Last updated: 29 May 2023

This Privacy Policy outlines how we, We Languages, gather, utilize, and disclose information about you. This policy is relevant when you (i) access and use our website, (ii) make use of our Applications, or (iii) access and use our services linked or referenced to our We Languages Terms. Collectively, these are referred to as the "We Languages Platform". This Privacy Policy is established to meet our transparency obligations under the "General Data Protection Regulation" or "GDPR."

By downloading, accessing, using, and/or interacting with our We Languages Platform, you are agreeing to and expressly consenting to our collection, use, and disclosure of the information you provide as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Terms of Service available at we-languages.com/legal (our "We Language Terms of Service") and is subject to the provisions of the We Languages Terms.

Any capitalized terms (including "We Languages," "us," "we," and "our") that are used but not defined in this Privacy Policy have the meaning assigned to such terms in our We Languages Terms. If you have any concerns about providing information to us or the use of that information as described in this Privacy Policy, you should not use our We Languages Platform.

Modifications

In our constant pursuit to deliver innovative methods to help you achieve your language learning goals through our We Languages Platform, this Privacy Policy might undergo changes periodically. Thus, we encourage you to review it frequently. The 'last updated' date at the top of this document indicates when this Privacy Policy was last revised.

Should there be a requirement under applicable data protection laws to provide you with advanced notice or obtain your consent for any such changes, we will ensure to do so. You can determine when this Policy was last amended by referring to the "last updated" date displayed at the top of this policy.

Any updates or alterations to this Privacy Policy will replace all previous versions.

1. How We Collect Information

At We Languages, we gather information via two primary methods: (i) data you voluntarily provide to us; and (ii) data we obtain automatically as you utilize our platform. For residents of the European Economic Area (the "EEA"), we process your information based on one of the following legal grounds: (i) with your consent; (ii) if it serves a legitimate interest; (iii) if the processing is necessary for the performance of a contract with you; and (iv) if we must comply with a legal or regulatory obligation.

2. Information We Collect That You Choose To Provide To Us

We gather information that you voluntarily share with us. For instance, when you create an account, modify your user profile, engage with interactive features of the We Languages platform, subscribe to our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support, or otherwise communicate with us. The type of data we may collect includes your name, username, country of residence, phone number, email address, postal address, photograph, avatar, password, security questions and answers, details about the products you use, the information you provide in response to surveys about our products, the information you provide when seeking assistance from us, billing information, payment card details, account details, forum posts, comments, and any other contact or identifying information you choose to provide.

For your awareness, the Company has gathered the following categories of personal information about users over the past twelve (12) month period, both directly and through third parties:

  • Identifiers, such as real name, postal address, Internet Protocol address, account name, or other similar identifiers;
  • Audio, electronic, visual, thermal, olfactory, or other similar information from a living person;
  • Professional or employment-related information; and
  • Educational information.

3. What Information We Collect Automatically When You Use the We Languages Platform

We automatically collect certain types of information when you interact with the We Languages Platform. This includes:

Device Information: We collect specific information about the device you use to access our platform. This can include the model of your device, the operating system and its version, unique device identifiers, mobile network information, the country you access from, crash reports, request and referral URLs, and details about system activity.

Software Information: We collect data specific to the software you use on the We Languages Platform, such as the version of our software you have installed or use, any updates you've installed, and the presence of required plug-ins.

Use Information: We collect data about how you use the We Languages Platform. This can include the type of web browser you use, your preferred language, times of access, the pages you view, your overall activity, interactions with other users, your internet protocol (IP) address, and the page you visited before navigating to the We Languages Platform.

Information Collected by Cookies and Other Tracking Technologies: We use various technologies, including cookies, web beacons, Flash Cookies, and other tracking technologies, to collect information about your use of the We Languages Platform. Here's a bit more about these:

  • Cookies: Cookies are small data files stored on your hard drive or in your device's memory that help us improve the We Languages Platform and your experience. They allow us to see which areas and features of the We Languages Platform are popular and count visits. For more information about cookies, including how to disable them, please refer to Section 11 (Your Choices and Controls).
  • Web Beacons: We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in the We Languages Platform or in emails. They help us deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.

4. How We Use Your Information

We use the information we collect about you for several purposes:

Service Provision: We use your information to provide, maintain, and improve the We Languages Platform. This includes providing and delivering the products and/or services you order and sending you related information, such as confirmations and invoices.

Communication: We use your information to send you communications about products, services, offers, promotions, rewards, or events offered by us and other companies. We also send news and information we think will be of interest to you. This can also include technical notices, updates, security alerts, and support and administrative messages.

Customer Support: We use your information to respond to your comments, questions, and requests and to provide customer service.

Analysis and Personalization: We use your information to monitor and analyze trends, usage, and activities in connection with the We Languages Platform. We also use this information to personalize the We Languages Platform and provide advertisements, content, suggested connections, and features that match user profiles or activities.

Contests and Rewards: We use your information to process and deliver contest entries and rewards.

Combining Information: We may link or combine information we collect from you with information we receive from others to better understand your needs and provide you with better service.

Data Retention: We retain your data only for as long as necessary to provide the service you have requested. After that, we may keep your information for a variety of legitimate legal or business purposes. These could include periods mandated by law, contract, or similar obligations applicable to our business operations, periods necessary for preserving, resolving, defending, or enforcing our legal/contractual rights, or periods needed to maintain accurate business and financial records.

5. What Kinds of Information We Share

We share your personal information outside of the Company in certain circumstances:

With Your Consent: We will share personal information outside of the Company when we have your explicit consent, particularly for sensitive personal information.

Vendors and Service Providers: We share personal information with vendors, consultants, and other service providers who need access to such information to carry out work on our behalf. They must follow our instructions and comply with our Privacy Policy and other appropriate confidentiality and security measures.

Teachers of We Languages Platform: We share your personal information with teachers of the We Languages Platform to facilitate teaching services.

Other Users: Your personal information is shared with other users of the We Languages Platform in connection with its social features. For example, your username, profile picture, and other information may be visible to other users.

Legal Obligations and Safety: We may disclose your information in response to a request if we believe such disclosure is required by law, regulation, or legal process. We may also disclose your information to protect the rights, property, and safety of the Company or others.

Business Transfers: Subject to applicable laws, we may share your information in connection with a merger, sale of company assets, or acquisition of all or a portion of our business.

Your Direction: We may share your information with your consent or at your direction, including if we notify you through the We Languages Platform that the information you provide will be shared in a particular manner and you provide such information.

Over the past twelve months, we have disclosed the following categories of personal information about consumers to third parties or service providers for business purposes:

  1. Identifiers, such as Internet Protocol addresses or account names.
  2. Audio, electronic, visual, thermal, olfactory, or other similar information.
  3. Professional or employment-related information.
  4. Education information.
  5. Consumer profiles are based on inferences drawn from the above information.

Please note that we do not sell any personal information about consumers. We may share aggregated or de-identified information which cannot reasonably be used to identify you. In such cases, we undertake appropriate procedures to ensure the information does not identify you, and we contractually prohibit recipients of the data from re-identifying this information to associate it with you.

6. Ways You Might Share Your Information through the We Languages Platform

The We Languages Platform offers social sharing features and other integrated tools such as the Facebook or Twitter "Like" button. These tools allow you to share your activity on the We Languages Platform with other media and vice versa. The use of these features can lead to the sharing of information with your friends or the public, depending on the settings you establish with the entity providing the social sharing feature.

For example, if you choose to use a social sharing feature, your activity on the We Languages Platform could be posted on your profile on that social media platform, visible to your friends or followers. The information shared could include what courses you've taken, your progress, or other activity.

To fully understand the data that may be shared and how it is used, we recommend reviewing the privacy policies of the entities providing these social sharing features. They will provide more information about the purpose and scope of data collection and processing in connection with these features. Please be aware that when you interact with these features, you could be making some of your personal information visible to others, depending on your privacy settings with those entities.

7. How We Keep Your Information Safe

Your security is a priority for us. We employ a range of commercially reasonable security measures designed to safeguard the information we collect about you against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction.

These security measures encompass various practices, such as:

  • Storing your sensitive data on a secured server that's protected by a firewall.
  • Using Secure Socket Layer (SSL) technology to transmit sensitive information (such as a credit card number) that you provide when using the We Languages Platform. SSL is a standard security protocol for establishing encrypted links between a web server and a browser, ensuring that all communication that happens between a web server and browser(s) remains encrypted and hence private.

However, we must note that no security system can provide absolute certainty of protection. Despite our efforts, we cannot guarantee that your information will always remain free from unauthorized access by third parties. Factors beyond our control, such as unauthorized entry or use and hardware or software failure, could compromise the security of user information.

Your password plays a crucial role in our security system. It's your responsibility to keep your password confidential and not share it with anyone. If you suspect that your password has been compromised in any way, please change it immediately. Your vigilance in protecting your password helps enhance the overall security of your information on the We Languages Platform.

8. Where We Store Your Information

All the information we collect about you is stored and processed in Japan in accordance with the purposes outlined in this Privacy Policy. If you are a resident of the European Economic Area (EEA), it's important to note that we might transfer your information to relevant entities or third parties in jurisdictions outside the EEA.

Please understand that these countries outside the EEA may not have identical data protection laws to those in your jurisdiction. However, we want to reassure you that we have implemented appropriate safeguards and mechanisms to ensure the secure transfer of your information across borders outside the EEA. Our commitment to your data security remains steadfast, irrespective of where your information is stored or processed.

9. Our Policies Regarding Children

We Languages Platform is not designed for or directed towards children under the age of eighteen (18). We do not knowingly collect any personal information from children. If you are under the age of 18, please do not attempt to use the We Languages Platform or send any information about yourself to us.

If we become aware that we have inadvertently collected personal information from a child, we will take reasonable measures to promptly delete such information from our records. Parents who believe that we might have collected any information from or about a child can submit a request to delete such information. Please see Section 13 (Contact Us) for our contact information.

10. Your Choices and Controls

We are committed to providing you with meaningful choices about the information we collect, and that is why we provide you with the ability to control how we use your information. You can access, view, update, correct, delete, or port your personal data or update your subscription preferences by signing into your account and visiting "Account Settings".

Where we rely on your consent to collect and use information about you, you can withdraw this consent at any time. However, if you request the deletion of your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

Cookies: Most web browsers accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the We Languages Platform. For more information, please visit the NAI's opt-out page where you can learn more about NAI members who deliver tailored online ads and your choices to opt out of receiving them.

Push Notifications: We may send push notifications or "alerts" to your device to provide information regarding the We Languages Platform, service updates, promotional communications, and other related messages. You can deactivate these push notifications by changing your notification settings via your device.

Promotional Communications: You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt-out, we may still send you non-promotional messages, such as those about your account or our ongoing business relations, administrative confirmations, order confirmations, important updates regarding the We Languages Platform, and notices about changes to this Privacy Policy and our We Languages Terms.

11. How We Respond to Do Not Track Signals

Currently, We Languages does not respond to Do Not Track (DNT) signals. DNT is a privacy preference that users can set in specific web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, because of the varying ways websites interpret the DNT signal, it is often unclear whether users intend for these signals to be transmitted or whether they are even aware of them. Therefore, we currently do not alter our data collection and usage practices upon receiving such signals. Nevertheless, you have options to control or limit how we and other websites collect and use your information. For instance, you can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

12. Contact Us

If you have any questions, concerns, or comments about our Privacy Policy, you can reach us through the following methods:

Customer Support

We are committed to working with you to resolve any privacy concerns fairly.

13. Right to Contact a Data Protection Authority

Should you feel that your privacy rights have been violated or that We Languages has not addressed your privacy-related concerns satisfactorily, you have the right to complain to your local Data Protection Authority or supervisory authority. For residents in the EEA, the contact information for these authorities can be found here. However, we recommend contacting us first so we may attempt to resolve any issues directly.

For inquiries regarding the management of personal information:
We Incorporated　Tobu Bldg.6F, 6-28-9 Jingumae, Shibuya-ku, Tokyo 150-0001 TEL: 050-5490-2495