Last updated on July 2nd, 2020.

Who we are and what this policy covers

The Service is operated by Ilini SARL (“Ilini”, “we”, “our” or “us”). We act as a data controller in relation to the personal information we collect and store about you.

Privacy protection is very important to us and we are committed to protecting you and respecting your privacy. This privacy policy describes how we collect, store, process, transfer, share and use data that identifies or is associated with you when providing our Service (hereinafter “personal information”).

We use cookies to store and access information whilst providing access to our site.

How we collect personal information 

We only collect information about you if we have a reason to do so — for example, to provide our Service, to communicate with you, or to make our Service better. We collect this information from three sources: if and when you provide information to us, automatically through operating our Service, and from outside sources. Let’s go over the information that we collect.

Information you provide to us

We collect information that you provide to us directly. Here are some examples:

• Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for an ilini.com account to provide an email address and password, along with a username or name and an indication of whether they are a teacher or a learner — and that’s it. You may provide us with more information — like a profile picture, your address, your interests and other information you want to share to customize our Service — but we don’t require that information to create an ilini.com account.
• Public profile information: If you have an individual Ilini account with us, we may offer you an option to create a public profile page, in which case you will decide which personal information you want to display on that page. For example, your username or a photo can be part of your public profile. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
• Payment and contact information: If you buy a subscription or any type of service from us, we’ll collect information to process those payments and contact you. If you buy something from us, you’ll provide additional personal and payment information like your name, credit card information, and contact information. We also keep a record of the purchases you’ve made. You may also provide us with financial details to set up a payments integration, like the email address for your Stripe or PayPal account or your bank account information. If you participate in our affiliate program, you’ll provide some additional information so we can process payments to you.
• Communications with us: You may also provide us with information when you send us an email or respond to an email from us, submit a request through our contact form, respond to surveys, communicate with our team about a support question, post a message in our public forum or in the comments sections. When you communicate with us via form, email, phone, comment, or otherwise, we store a copy of our communications.
• Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV as part of the application process.

Information We Collect Automatically

We also collect some information automatically:

• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. 
• Usage information: We collect information about your usage of our Services. For example, we collect information about the videos that you watch, the quizzes that you take, the words that you save in your vocabulary list, etc. We also collect information about what happens when you use our Service (e.g., page views, interactions with the various features of our Service) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
• Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. 
• Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Ilini uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Service, as well as track and understand email campaign effectiveness. 

Information We Collect from Other Sources

We may also get information about you from other sources. For example, if you create or log in to your ilini.com account through another service (like Google or Facebook), we’ll receive information from that service (e.g., your username, email and profile picture) via the authorization procedures for that service. The information we receive depends on which services you use or authorize and what options are available.

We may link or combine the personal information we collect about you, the information we collect automatically and the information we collect from other sources. This allows us to provide you with a personalised experience regardless of how you interact with us.

We may anonymise and aggregate any of the information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and features.

Why and how we use personal information

Purposes for Using Information

We use information about you for the purposes listed below:

• To provide our Services. For example, to set up and maintain your account, provide customer service, process payments and orders, and verify user information.
• To customize the user experience. For example, to personalize your experience by serving you relevant notifications for our Services, recommending videos or providing personal vocabulary lists.
• To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
• To ensure quality, maintain safety, and improve our Services. For example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them learn languages more efficiently or make our Services easier to use.
• To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users, like those who have a particular plan with us or have been users for a certain length of time, advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a paid plan after receiving a marketing message), and understanding and forecasting user retention.
• To communicate with you, if you opt in for such communications. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Ilini. If you have opted in but later decide that you don’t want to hear from us anymore, you can opt out at any time. (If you opt out, we’ll still send you important updates relating to your account.)
• To recruit and hire new team members. For example, by evaluating job applicants and communicating with them.

Legal Bases for Collecting and Using Information

A note here about our legal grounds for processing information about you under EU data protection laws. Our use of your information is based on the grounds that: 

• The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or 
• The use is necessary for compliance with a legal obligation; or 
• The use is necessary in order to protect your vital interests or those of another person; or
• We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or 
• You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on.

Sharing Information

How We Share Information

We do not sell our users' data. We aren't a data broker, we don't sell your personal information to data brokers, and we don't sell your information to other companies that want to spam you with marketing emails. 

We may share your personal information with the following parties, in limited circumstances, with appropriate safeguards on your privacy and in accordance with the uses listed in the previous section:

• Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us. This includes vendors that help us provide our Services to you, like Stripe, a payment provider that processes your credit and debit card information, IT infrastructure, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you; those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); or other third-party tools that help us manage operations.Other vendors are listed in our more specific policies.
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request. 
• To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Ilini, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
• Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Ilini goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
• With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so, like when you connected your site to a social media service.
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.

Information Shared Publicly

Information that individual Ilini users choose to make public is — you guessed it — disclosed publicly. That means information like your public profile, comments, other content that you make public on Ilini. Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share publicly.

Marketing

We may occasionally send you emails with information about our products and services. We may also send you push notifications if you opt in for such notifications. For some marketing messages we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

We will only send marketing messages to you if you have given us your consent to do so. We will not send marketing messages to school pupils using our Service for schools and organizations. We will only send marketing messages to users of our Service for individuals or to users of our Service for schools and organizations that have a designated “teacher” account. We will ask you if you would like to receive these messages when we first collect your contact details. You can also change your marketing preference at a later date by clicking on the unsubscribe link at the bottom of marketing emails or through your account settings page. You can also change your push notification preferences from your account settings page.

If you receive marketing from us through other channels e.g. post or by phone, and you no longer want to receive such messages, you can tell us to stop marketing to you by post or phone marketing messages by using our contact details at the end of this privacy policy.

Note that if you do opt-out of or do not grant consent to receiving marketing messages from Ilini, we may still send you non-marketing messages, such as communications relating to the provision of our Service.

You can also let us know at any time that you do not wish to receive marketing anymore by sending an email to us at support@ilini.com. You may also be able to unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on "How and Why We Use Information" — and we’re not legally required to keep it.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks. 

We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

Choices

You have several choices available when it comes to information about you:

• Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
• Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
• Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Services. You can close your account through your account settings or by sending us an email at support@ilini.com.  Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

International transfers of personal data

The information about you that we process when you use the Services in the EU may be used, stored, and/or accessed outside of the jurisdiction you are in where we and our third party service providers have operations. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the European Economic Area (EEA), we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:

• In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
• In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Our policy towards children

Our Service for individual users is not directed to persons under the age of 13. We do not knowingly collect personal information from children under 13. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

Our Service for schools and organizations may be used by children under 13, but only with the prior consent of their parent or their school, as permitted by the Children’s Online Privacy Protection Act (COPPA). If Ilini collects information from children under 13 through its Service for schools and organizations, Ilini will collect, use, share and store such data only for the purposes of providing services to the student as defined in our agreement with the school. Schools that do want to provide children under 13 access to the Service must notify Ilini when entering into an agreement with us, so that we can take all necessary measures.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (the “GDPR”), you may have specific rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data; and
• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:

• Identifiers (like your name, contact information, and device and online identifiers);
• Commercial information (your billing information and purchase history, for example);
• Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
• Internet or other electronic network activity information (such as your usage of our Services);
• Geolocation data (such as your location based on your IP address);
• Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
• Professional or employment-related information (for example your job as a language teacher if you create a teacher account); and
• Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the Information We Collect section above. We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section. If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

• Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
• Request deletion of personal information we collect or maintain;
• Opt out of any sale of personal information; and
• Not receive discriminatory treatment for exercising your rights under the CCPA.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to the bottom of this page to find out how to reach us. When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

Cookies

Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as “first party cookies”), or by third parties, such as those who serve content or provide advertising or analytics services on the website (“third party cookies”).

Both websites and HTML emails may also contain other tracking technologies such as “web beacons” or “pixels.” These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.

How we use cookies

We use cookies for a number of different purposes. Some cookies are necessary for technical reasons, and some enable a personalized experience for both visitors and registered users. Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action (clicking the “like” or “follow” button on a post, for example).

Many of the cookies we use are only set if you are a registered ilini.com user (so you don’t have to log in every time, for example), while others are set whenever you visit one of our websites, irrespective of whether you have an account.

Types of Cookie

The table below explains the types of cookies we use on our websites and why we use them.

Controlling Cookies

Visitors may wish to restrict the use of cookies or completely prevent them from being set. Most browsers provide for ways to control cookie behavior such as the length of time they are stored – either through built-in functionality or by utilizing third party plugins. If you disable cookies, please be aware that some of the features of our service may not function correctly.

Browser settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.

• (a) Cookie settings in Internet Explorer
• (b) Cookie settings in Edge
• (c) Cookie settings in Firefox
• (d) Cookie settings in Chrome
• (e) Cookie settings in Safari web and iOS.

To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following sites:

• networkadvertising.org
• optout.aboutads.info 
• youradchoices.com
• youronlinechoices.eu
• allaboutcookies.org

On a mobile device, you may also be to adjust your settings to limit tracking.  

Links to third party websites

Our website may contain links to websites of our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

Privacy Policy Changes

Although most changes are likely to be minor, Ilini may change its Privacy Policy from time to time. Ilini encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (like adding a statement to our homepage or the Ilini Blog, or sending you a notification through email or your dashboard). Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Contact

Questions, comments and requests regarding this privacy policy are welcome and should be addressed to support@ilini.com.