Lugga shall respect the privacy of users when using our Language Learning Application and will strive to protect the personal information of users based on the following policies.
Our Application will collect the personal information of users. This information includes:
User names
Email addresses
Learned languages and languages currently studied
Countries knowledgeable about and countries interested in
Profile photographs
In addition, when using this service, information to be used in various areas, including the following, will be automatically collected and generated.
Access log
Device information
IP Address
Cookie information
Statistical data
Furthermore, this information will be used in the analysis of the management and utilization of this service and does not include information that can be used to identify individual users.
The purpose of use and scope of the application of personal information is as follows. Lugga may amend the purpose of use of personal information provided within a reasonable scope, and when this purpose is changed, will either notify users or make a public announcement.
To provide this service and authenticate the identity of users
To provide information for the purpose of providing member services to companies who supply product advertisements, etc.
To implement questionnaires and campaigns to improve services provided by our company
For the free supply of various information in emails from application, and replies to inquiries.
To respond to actions that violate the rules and policies, etc., (hereafter referred to as “rules, etc.”) relevant to this application.
To notify users of changes to rules, etc. relevant to this service
To help to improve this service and develop new services
To create statistical data about this service that has been formatted so that individual users cannot be identified
For the implementation of business alliance with a third party (Limited to personal information included in the posted data, etc. (posted original text, corrected text, explanatory text for correction, native language, information on learning words, voice data and other data created or posted by members)For other purposes incident to those stated above
Users may request the correction, addition, or deletion of personal information, based on the Act for the Protection of personal data (Meaning “personal data” as defined in Article 2.6 of the Act on the Protection of Personal Information. The same shall apply hereinafter).
1. As a general principle, the personal data of users will not be released to third parties without the consent of the user. Personal data will only be released after specifying its destination and what information will be sent, and after obtaining the consent of the user. However, this does not apply in the following circumstances:
(1) To comply with laws and regulations
(2) When it is required to protect a person’s life, body, or property, and it would be difficult to obtain the user’s consent
(3) When it is especially required to improve public health or to promote the sound growth of a child and it would be difficult to obtain the user’s consent
(4) When it is required for cooperation with a state organ, a local government, or an external party who has taken on work from either of these, so that these organizations may execute work prescribed by law and regulations, and obtaining the consent of users could potentially impede the execution of this work
2. The provisions regarding the supply of information to third parties as prescribed above shall not apply to the following, regardless of the provisions of the preceding paragraph.
(1) When entrusting the handling of personal data, in whole or in part, within the scope necessary for the achievement of the purpose of use
(2) When personal data is supplied as a result of the succession of business after a merger or otherwise
(3) For joint use as prescribed in the Act for the Protection of personal data
Our company bears no responsibility for the acquisition of personal information by third parties under the following circumstances:
When a user discloses personal information to another user via the features of this service or any other method
When a user can be identified by chance through activity data and information entered by another user
When a separate user acquires information that can be used to identify the user (ID, password, etc.)
1.This service may use cookies and other similar technology. This technology helps our company to understand the utilization, etc., of this service, and plays a part in the improvement of this service. If you do not want us to store cookies on your computer, you can disable cookies on your browser settings. However, you may become unable to use parts of this service if you disable cookies.
*Cookies are information files sent from the server to the user’s browser and then stored on the user’s hard disk.
2.We use cookies, image files (web beacons), etc. from third-party companies (*1) and obtain statistical site usage information in order to study customer trends and provide optimal ad delivery.
In addition, some of the cookies and web beacons mentioned above include third-party companies obtaining information directly, and any cookie information collected there is not provided or disclosed to us, but is managed in accordance with the privacy policy prescribed by the third-party company. This information cannot be used to identify individuals and is handled in the form of anonymous data. It is also not used for anything other than the stated purpose.
*1: For third-party company privacy policies and explanations about cookies, please refer to the website of the third-party company.
By opting out, users are able to invalidate any analysis using cookie technology.
Information about users who have accessed this application’s website is recorded in the form of an access log. The access log includes information such as the user’s IP address, host name, browser, OS, time of access, etc.
Access logs are used in statistical analysis related to the maintenance and utilization of this service and have never been used for any other purpose.
Our company creates statistical data based on the personal information provided, in a format that cannot be used to identify individual users, and may use this data without any restriction.
Lugga occasionally reviews how personal information is handled, is continuously striving for improvement, and as such may make amendments to this Privacy Policy as necessary.
The personal information provided by our users is managed responsibly by Lugga. If you have any questions or comments regarding the handling of personal information on this service, please contact us using the address below.
Admin@luggalanguages.com
GDPR PRIVACY POLICY
This GDPR PRIVACY POLICY (this “Privacy Policy”) states the policy for processing of personal data obtained from persons (the “User” or “Users”) residing in EU that use the Language learning application Lugga. Upon the User’s agreement to this Privacy Policy, the User shall be deemed to have given a voluntary and express consent to the subject matters of the User’s consent stipulated in this Privacy Policy (including, without limitation, the purposes of processing of personal data and transfer of personal data to third countries).
The following terms as used herein shall have the meanings as set forth below. Definitions of the terms that are not defined herein shall be subject to the definitions provided in GDPR.
EU
European Union that includes the member states of European Union, as well as Iceland, Lichtenstein and Norway under Agreement on the European Economic Area (EEA). -GDPR
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC(General Data Protection Regulation).
Applicable Privacy Laws
Applicable privacy laws including GDPR and domestic laws related thereto of relevant countries.
personal data
“personal data” as defined in GDPR.
processing
“processing” as defined in GDPR.
controller
“controller” as defined in GDPR.
This Privacy Policy shall be applied to the processing of the personal data of the Users in relation to the Service that shall be governed by the Applicable Privacy laws.
If any User under the age of 16 uses the Service, it shall make sure to obtain the guardian’s consent to this Privacy Policy or to give the consent to this Privacy Policy under the guardian’s permission thereto.
The Controller for the processing of the personal data shall be the company Wellness Booths whose contact details are as follows.
Wellness Booths
9 Deerhurst Road
Coventry
UK
a. Email address
b. User name and password
c. Native language and language that the User is interested in
d. Countries that the User is familiar with and those that the User is interested in
e. Profile photo
f. Access log
g. Device information
h. Cookie information
i. IP address
a. When the User subscribes for the Service
b. When the User otherwise use the Service
a. Performance of contract, or response to requests of Users prior to executing contract Lugga may process the personal data of the User entering into a contract regarding use of the application, for the purpose of performing the contract. Lugga may also process the personal data of the User prior to entering into such contract, for the purpose of taking steps in response to the Users requests.
b. Communication
Lugga may use the personal data for the purpose of (i) communication regarding the Service, (ii) notification of information important for the User’s account and/or use of the application, and (iii) responding to complaints. If the User makes an account for the Service, Lugga saves relevant personal data so that the User is not required to enter the personal data each time. Such processing of the personal data is necessary for performance of contracts and/or legitimate interests pursued by the Lugga, namely, for performing normal operations.
c. Marketing
If the Lugga contacts the User by email for the purpose of marketing (including announcement and implementation of campaigns), Lugga shall obtain the User’s prior consent. At any time the User may require the termination of the distribution of such email to the User. Such processing of personal data is (i) necessary for legitimate interests pursued by Lugga, namely, to communicate with the User and provide products or services, or (ii) based on the User’s prior consent.
d. Improvement of services Lugga may conduct a questionnaire survey to Users and use the personal data of the Users obtained through the questionnaire survey. Such processing of the personal data is necessary for legitimate interests pursued by Lugga, namely, for improvement, etc. of services of the Company.
e. Customer Service If the User uses a customer service, the Lugga may use the personal data of the User for providing the customer service. Such processing of the personal data is necessary for performance of contracts and/or legitimate interests pursued by Lugga, namely, for performing the Lugga’s normal operation.
Lugga may provide the personal data of the Users to the following parties, to the extent necessary for pursuing the purpose of processing. As set forth in Section 8.2, such third parties may include parties residing or located in countries outside EU.
(1) Accountants, lawyers and other professional advisers
(2) Providers of the services related to the Service, including, without limitation, data storage, maintenance and payment service
Lugga shall store the personal data of the Users to the extent necessary for the purpose of processing thereof, and delete the personal data when the storage becomes unnecessary for such purpose.
Cookies or similar technologies may be used in Lugga’s service. Such technologies help the Lugga to recognise the status of use of Lugga’s service, etc. and contribute to improvement of the service. When a User intends to disable cookies, the User may disable cookies by changing the web browser’s settings. Please note that when cookies are disabled, a part of the service may be unavailable.
(1) Access to personal data
(2) Modification of personal data
(3) Deletion of personal data
(4) Restriction on processing of personal data
(5) Objection to processing
(6) Exercise of right to data portability
(1) Document for identification of the User as specified by Lugga
(2) Document for identification of the representative of the User as specified by Lugga
For the processing of the personal data based on the User’s consent, the User shall have the right to withdraw the consent for the personal data at any time.
In addition to the aforementioned rights, the User may lodge a complaint with a supervisory authority at any time. However, Lugga appreciates a notification to Lugga prior to contacting the supervisory authority, so that the Lugga may have the opportunity to respond to the complaint of the User.
Since the personal data to be provided by the User are necessary for Lugga to provide the Service, the Service may be unavailable to the User that does not provide the data.
For questions or complaints, or for the exercise of the rights under Sections 11 and 12, please contact the following contact addresses.
Email address: admin@luggalanguages.com