PRIVACY POLICY
Last Updated November 17, 2021
Voxy EnGen, Inc. (“Voxy,” “EnGen", “we,” “us,” or “our”) has prepared this Privacy Policy to explain what Personal Information (defined below) we collect, how we use and share that information, and your choices concerning our information practices. Through our mobile application (the “App”) and website (the “Site”), we provide a platform that helps people learn to speak English (such services are referred to collectively in this Privacy Policy as the “Service”).
This Privacy Policy explains what Personal Information (defined below) we collect, how we use and share that information, and your choices concerning our information practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.
Before using the Service or submitting any Personal Information to EnGen, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.
1. PERSONAL INFORMATION WE COLLECT
We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows:
Personal Information You Provide: We collect the following categories of Personal Information from you when you access, use, or browse any Site or provide Personal Information to us:
· Identification Information: We collect your name, email address, phone number, and password.
· Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing communication information is optional to you.
· Commercial Class Information: We may retain a history of the products or classes you browse and/or purchase take using the Service, as well as information relating to your progress in such classes. We may also record classes.
· Social Media Information: We have pages on social media sites like Facebook, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
Internet Activity Information: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:
● Log Information: Information that your browser automatically sends whenever you visit the Site. Log Information includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
● Cookies Information: Please see the “Cookies” section below to learn more about how we use cookies.
● Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
● Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
● Location Information: We derive a rough estimate of your location from your IP address. We collect your location information through the App using your device IP address, WiFi, Bluetooth, and GPS coordinates (e.g. latitude/longitude) of your mobile device. If you have given the App permission to access your location, we will collect your device’s location only while you are using the Service and store your location history. If you want to opt-out of the collection of your Location Information, please adjust your settings in your mobile device to limit the App’s access to your Location Information.
Personal Information Collected from Third Parties: We may collect Personal Information about you from third parties such as advertising and marketing partners and lead generation services.
Derived Information: We may infer your preferences for services based on the Personal Information we collect about you.
Cookies and tracking technologies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.
Some of our business partners also use cookies to provide us with anonymous, aggregate data and information regarding our users. In order to opt-out of a third-party vendor’s use of cookies, visit the Network Advertising Initiative opt-out page.
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
Advertising networks may use cookies to collect Personal Information. Most advertising networks offer you a way to opt-out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources and follow the opt-out instructions there.
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
We or our third-party tracking-utility company also use “web beacons” to collect information about your use of our Site, the websites of selected sponsors and advertisers, and our content and Services. Web beacons are tiny graphic image files embedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user’s browser. The information collected by web beacons allows us to statistically monitor how many people are using our Site and Services, selected sponsors’ and advertisers’ websites and using our Services and for what purposes.
Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this information, click here.
Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. We make reasonable commercial efforts to recognize and support “Do Not Track” signals.
2. HOW WE USE PERSONAL INFORMATION
We may use Personal Information for the following purposes:
· To provide the Service and help our users learn English;
· To alert you to new features, terms, content, Services, activities, or products;
· To send emails or newsletters, and to provide you with personalized content in the newsletters;
· To respond to your inquiries, comments, feedback, or questions;
· To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
· To analyze how you interact with our Service, including your browsing and viewing preferences;
· To analyze our users’ demographics and interests;
· To maintain and improve the Service;
· To develop new products and services;
· To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks;
· To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties; and
· To enforce the terms of service.
Aggregated Information. We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.
Marketing. We may use your Personal Information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
3. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, with the following categories of third parties:
· Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Information.
· Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
· Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
· Affiliates: We may share Personal Information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with EnGen. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.
· Sponsors: if your employer, school, or other third party sponsors your access to the Service (each a “Sponsor”), we may share your Personal Information with the Sponsor that sponsors your access to the Service.
4. DATA RETENTION
We keep Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business or contractual need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer. Upon termination of this Agreement, Customer has the option to request the removal of Personally Identifiable Information related to Customer Data and Usage Data collected during the Term.
5. CALIFORNIA PRIVACY RIGHTS DISCLOSURES
If you are a California Resident and have provided personal information to us, you are entitled by law to request certain information regarding any disclosure that may have been made by us to third parties of personal information for their direct marketing purposes. To make such a request, send a message to support@getengen.com. Where provided for by law and subject to any applicable exceptions, California residents may have the right:
· To know the categories of Personal Information that EnGen has collected about you, the business purpose for collecting your Personal Information, and the categories of sources from which the Personal Information was collected;
· To access the specific pieces of Personal Information that EnGen has collected about you;
· To know whether EnGen has disclosed your Personal Information for business purposes, the categories of Personal Information so disclosed, and the categories of third parties to whom we have disclosed your Personal Information;
· To have EnGen under certain circumstances, delete your Personal Information;
· To instruct businesses that sell Personal Information to stop doing so – EnGen, however, does not sell Personal Information; and
· To be free from discrimination related to the exercise of these rights.
If you would like to exercise any or all of these rights, you may do so by contacting us. The message should specify that you seek your “California Customer Choice Privacy Notice.” Please allow thirty (30) days for a response. We are required to respond only to one request per customer per year, and are not required to respond to requests made through means other than through the above channels. When contacting us, please indicate your name, address, email address, and what personal information you do not want us to share with third parties for their direct marketing purposes. Please note that there is no charge for controlling the sharing of your personal information or for processing this request. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
Please contact us with questions or to request access to an alternative format of this Privacy Policy.
6. CHILDREN
Our Service is not directed to children who are under the age of 16. EnGen does not knowingly collect Personal Information from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Information to EnGen through the Service please contact us and we will endeavor to delete that information from our databases:
If you are under 13, you are not permitted to register for emails or newsletters or to otherwise submit any Personal Information to us. If you provide information to us through the Site, you represent that you are 13 years of age or older. If you are between 13 and 17 years of age, when you visit, browse, use, or submit personal information to the Site, you represent that you have the permission of a parent or guardian to do so and who agrees to our Terms of Service and acknowledges this Privacy Policy on your behalf.
7. LINKS TO OTHER WEBSITES
The Service may contain links to other websites not operated or controlled by EnGen, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
8. SECURITY
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to EnGen via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.
9. YOUR CHOICES
In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to request updates or corrections to your Personal Information.
10. CHANGES TO THE PRIVACY POLICY
The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
11. CONTACT US
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated privacy request address: privacy@voxyengen.com