At LingoCall we care about our users and visitors, and for the trust they have in us.

Introduction

LingoCall puts remote language services at your fingertips. Understanding how and why we use your information should be easy for you. Our Privacy Policy section provides you with up-to-date information about the data we collect and the use we make of it. We also want you to know something more about our concept of privacy.

Our privacy policy is based on these three main aspects:

When you use the LingoCall services, you trust us with your information. We are committed to not disappoint your trust. For this, the first thing we want to do is help you understand our privacy practices.

In this Privacy Policy, the terms Applications, LingoCall Apps, App or Apps refer to the set of iOS, Android, and web applications that make up the LingoCall platform through which we provide our services.

Users, exercising their right to protect their privacy, must communicate by email with LingoCall, to info@lingocall.com, which must be written in English or Spanish, to be duly processed by our staff.

This privacy policy describes the information we collect, how we use it, share it, and your choices regarding this information. We recommend that you read it along with our Privacy Policy Summary, which highlights the key points about our privacy practices (including the information we collect, when we collect it, and how we use it).

Last modified: July, 2021

Effective date: July 22, 2021

Data collection and applications

Ambit

SUMMARY

This policy is applicable to users of LingoCall services anywhere in the world, and includes users of applications (Apps), websites, tools, and other LingoCall services.

This policy describes how LingoCall collects and uses your personal information to provide its services. This policy is applicable to all users of our applications, websites, tools, and other services anywhere in the world. This policy applies specifically to:

Customers: users who request or receive the linguistic services provided by our associated interpreters / translators.

Associated interpreters / translators: Professional interpreters/translators who provide linguistic services, individually, through the LingoCall platform.

All people subject to this policy are called “users” for its purposes.

The practices described in this policy are subject to applicable laws in the places where we operate. This means that we only participate in the practices described in this policy in a specific country or region, if the laws of those places allow us to do it. Contact us if you have questions about our practices in your country or region.

Data controller

SUMMARY

LingoCall offers services to users all over the world. If you use our services, the data controller of your information is:

LingoCall S.A.

Costa Rica

Concepción Tres Ríos, Monserrat # 52

Questions, comments and complaints about LingoCall data practices can be sent to the LingoCall data protection office by email at info@lingocall.com

Information we collect

SUMMARY

LingoCall collects:

– Information you provide, such as when you create your LingoCall account.

– Information that is created when you use our services, such as information on the services you requested, language combinations, minutes of service, etc.

The following information is collected by LingoCall, or in its name:

1. Information provided by you

It can include:

– User Profile: We collect information when creating or updating your LingoCall account. This information may include your name, email address, country of residence, login name and password, payments or banking information (including related payment verification information), government tax identification numbers, or social security numbers. It also includes information on the languages that each interpreter handles, in the case of interpreter users.

– Background Verification Information: We may collect information about background verification if you register to use LingoCall’s services as an associate interpreter/translator. It may include information from your Curriculum Vitae, experience, and professional references of the interpreter/translator.

– Demographics: We may collect demographic information about you with methods such as user surveys, among others.

– User content: We may collect information that you send when contacting LingoCall’s customer service, providing ratings or qualification of the interpreters when using our services, or by contacting LingoCall in any other way.

2. Information created when using our services

It can include:

– Transaction information

We collect transaction data related to your use of the services, including information about the type of services you have requested or provided, details of the order, delivery information, date and time of service provided, the amount charged, the rendered or demanded minutes of service, and the payment method. On the other hand, if someone uses your promotional code, we will associate both names with each other.

– Usage information

We collect information about your interaction with our services. It includes information such as, the dates and times of access, characteristics of the applications or the pages displayed, about the blocking of the applications or other activity of the system, the type of browser, as well as the site of a third party, or the service that you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and other similar technologies that create and maintain unique identifiers. For more information about these technologies, see our Cookies Policy.

– Communication Data

We allow users to communicate with each other and with LingoCall through the applications of LingoCall (iOS, Android, and Web), strictly to facilitate and provide the service of linguistic interpretation, when the client user requests the service of an interpreter and he/she accepts the request of service and when the user invites the third person to participate in the video conference.

3. Information from other sources

This information may include:

– User comments, such as ratings or complaints.

– Users that provide information related to the recommendation programs.

– Users who request services for them or on their behalf.

– Users or third parties that provide information related to claims or disputes.

– LingoCall business partners through which you create or access your LingoCall account, as payment providers, social networking services, and IP telephony providers.

– Available public sources.

– Marketing service providers.

LingoCall may combine the information collected from those sources with other information you have.

How we use your information

SUMMARY

LingoCall collects and uses the information to enable the reliability and convenience of providing its remote language services. We also use the information collected to improve the security and protection of our users and services, to provide customer assistance for research and development purposes, to allow communications with users or between themselves but strictly through our platform, to offer promotions or contests, or anything regarding legal proceedings. LingoCall does not sell or share personal information to third parties for direct marketing purposes.

LingoCall uses the information collected for the following purposes, among others:

1. Provide services and features

LingoCall uses the information collected to offer, customize, maintain, and improve our products and services. This includes using the information to:

– Create and update your account.

– Verify your identity.

– Allow the provision of remote linguistic interpretation service on video conferences and other linguistic services. This includes the automatic processing of your information to activate the calculation of minutes of service and the fixed charge per connection.

– Process or facilitate payments for these services.

– To track the progress of provided or demanded services.

– Activate features that allow sharing information with other people, such as sharing the address of our website, or any of our blog posts on our website, on social networks, and other media.

– Activate features to customize the LingoCall account, specifically in the case of the interpreters/translators who personalize their account to define in which languages and which combinations they want to provide the remote linguistic services.

– Carry out the internal operations necessary to provide our services, including the solution of software and operation problems, data analysis, tests and investigations, as well as supervising and analyzing the trends of use and activity.

2. Protection and security

We use your data to help maintain the security and integrity of our services and users. This includes, for example:

– Selection of associated interpreters/translators before enabling them to provide their services through LingoCall and, subsequently, include reviews of background validations and experience, if permitted by law, to avoid rendering services by non- adequate interpreters/translators.

– We collect information on the qualifications received by the interpreters from the client users, in order to follow up on their performance, identify opportunities for improvement, and support them to enhance their performance and, in general terms, to optimize our quality assurance.

3. Customer assistance

LingoCall uses the information collected (including recordings of customer assistance calls, after notifying about them and receiving the corresponding consent) to help you when you contact our customer support services, for example, to:

– Send your questions to the appropriate customer support officer.

– Investigate and address any problems.

– Monitor and improve our customer service response.

4. Research and Development

We can use the collected information to perform tests, research, analysis, and product development. This allows us to improve and reinforce the security of our services, develop new features and products, and provide solutions for prices, services, and promotions related to our services.

5. Communications between users

LingoCall uses the collected information to allow communications between our users through the strict use of our platform and its defined communication features. For example, when the user shares the link to invite a third person to participate in the video conference.

6. Communications from LingoCall

LingoCall may use the collected information to contact you about products, services, promotions, studies, surveys, news, updates, and events. It can also use this information to promote and process contests and sweepstakes, to comply with the corresponding prizes, and to provide you with relevant announcements and contents about our services and those of our business partners. You can receive some of these communications based on your profile as a LingoCall user. These communications are made through our server or electronic newsletter systems. At any time, the user can request not to receive more notifications or newsletters, either by configuring the newsletter system to not receive any more messages, or by writing a request to info@lingocall.com.

It is important to clarify that if you choose not to receive any more messages, you can only do it for non-operational messages, that is, for those that are not related to the use of our services, such as promotional or marketing messages, for example.

7. Procedures and requirements

We may use the collected information to investigate or address lawsuits or disputes related to the use of the LingoCall services, or to the extent permitted by the current legislation, or as requested by regulatory agencies, governmental entities, or official investigations.

Cookies and third-party technologies

SUMMARY

LingoCall and its partners may, in some cases, use cookies and other identification technologies in applications, websites, emails, and online advertising for the purposes described in this policy.

Cookies are small text files stored in the browser or device by websites, applications, online media, and advertisements.

LingoCall uses cookies and similar technologies for purposes, such as:

– Authenticate users.

– Remember preferences and user settings.

– Determine the popularity of the content.

– Deliver and measure the effectiveness of advertising campaigns.

– Analyze the trend and traffic of its website and, in general, to understand the online behaviors and the interests of the people who interact with our services.

We can also allow others to provide audience measurement and analytics services for us, post on our behalf on the Internet, and track and report on the results of these ads. These entities may use cookies, web beacons, software development kits (SDKs), and other technologies used to identify the device used to visit our website and use our services, as well as to visit other sites and online services. Read our Cookies Summary for more information about the use of cookies and other technologies described in this section, including the options you have related to these technologies.

Exchange of information and disclosure

SUMMARY

Some of the products, services, and features of LingoCall require that we share information with other users if you request it. We may also share the information with our subsidiaries, and business partners for legal reasons in case of claims or disputes.

LingoCall may share the information we collect:

1. With other users

– For example, if you are a customer user, we can share your name with the interpreter at the time of providing the service.

– If you are an interpreter/translator, we may share information with clients about the previous assessments you have had in providing your services, including your name, and average rating provided by clients.

– Likewise, if you are a user customer, we may share information with the interpreters of previous assessments you have had when requesting services, including your name, and average rating provided by the interpreters.

2. On request

Share information with:

– Other people who request it. For example, when a client user wants to schedule a future meeting for a remote interpretation service for a specific event at a conference room.

– LingoCall business partners. For example, if you requested a service through an association or promotional offer made by a third party that is a partner of LingoCall, (websites we join to offer their users our services), LingoCall may share your information with this third party.

3. With the general public if you publish content in a public forum.

We love receiving information from our users, including through public forums such as LingoCall blogs, social networks, and certain features of our network. When communicating through these channels, the public can see these communications.

4. With the owner of the LingoCall accounts that you use.

If you use a profile that is associated with another person, we may share your information with the service owner of that profile. This happens, for example, if you are:

– A user customer that is part of a company or corporate client that has developed a partnership with LingoCall so that its employees can use the services of LingoCall.

5. With subsidiaries of LingoCall

We share information with our subsidiaries and affiliates to help us provide our services, or behavioral data processing, on our behalf. For example, LingoCall could have subsidiaries in several countries, at some point.

6. With the service providers and business partners of LingoCall

LingoCall can provide information to its suppliers, consultants, marketing partners, research companies, and other service providers or business partners. This may include, for example:

– Moderators and payment processors.

– Background validation providers (interpreters/translators only).

– Cloud storage providers.

– Marketing partners and marketing platform providers.

– Data analysis providers.

– Research partners, including those who conduct surveys or research projects in partnership with LingoCall or on behalf of LingoCall.

– Providers that assist LingoCall to improve the security and protection of their applications.

– Consultants, lawyers, accountants, and other professional service providers.

– Partners of associated interpreters.

7. For legal reasons or in the case of a dispute

LingoCall may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or when disclosure is necessary for security reasons or similar problems.

This includes sharing your information with legal authorities, government authorities, hospitals, judicial courts (if a hospital or judicial authority require it as a condition to operate or provide services to patients or persons in a certain hospital or court), or other third parties. It is necessary to enforce our Terms of Service, user agreements, or other policies, to protect the rights or property of LingoCall or the rights, safety, or property of third parties, or in the case of claims or disputes related to the use of our services. If you use another person’s credit card, the law may require us to share information with the holder of that credit card, including the information shared on the video call.

This also includes sharing your information with others in connection with, or during negotiations of any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or part of our business by another company.

8. With your consent

LingoCall may share your information in a way other than that described in this policy if we notify you and you accept it.

Elimination and retention of information

SUMMARY

LingoCall will keep the user profile and any other information for as long as you maintain your LingoCall account.

LingoCall will keep, for 7 years, any information regarding transactions, use, and any other type required by the regulations, taxes, insurance, or any other requirement in the places where it operates. After this period, LingoCall will delete or will make anonymous this information following the applicable laws.

If you withdraw your consent for the collection or use of personal information for optional features, such as the features used by our platform, LingoCall will eliminate such personal information; however, it is possible some LingoCall services cannot be provided.

Users can request the removal of their accounts at any time. After submitting this request, LingoCall will delete the information that is not necessary to save and restrict the access or use of any information that must be kept.

LingoCall needs the user’s profile information to provide their services and will keep it for as long as they have their LingoCall account.

LingoCall will keep certain information for a minimum of 7 years, including information on transactions, minutes of service per transaction, languages used in the service, and use required by regulations, taxes, insurance, or any other requirement in the places where it operates. Once such information is no longer necessary to provide LingoCall services, to allow customer assistance, to improve user experience or for any other operational purposes, LingoCall will take the necessary steps to prevent access to this information or its use for any purpose that does not fulfill these requirements, or for reasons of security, prevention, and detection of security and fraud problems.

You can request the deletion of your account as a user client or associated interpreter, at any time, by sending an email to info@lingocall.com, which must be written in English or Spanish.

After submitting this application, LingoCall removes information that should not be retained. In certain circumstances LingoCall will not be able to eliminate your account in case there is outstanding credit, or unresolved claims or disputes. Once the problem is solved, LingoCall will delete your account as described above.

LingoCall may also retain certain information if necessary for your legitimate business interests, such as fraud prevention, security improvement, and user protection. For example, if a user account is closed due to dangerous behavior or security-related incidents, at LingoCall, we may keep certain information about that account to prevent the same user from opening a new account in the future.

Special information for users of the European Union

SUMMARY

As of May 25, 2018, the processing of personal data of users in the European Union will be subject to the General Data Protection Regulation (GDPR).

In this section, we summarize the bases of LingoCall to process personal information according to the GDPR and the rights of users of the European Union concerning the management of personal information by LingoCall.

1. User rights in the European Union

If you are a LingoCall user in the European Union, you have the following rights regarding your personal information at LingoCall. To exercise these rights, consult the following sections or send your request to info@lingocall.com

Users outside the European Union can also request the explanation, correction, deletion, or copies of their personal data at info@lingocall.com

1. Explanations and copies of your data

– You have the right to request an explanation of the information that LingoCall has about you and how LingoCall uses it.

– You also have the right to receive a copy of the information that LingoCall collects about you, whether this information is collected based on consent or because you require the information to provide the services you request.

1. Correction

– If LingoCall has information about you that you consider is incorrect, you have the right to request its revision. For more information on the correction and request for correction of your information, see the section “Explanation, Copies and Correction” below.

1. Elimination

– Users can request the removal of their accounts at any time. Users can request deletion by sending an email to info@lingocall.com. We may retain certain personal information for legitimate business purposes under the provisions of the law.

– For more information on LingoCall’s disposal and conservation practices, see the “Deleting and Preserving Information” section above.

1. Objections and complaints

– Users of the European Union have the right to object to the processing of personal data by LingoCall, which includes cases for marketing purposes based on profiling or automated decision making. LingoCall can continue to process your information despite the objection per the provisions of the GDPR.

– Users of the European Union also have the right to file complaints about the management by LingoCall of personal information before the Dutch Data Protection Authority, Autoriteit Persoonsgegevens. Their contact information is as follows:

Autoriteit Persoonsgegevens

Postbus 93374

2509 AJ DEN HAAG

(+31) – (0)70 – 888 85 00

– You can also send questions, comments, or complaints to the Data Protection Officer of LingoCall by writing to info@lingocall.com.

2. Basics for data processing

The GDPR requires companies to process the personal data of European Union users on a specific legal basis. As described below, LingoCall processes the information of users from the European Union according to one or more of the foundations specified in the GDPR:

1. Processing is necessary to provide the services and functions that you request.

– LingoCall must collect and use certain information to provide its services. Among this information, it is included:

— User profile information: necessary to establish and maintain the account, in addition to verifying your identity, it allows communications about the provided services, orders, and accounts; therefore, you can make payments or receive income.

— Background check information: necessary to be able to authorize the interpreters to provide interpretation services through the LingoCall app.

— Information about the languages in which the interpreter provides his/her services: necessary to assign interpretation services demanded by the user’s clients.

— Transaction information, which must be generated and maintained for the use of LingoCall services.

— Usage information: necessary to maintain, optimize, and improve the services of LingoCall, including to determine, along with other information, incentives, to connect clients and interpreters, as well as calculate the costs of the interpretation services provided and the income of the interpreters.

– The collection and use of this information are necessary to use the LingoCall App.

1. Processing is necessary to protect the vital interests of our users or third parties.

– LingoCall can process personal information, which includes the disclosure of data to judicial authorities in case of threats to the safety of users or third parties.

1. Processing is necessary for the legitimate interests of LingoCall.

– LingoCall collects and uses personal information to the extent necessary to fulfill your legitimate interests. It includes the collection and use of information:

— To maintain and improve the safety of our users. For example, we collect background validation information (if the law allows it) to prevent dangerous users, in this case interpreters, from providing services through our apps. We also use personal information to restrict users who have engaged in inappropriate or dangerous behavior from using our services. For example, keeping information from blocked users to stop them from using LingoCall apps. We also use the information to avoid matching users and interpreters among those who may be at high risk of conflict (for example, because they have been the subject of previous complaints by other users).

— To avoid, detect, and combat fraud concerning the use of our services. For example, LingoCall uses the user’s profile information and payment methods to identify and avoid situations in which users attempt to defraud LingoCall or other users.

— To inform the judicial authorities about criminal acts or threats against public safety.

— To assist customers.

— To optimize our service and to develop new ones. It includes, for example, identification of the most demanded language combinations in the services of remote linguistic interpretation, recommendation of (new) functions, improvement of navigation and prices, assignment of interpreters.

— For research and analysis purposes. It includes, for example, analysis of usage trends to improve the user experience and the security of our services.

— For direct marketing purposes. It includes, for example, data analysis to identify trends and adapt marketing messages to the needs of the user.

— To ensure compliance with the LingoCall Terms of Service.

1. Processing is necessary for the legitimate interests of other persons or third parties.

– LingoCall collects and uses personal information to the extent necessary for the interests of other people or the general public. This includes sharing information related to legal or insurance claims, to protect the rights and safety of third parties.

– LingoCall may also process personal information when necessary for a substantial public interest, following the applicable laws.

1. The processing is necessary to comply with the legal obligations of LingoCall.

– LingoCall is subject to the legal requirements of the jurisdictions in which it operates regarding the collection, processing, disclosure, or preservation of your personal data. For example, LingoCall is subject to laws and regulations in many cities and countries that require that information about its defendant interpretation services to be collected and stored. This information must be stored for extended periods of time, and copies of such information could be provided to government authorities or other entities. LingoCall uses your information to comply with these laws to the extent that they apply to the use of the LingoCall apps.

– LingoCall may also share information with judicial authorities or requests from third parties as a result of legal proceedings.

1. Consent

– LingoCall may collect and use your information based on your consent. You can revoke your consent at any time. If you revoke your consent, you may not use any service or function that requires the collection or use of the information we have collected based on your consent.

– LingoCall is subject to consent concerning the collection and use of data that are necessary to improve the user experience, activate optional services or features, or communicate with you. If you are a user from the European Union, the following types of compilations or uses of data are made based on your consent.

— Name, e-mail, and valid payment method in the case of customer users.

— In the case of associated interpreters/translators: name, email, Paypal.com email address, bank details (bank account number where we must deposit your payments), and curriculum vitae.

— Notifications: Discounts and news.

– See the “Choice and Transparency” section below for more information on the use and collection of data, acceptance and non-acceptance, and the consequences of non-acceptance of the use of LingoCall apps.

– LingoCall may also collect personal information about you through voluntary surveys. Your responses to these surveys are collected based on consent and they will be deleted once they are no longer needed for the purposes for which they were collected.

Choice and Transparency

SUMMARY

LingoCall provides means for you to consult and control the information it collects, including through:

– Device permissions.

– User rating pages.

– Cancellation of marketing notifications.

You can also request that LingoCall provide explanations, copies, or corrections of your data.

1. DEVICE PERMISSIONS

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that cannot be accessed by the apps without giving consent. These platforms have different authorization systems to obtain consent. The iOS platform will notify you the first time that the LingoCall app wants to obtain permission to access certain types of data, and will ask you to allow it, or not. Android devices will notify you of the permissions that the LingoCall app requires before you use the app for the first time, and your use of the app will constitute your consent.

In the specific case of the LingoCall App, the platform asks users to allow the use of the camera, sound system, and microphone of the device to establish communication through remote video conference. It is important to highlight that if the user does not allow the use of these functionalities of the device, he/she will not be able to use the LingoCall services, given that these features of the device are essential for the provision of the service.

1. RATING CONSULTATION

After each video call, the user clients and the interpreters can value each other and comment on how the interpretation service has gone. This bidirectional system makes everyone responsible for their behavior. The registration helps create a respectful and safe environment for the users and for the interpreters.

The user’s assessment is available in the profile section of the App and the interpreter’s is in the configuration section.

1. EXPLANATIONS, COPIES, AND CORRECTIONS

You can request that LingoCall:

– Provide a detailed explanation of the information it has collected about you and how it uses this information.

– Request a copy of the information that LingoCall has collected about you.

– Request the correction of any information that LingoCall has collected about you that might be incorrect.

To make these requests, contact LingoCall at info@lingocall.com

You can also request the change or edition of your name, the telephone number, and the email address associated with your account by sending an email to info@lingocall.com. You can also check your history of requested services in the LingoCall App.

1. CANCELLATION OF MARKETING NOTIFICATIONS

You can cancel the reception of promotional emails from LingoCall at the email’s footer link. You can also cancel the reception of emails and other messages from LingoCall by following the instructions in these messages. Please note that if you cancel the subscription to marketing or promotional messages, we may continue to send non-promotional communications, such as operational messages related to the services requested (for example, receipts of your calls or information about your account).

Updates to this policy

SUMMARY

We may update this policy occasionally. If we make significant changes, we will notify you via email. Following the provisions of the applicable law, by using our services after receiving such notification, you will be accepting all policy updates.

We recommend that you periodically review this policy to obtain the most up-to-date information about our privacy practices. If you wish, we will also make available the previous versions of our privacy policies so that you can consult them.