read this Privacy Policy carefully before using Tongo

This Privacy Policy is aimed to inform you (“You”) as a user of Tongo, a service available via the link tongo-learning.com (the “Website”) and the related application software distributed via application store(s) (the “App”), collectively referred to as the “Service”, about collection, usage, sharing of Your information by MOBAPP DEVELOPMENT LIMITED, a company having its registered address at Florinis, 7, Greg Tower, 2nd floor, 1065, Nicosia, Cyprus (collectively “we”, “us”, “our”).

You are also hereby informed of the options available to You in terms of the usage and disclosure of Your information by us.

This Privacy Policy is incorporated into, and is subject to, the Service Terms of Use. We shall not collect, use or share Your information except as described in this Privacy Policy.

By choosing to use our Service You: (i) agree to the collection and use of information in relation to this Privacy Policy, (ii) warrant and guarantee that You are over 16 years of age (or are a parent or guardian with such authority to agree to this Privacy Policy for the benefit of an individual under 16 years of age). Please do not use the Service if You do not agree to this Privacy Policy.

WHAT KIND OF INFORMATION DO WE COLLECT?

We may collect information that can identify You, such as Your name and email address (“Personal Information”), and other information that does not identify You, as listed below.

Information You provide

• Your full name and email address. We may collect and store the abovementioned information when You register and use the Service or provide it to us in some other manner, for example by corresponding with us (by email or chat, for instance) when You report a problem with the Service or when You subscribe to any of our services, or search for a service.

Note: Information about a third party

When You provide us with information about a third party, You must have the consent of that third party before providing us with that information. By providing us with information regarding a third party You warrant that You have their permission to provide that information to us.

Information collected automatically

• Device information that may include information specific to Your device (e.g., OS version, hardware model, unique device identifier, network information); information about Your logging in, use of features, functions, or notifications on the device. We may also collect and use Your Apple Identifier for Advertising (IDFA) and Google Advertising ID (AAID) to recognize Your device and support advertising activities on our Services. These number values are not permanently tied to Your device and, depending on Your operating system, You can reset it through Your device settings.
• Usage information: Your user account registration date and time, information about the use of the Service, such as frequency of use, engagement with particular features, which sections of the Service user visits and Your common use patterns.
• Location: IP address, time zone, mobile service provider.

If You purchase the access to or otherwise use the Service through the Website, we may additionally collect the following data:

• Transaction data: when You make payments through the Website, You need to provide financial account data, such as Your credit card number, billing and residence address, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used, payment transaction identification number.
• Cookies. We may use cookies in a range of ways to improve Your experience on the Website, including understanding how You use the Website and approving Your Website usage experience.

Cookies are text files placed on the computer to collect standard Internet log information and visitor's behavior information. When You visit the Website, we may collect information from You automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

There are a number of different types of cookies, however, the Website uses the following:

• Functionality – we use these cookies to recognize You on our Website and remember Your previously selected preferences. These could include what language You prefer and location You are in. A mix of first-party and third-party cookies are used.
• Activity – we use these cookies to collect information about the Your visit to the Website, the content You viewed, the links You followed and information about Your browser, device, and IP address.

Most browsers accept cookies automatically. If You want to prevent cookies from being saved, you can select the ‘Accept no cookies’ option in Your browser settings. To find out exactly how this works, You can consult Your browser manufacturer’s instructions. You can delete cookies that have already been saved on Your computer at any time. However, in a few cases, some of the Website features may not function as a result.

WHAT DO WE COLLECT THIS INFORMATION FOR?

• Enhancing Your user experience on our Service by operating, maintaining, and providing You with all of the content and features of the Services;
• Managing Your account and providing You with customer support. We may use Your Personal Information to respond to Your requests for technical support, Service information or to any other communication You initiate (“customer support purposes”);
• Performing research and analysis about Your use of, or interest in, our products, services or content, or products, services or content offered by others (“analytics purposes”);
• Communicating with You via email, push notifications, reminders and/or through other digital methods about products or services that may be of interest to You either from us or other third parties. You can opt out of receiving push notifications by changing the settings on Your device or in Your browser;
• If applicable, developing and providing content and advertising tailored to Your interests on our Service and other third-party services (“marketing purposes”);
• Detecting and resolving any fraud or other illegal or undesirable user behavior;
• Taking other legally-required actions.

With respect to Your purchase of the access to the Service through the Website, Your information may be collected to process Your payments as described in detail below.

We provide paid Content (as defined in the Terms of Use) within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, You will be able to make a payment for the Content and we will be notified that the payment has been made and either completed or not completed.

We will not store or collect Your payment card details ourselves. This information will be provided directly to our third-party payment processors, referred to in the next section. Our payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council. Payment processors who follow PCI-DSS requirements are committed to ensuring the secure handling of payment information.

WITH WHOM AND WHAT DO WE SHARE THIS INFORMATION FOR AND HOW MAY WE DISCLOSE IT?

Service Providers

We may share Your Personal Information with third parties that perform certain services on our behalf, such as our authorized service providers or analytics providers. In general, the third-party providers engaged by us will only collect, use and disclose Your information to the extent necessary to allow them to perform the services they provide to us, e.g. facilitating our Service and analyzing how our Service is used. Please note that they are obligated not to disclose or use the information for any other purpose.

You can learn more about service providers with whom we may share Your Personal Information as described above hereunder, along with links to such service providers’ privacy policies, which we recommend You read, depending on whether You use the Website or the App.

Service Providers as to the Website

1. Amazon Web Services

We use Amazon Web Services, which is a hosting and backend service provided by Amazon, for personal data hosting and enabling our Service to operate and be distributed to its users.

1. Amazon PinPoint

Amazon Pinpoint is AWS’s Digital User Engagement Service that provides tools, which enable Service audience management and segmentation, A/B testing and helps us understand user behavior.

In order to receive the analytics mentioned above we share the following data with Amazon PinPoint:

• User data;
• Endpoint data;
• Event data;

You can learn more about the Amazon Privacy Policy here: AWS Privacy Notice & AWS Data Privacy FAQ.

1. AppsFlyer

We use AppsFlyer for analytics purposes, specifically for research and analysis of users’ interaction with the Website. Appsflyer helps us to understand, in particular, how users find our Website (for example, which advertiser served an ad that led You to our Website). Appsflyer also provides us with different analytics tools that enable us to research and analyze Your use of the Service.

In order to receive these services from Appsflyer, we share such data as:

• Device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier (“Technical Information”);
• IP address (which may also provide general location information), user agent, Google Advertiser ID and other similar unique identifiers (“Technical Identifiers”).

You can learn more about the AppsFlyer Privacy Policy here: https://www.appsflyer.com/privacy-policy/. Please note that You may cancel collection of Your Personal Information for and sharing it with AppsFlyer here: https://www.appsflyer.com/optout.

1. Amplitude

We use Amplitude for analytics and customer support purposes, specifically to understand how customers use our Service.

As for analytics purposes, Amplitude helps us to understand, in particular, how users find our Website (for example, which advertiser had delivered an ad that led You to our Website). Amplitude also provides us with different analytics tools that enable us to research and analyze Your use of the Service, which helps us to decide what features we should focus on. As for customer support purposes, Amplitude helps us to respond to Your requests for technical support. For example, it enables us to track Your interaction with our Service in order to detect particular technical issues with the Website.

In order to receive these services from Amplitude, we share such data as:

• Platform, device type, device family, country, city, region, carrier, OS, time zone, language, IP Address, locale, referral source (“technical information”);
• Your interaction with the Service (i.e. taps on the particular screens) and age, gender, email, (“user related information”);
• Unique identifiers (such as IDFA).

Amplitude is EU-US Privacy Shield certified, which you can verify and learn more about here: https://www.privacyshield.gov/participant?id=a2zt000000001XZAAY&status=Active.
You can learn more about the Amplitude Privacy Policy here: https://amplitude.com/privacy.

1. Crashlytics

Crashlytics is a monitoring service provided by Google, which helps us to oversee infrastructure and Website performance, specifically we analyze Website crashes, reasons for such crashes and ways to avoid the crashes.
You can learn more about the Crashlytics Privacy Policy here: https://docs.fabric.io/apple/fabric/data-privacy.html#crashlytics.

1. Facebook Pixel

The Facebook Pixel is an instrument, which allows us to track and analyze user’s activity on the Website.
You can learn more about the Facebook Pixel Privacy Policy here: https://www.facebook.com/policy.php.

1. Google Analytics

Google Analytics is a product analytics tool provided by Google, which helps us to analyze the Service data and understand our users to optimize the Service performance.
You can learn more about the Google Analytics Privacy Policy here: https://policies.google.com/privacy.

1. Advertising services providers

We engage certain third-party service providers in order to help us spread the word about the Service and help the Service reach its potential users through reports and insights on how to optimize our promotional campaigns. For these providers, we recommend that You read their privacy policies so You can understand the manner in which Your Personal Information will be handled by these providers:

• Snapchat (https://www.snap.com/en-US/privacy/privacy-center);
• Pinterest (https://policy.pinterest.com/en/privacy-policy);
• Twitter (https://twitter.com/en/privacy);
• Google AdWords (https://policies.google.com/privacy);
  
  
1. Payment services providers

Certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies with respect to the information we are required to provide to them for Your purchase-related transactions. For these providers, we recommend that You read their privacy policies so You can understand the manner in which Your Personal Information will be handled by these providers:

• GTWS Solid Technologies Limited (https://solidtech.dev/terms);
• CHECKOUT LTD, CHECKOUT TECHNOLOGY LTD (https://www.checkout.com/legal/privacy-policy);
• SafeCharge (https://www.safecharge.com/privacy-policy);
• PayPal Holdings, Inc. (https://www.paypal.com/va/webapps/mpp/ua/privacy-full).

We recommend that You read all the privacy policies indicated above so You can understand the manner in which Your Personal Information will be handled by these providers.

Service Providers as to the App

1. AppsFlyer

We use AppsFlyer for analytics purposes as described herein below.

Appsflyer helps us to understand, in particular, how users find our App (for example, which advertiser had delivered an ad that led You to our App in App store). Appsflyer also provides us with different analytics tools that enable us to research and analyze Your use of the Service.

In order to receive those services from AppsFlyer, we share such data as:

• Device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier (“Technical Information”);
• IP address (which may also provide general location information), User agent, IDFA (Apple identifier for advertisers), Google Advertiser ID and other similar unique identifiers (“Technical Identifiers”);
• Information relating to our ad campaigns and Your actions in the App, such as: clicks on the ads, ad impressions viewed, the URL from the referring website, downloads and installations of App, and other interactions, events and actions, such as add to cart, in-app purchases made, clicks, engagement time etc. (“Engagement Information”).

Please read AppsFlyer privacy policy regarding its collection and use of data in order to perform services for us, available at https://www.appsflyer.com/services-privacy-policy, to acknowledge how AppsFlyer operates Your Personal Information. Please note that You may cancel collection of Your Personal Information for and sharing it with AppsFlyer using this link: https://www.appsflyer.com/optout.

1. Amplitude

We use Amplitude for analytics and customer support purposes as described herein above.

As for analytics purposes, Amplitude helps us to understand, in particular, how users find our App (for example, which advertiser had delivered an ad that led You to our App in App store). Amplitude also provides us with different analytics tools that enable us to research and analyze Your use of the Service.

As for customer support purposes, Amplitude helps us to respond to Your requests for technical support. For example, it enables us to track Your interaction with our App and in order to detect particular technical issues with our App.

In order to receive those services from Amplitude, we share such data as:

• Age, gender, email, locale, referral source, plan type (“user related information”);
• Platform, device type, device family, country, city, region, carrier, OS, language, IP address (“technical information”);
• Your interaction with the App (i.e. taps on the particular screens).

Amplitude is EU-US Privacy Shield certified, which you can verify and learn more about here: https://www.privacyshield.gov/participant?id=a2zt000000001XZAAY&status=Active.

You can learn more about the Amplitude Privacy Policy here: https://amplitude.com/privacy.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies with respect to the information we are required to provide to them for Your in-App purchase-related transactions. For these providers, we recommend that You read their privacy policies, so that You can understand the manner in which Your Personal Information will be handled by these providers. For example, Apple and Google may be two such third-party companies that provide payments and they can be contacted through their websites: https://www.apple.com and https://play.google.com.

Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms of Use to protect our rights, privacy, safety, or property, and/or that of our affiliates, You or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Information on customers is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

International Data Transfers

Please note that our business is global, so when You provide Personal Information through our Service, the information may be sent to servers located in different countries around the world.

If You reside in the European Economic Area, please note that we take all adequate security measures to provide suitable safeguards due to data transfer to third countries. Our sub-processors located in such countries are also bound by respective data transfer agreements between them and us to provide all available legal security measures in regard to data privacy. Should You have questions concerning data transfer to third countries please contact us at the email specified in section “Contact Us” below. Subject to applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

HOW YOU CAN ACCESS YOUR INFORMATION

If You would like to update or correct any information that You have provided to us through Your use of the Service, You may use the Service to do so. If You need help with rectification of data You think is inaccurate, please contact us via email specified in section “Contact Us” below.

You may also change certain Personal Information in Your account by going to the ‘Settings’ menu and editing Your account or sending an email request to us at the email specified in section “Contact Us” below.

You can make a request to erase Your Personal Information through the ‘Settings’ menu of the Service. Please note that it may affect the Services provided, and You will not be able to use the full scope of the Services. When we delete any information, it will be deleted from the active database, but it may remain in our archives due to legal obligations. Should You require the deletion of such Personal Information from our archives, please contact us at the email specified in section “Contact Us” below. Please note that we may be required to keep such information in our archives and not delete it (or to keep this information for a certain time, in which case we will comply with Your deletion request only after we have fulfilled such requirements). Please also note that the erasing of Your Personal Information does not mean the automatic cancellation of Your subscription purchased via the App or the Website or refund of Your payments.

You can make a request to receive the Personal Information related to You through the ‘Settings’ menu of the Service. Should You make such a request, You will be required to provide us with an email address, which we would be able to send Your Personal Information to. Please note that You confirm and guarantee that the email address You provide to us in order to receive Your Personal Information shall belong to You and You shall be solely responsible for its correctness and validity and therefore we shall in any case not be liable for any breach of Your Personal Information due to sending it to that email address.

If You reside in the European Economic Area You may object to the processing of Personal Information concerning You for marketing purposes by contacting us at the email specified in section “Contact Us” below and the related Personal Information shall no longer be processed for such purposes.

Please note that You may also opt out from collection of Your data for marketing and advertising purposes not only via our Service, but also on Your entire device using:

Your mobile device settings

iOS: go to “Settings” -> “Privacy” -> “Advertising” -> “Limit Ad Tracking”. You may additionally reset Your advertising identifier (this also may help You to see less of personalized ads) in the same section.

Android: for Android 6.0 and higher – go to “Settings” -> “Google” -> “Ads” -> ”Opt out of interest-based ads”. For Android 5.2 and lower, use Google Settings app -> “Ads” -> ”Opt out of interest-based ads”. You may additionally reset Your advertising identifier (this also may help You to see less of personalized ads) in the same section for both options mentioned.

and links below:

• Network Advertising Initiative – http://optout.networkadvertising.org
• Digital Advertising Alliance – http://optout.aboutads.info
• Digital Advertising Alliance (Canada) – http://Youradchoices.ca/choices
• Digital Advertising Alliance (EU) – http://www.Youronlinechoices.com
• DAA AppChoices page – http://www.aboutads.info/appchoices

Please note that the result of such objection or cancellation may affect the process of the Services improvement. However, You would still be able to use the Service.

If You think that the Personal Information related to You is inaccurate, but You can’t rectify it as described above, You may contact us at the email specified in section “Contact Us” below to restrict the processing of such data for the period of time we need to verify the accuracy of the Personal Information, which we will inform You of.

As to the App, You can also stop collection of information by the App by uninstalling the App from Your mobile device. You may use the standard uninstall processes as may be available as part of Your mobile device or via the App marketplace or network.

HOW WE SECURE YOUR INFORMATION

Security is our highest priority. We process Your information keeping Your security and privacy in mind.

• We protect the security of Your information by using encryption protocols;
• We aggregate and pseudonymize all of the users’ Personal Information;
• We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of Personal Information;
• We employ Personal Information systematic backups, which are intended to reduce the risk from disk crashes and errors, such as accidental information deletion.

While we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we make all reasonable efforts to prevent it. However, You should bear in mind that submission of information over the Internet is never entirely secure.

Please note that we do not collect and we are not responsible for the collection or security of Your payment details.

CHILDREN’S PRIVACY

This Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from children under 16. If we discover that a child under 16 has provided us with Personal Information, we shall take steps to delete such information and terminate the child’s account. If You are a parent or a guardian and You are aware that Your child has provided us with Personal Information, please contact us so that we will be able to take the necessary actions.

RETENTION

We will retain Your information for as long (i) as You have an account with the Service, or (ii) as the App is installed on Your mobile device, or (iii) as needed to provide You with our Service. We will also retain and use Your information, including copies of Your information, as necessary to comply with our legal obligations (including for tax and accounting purposes), resolve disputes, and enforce our agreements.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. Thus, You are advised to check our Service occasionally to inform Yourself of any changes. We will notify You of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page. Your continued use of the Service after changes to the Privacy Policy have been posted will constitute Your acceptance of such changes.

CONTACT US

Please submit any questions, concerns or comments You have about this Privacy Policy or any requests concerning Your Personal Information via the following email: support@tongo-learning.com.