LINGOTUNE PRIVACY POLICY

Date of Last Revision: 20 November, 2025

This Privacy Policy describes how Lingotune, Inc. ( “we”, “us”, or “our”) handles personal information that we collect through our websites on which a link to this Privacy Policy is displayed, through our marketing initiatives, when you apply for a job with us, and in connection with other interactions with you (collectively, the “Service” or “Services”).

Applicability of this Privacy Policy

Personal information we collect

Information you provide to us:

• Contact information, such as your first and last name and email address.
• Account information, such as your profile photo and other optional information you choose to include in your profile.
• Audio information, such as your audio recordings when using our Services to practice your language learning skills and other audio-based recording content that you provide to us.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Marketing information, such as your preferences for receiving our communications, and details about how you engage with our communications.
• Payment Information such billing details such as credit card information, banking information, and billing address needed if you sign up for a paid subscription. Your payment information, such as your payment method (valid credit card number, type, expiration date or other financial information), is collected and stored by our third party payment processing provider.  The use and storage of that information is governed by the payment processor’s applicable privacy policy.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information you provide to us about others: Where you provide us with the personal information of third parties, such as your friends or other contacts via the Services, it is your responsibility to (1) inform them about our processing of their personal information in accordance with this Privacy Policy and (2) confirm that they have given you their permission.

Information we obtain from third parties:

• Third-party login information. When you link, connect, or log in to our Services with a third-party service (e.g., Google, Apple, etc.), you may direct the service to send us information controlled by that service or as authorized by you via your privacy settings on that service.
• Social media information. We may maintain pages on social media platforms, such as Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with personal information about you through the platform, and we will treat such information in accordance with this Privacy Policy.
• Other sources. We may obtain personal information from other third parties, such as marketing partners, publicly-available sources, and data providers.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interactions over time with our website, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Email open/click information. We may use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email that we may send to you.

We use the following tools for automatic data collection:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand website user activity and patterns. For example, Google Analytics collects information about how users use our website, which we then use to compile reports that disclose trends without identifying individual visitors, and help us improve our website. For more information on Google Analytics, click here.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information

Providing our Services. We use personal information to operate, maintain, and provide you with our Services.

To communicate with you. We use personal information to respond to your requests, provide customer support, and otherwise communicate with you about our Services, including by sending announcements, surveys, updates, security alerts, and support and administrative messages.

To improve, monitor, and personalize our Services. We use personal information to improve our Services, including by understanding your needs and interests, and personalizing your experience with the Services and our communications.

For research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We may use this data and disclose it to third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Direct marketing. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, newsletters, and updates on news and events. You may opt out of our marketing emails as described in the “Opt out of marketing communications” section below.

For interest-based advertising. We may engage advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information (including the automatically-collected data described above) about your interactions over time across our website, our communications, and other online services, and use that information to serve online ads that they think will interest you.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend our company against legal claims or disputes, including to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
• Audit our internal processes for compliance with legal and contractual requirements and internal policies.
• Enforce the terms and conditions that govern our website.
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How we disclose your personal information

Service providers. We may disclose your personal information to third party companies and individuals that provide services on our behalf or help us operate our Services (such as lawyers, bankers, auditors, insurers, customer support, artificial intelligence, hosting, analytics, email delivery, marketing, and database management). We do not allow such third party providers of artificial intelligence services to use your personal information to develop, improve, train, or provide their technologies for the benefit of their other customers.

Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Advertising partners. We may disclose your personal information to third party advertising companies, including for the interest-based advertising purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Other third parties at your direction or with your consent.

Your choices

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions contained in the marketing communication we send you. You may continue to receive service-related and other non-marketing emails.

Limit online tracking. There are a number of ways to limit online tracking, which we have summarized below. Please note that these tools are not associated with us and we cannot guarantee that they work as their providers advertise them:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:

• Digital Advertising Alliance for Websites: optout.aboutads.info and https://www.aboutads.info/appchoices (for mobile opt outs);
• Network Advertising Initiative: optout.networkadvertising.org  

• Platform Opt-Outs. You can also use the opt-out features offered by third-party advertising platforms, such as:

• LinkedIn opt-out
• Google opt-out
• Facebook 

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other sites, mobile applications and services

Our website may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and disclosure of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Retention of personal information

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Job applicants

When you apply for one of our open positions, we collect the information that you provide in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or that you may provide during the interview process. This may also include demographic or diversity information that you voluntarily provide. We may also conduct background checks and receive related information. We also collect personal information from other sources where relevant for your application, such as employment research firms, recruiters, identity verification services, and information that you make publicly available on websites or social media platforms (for example, LinkedIn).

Throughout the recruitment process, we may supplement your personal information in connection with the assessment of your application. For example, we may record the views of those considering your application about your suitability for the role for which you have applied and retain interview notes. If you accept an offer from us, your personal information will be incorporated into and used as part of your employee record.

We use applicants' information to facilitate our recruitment activities, process employment applications and personalize candidate communication, including evaluating candidates and monitoring recruitment statistics. We also use successful applicants' information to administer the employment relationship. We may also use and disclose applicants' information to improve our Services and for the compliance and protection purposes described above.

Children

Our website is not intended for use by children under 13 years of age. If we learn that we have collected personal information through the website from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website.

How to contact us

Please direct any questions or comments about this Policy or our privacy practices to founders@lingotune.ai