User Data Policy
1.
General
At
Expert app, we care about your personal data, so we have prepared this Privacy
Policy to explain how we collect, use and share it.
This
Privacy Policy (“Privacy Policy”) details the personal data Expert app,
Inc. (“Expert app”, “we”, “us” or “our”) receives
about you, how we process it and your rights and obligations in relation to
your personal data. Expert app is the data controller for the purposes of the
General Data Protection Regulation (“GDPR”) and any relevant local
legislation (“Data Protection Laws”).
By
using or accessing the Service, you agree to the terms of this Privacy Policy.
Capitalized terms not defined here have the meanings set forth in the terms and
conditions (the “Terms and Conditions”), located at https://www.expertapp.org/TermsofUse.htm
. We may update our Privacy Policy to reflect changes to our information
practices. If we do this and the changes are material, we will post a notice
that we have made changes to this Privacy Policy on the Website for at least 7
days before the changes are made, and we will indicate the date these terms
were last revised at the bottom of the Privacy Policy. Any revisions to this
Privacy Policy will become effective at the end of that 7 day period.
If
you are an employee, worker or contractor of Expert app, the information about
how we handle your personal information is available in the Expert app internal
knowledge base. With respect to employees based in Europe, we are committed to
cooperating with European data protection authorities (DPAs) and comply with
the advice given by such authorities with regard to human resources data
transferred from Europe in the context of the employment relationship.
2.
Information We Collect
This
Privacy Policy explains how we collect, use and share your personal data.
Information you provide
Through
the registration process, you will provide us with your name, e-mail address
(or parent’s e-mail address), and age or date of birth. You will also provide
us with your payment transaction information if you choose to pay for Expert
app services.
Activity Data
When
you use the Service, you will submit information and content to your profile.
We will also generate data about your use of our Services including your
engagement in educational activities on the Service, or your sending of
messages and otherwise transmitting information to other users (“Activity
Data”). We also collect technical data about how you interact with our
Services.
When
you use Expert app in our app or on our website, we use a service named
FullStory to log your activity. This provides us with a set of data and a
session replay of your activity on Expert app in the form of a video. FullSory
captures and analyzes your usage data to help us make your Expert app
experience better.
We
only collect the data we need which means we don’t record:
o
Usernames
o
Names
o
Profile Images
o
Email addresses
o
Phone Number
o
Locations or bios on the Profile page
o
Passwords
We
do record the following data:
Usage Patterns
o
Clicks
o
Mouse movements
o
Scrolling
o
Typing
Tech Specs
o
Browser
o
Device type
o
Device ID
o
Operating system
o
Viewfinder size
o
Script errors
o
IP address
Navigation
o
Pages visited
o
Referrers
o
URL parameters
o
Session duration
Learning Activity
o
Session progress
o
Answers
Live Speaking Practice
When
you take a Live Speaking Lesson, we will use your computer's microphone throughout
the lesson to speak to your tutor. You also have the option of using your
camera to share your video with your tutor. Expert app records these audio and
video lessons and retains them until you close your Expert app account. Expert
app uses this data to help improve the quality of the lessons and for internal
research purposes.
Expert
app does not share any of your personal data with your tutor. You are
completely anonymous to them by default, and you can freely choose whether you
show them your video or tell them any personal details such as your name during
the conversation. Expert app only shares some basic skill level information
with the tutor, prior to your lesson, so they understand how best to speak to
you.
Speaking Challenges
Some
lessons involve you speaking into the app. To recognize speech your audio may
be sent to a third party provider such as Google, Apple, or Amazon Web
Services. We may ask you to allow Expert app to collect and analyze your speech
data to help us understand the effectiveness of our lessons, and to improve the
product. If you choose not to share your audio with us, or if we haven’t asked
you yet, then your audio will not be used in this way. Any audio you agree to
send to Expert app is anonymized when it reaches our servers to ensure that no
trace of your personal data remains attached to the audio.
Test Data
If
you register for the Expert app English Test, you will also provide us with
your gender, native language, secondary school, and self-reported test scores
for other exams. Each time you take a test you must also provide a photo of a
current, valid driver’s license, passport, or other government issued ID and
take a photo of your face to verify your identity (“Testing ID”).
When
you use the Service to take an examination in the Expert app English Test you
must provide access to your computer’s webcam and microphone. We will use them
to record you and your screen during the entire examination period (“Testing
Video”). From the collected data, Expert app and/or its trusted
third-parties may extract biometric signals for the use of identity
verification. While using the Expert app English Test, you will submit answers
to questions and other information as part of the testing and evaluation
process.
The
testing software will be installed onto your computer. During the test, the
testing software will monitor if additional applications or processes are
running on your computer, but will not open any applications or individual
files. Please close any other applications by exiting from them completely
prior to starting the test.
Additionally,
Expert app will be able to note if any peripherals are used during the test
(i.e. external devices attached to your computer), but will not have any
control or access to these peripherals. Please remove these before testing if
you do not wish to have their presence known.
Expert
app will not open network packets, but will have access to network usage
statistics and the volume of network traffic.
Third Party Data
We
also collect information about you from third parties.
Product Research and Development
We
may contact you to participate in product research activities. These may
include surveys, interviews, and other types of feedback sessions. When you
participate in these research activities, the information you provide will be
used to test, improve, and develop our products. We will record the video,
audio and text transcriptions of this feedback together with any additional
contact information you provide and will retain this data for two years.
Please
contact us at support@expertapp.org to:
o
Request more information about the research
activities you have volunteered for.
o
Opt out of being contacted for research
activities.
o
Request a copy of any research related data
you have provided to us.
3.
Cookies
When
you enter the Website, we collect your browser type and your IP address (a
unique address that identifies your computer on the Internet). When you use our
mobile Application, we collect your device type, your device ID, and your IP
address.
In
addition, we store certain information from your browser using
"cookies." A cookie is a piece of data stored on the user's computer
tied to information about the user. We use session ID cookies to confirm that
users are logged in. If you do not want information collected through the use
of cookies, there is a simple procedure in most browsers that allows you to
deny or accept the cookie feature; however, you should note that cookies may be
necessary to provide you certain features available on the Website (e.g.,
customized delivery of information).
4.
Information Obtained by Third Parties
To
support and enhance the Service, we work with a variety of third party advertising
networks, marketing analytics service providers and website analysis firms,
such as Google, Facebook, Oath, and Unity (collectively, “Third Party
Advertising Service Providers”). These Third Party Advertising Service
Providers collect and use personal data about your visits to and use of the
Website and mobile Application, as well as other websites in order to serve you
with advertisements and content tailored to meet your preferences and likely
interests or better understand ad effectiveness. Aggregate demographic and
interest data will also be used for market research purposes.
We
use Google Analytics which is a web analytics tool that helps us understand how
users engage with the Website. Like many services, Google Analytics uses
first-party cookies to track user interactions as in our case, where they are
used to collect information about how users use our site. This information is
used to compile reports and to help us improve our Website. The reports
disclose website trends without identifying individual visitors. You can opt
out of Google Analytics without affecting how you visit our site – for more
information on opting out of being tracked by Google Analytics across all
websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
In
addition, your mobile devices may offer settings that enable you to make
choices about the collection, use, or transfer of mobile app information for
online behavioral advertising (for example, Apple iOS’ Advertising ID and
Google Android’s Advertising ID). Please note that opting out does not prevent
the display of all advertisements to you.
5.
Use of information obtained by Expert
app
Expert
app may occasionally send you service related and product change announcements
through the general operation of the Service. We will send you reminder
notifications to support the Expert app teaching methodology by reinforcing the
learning cadence and help maintain your learning streak. We process your data
to help provide you with the Service and offer personalized features, to
understand and improve our Service and to keep our Service safe and secure.
Expert
app may use or share anonymous data collected through the Service, including
Activity Data without limitation. As a business, it is critical that we perform
our contract with you with the best service possible, and it is in our
legitimate interests to perform these processing functions and to enable
service e-mails by default to keep your data secure and provide our Service.
You may opt out of any non-essential service e-mails at any time.
We
may also use your contact information to send you notifications regarding new
services, offers and promotions offered by Expert app if you affirmatively consent
to receive such communications.
When
you register with Expert app, some of your information is made public and
available at various locations including expertapp.org. This will include the
data from your Expert app Profile and Account (Name, Location, Bio, Username,
User ID, Profile picture and Expert app Plus membership status); your followers
and the people you follow; and your learning progress (XP, Streak, Lingots,
Daily Progress, Languages being learned, progress level, Crowns, Skills,
Lessons undertaken, Lexemes and Strength). Tinycards decks you create are also
public by default, but can be made visible to only you or to people you have
shared a link with. Your Expert app account email address is not shown
publicly. Third party websites may be able to read, collect and use your public
information for their own purposes.
Profile
information is used by Expert app to be presented back to and edited by you
when you access the Service and to be presented to other users. In some cases,
other users may be able to supplement your profile, including by submitting
comments (which can be deleted by you). Expert app uses this information to
provide you with support, to send you essential notifications, to enforce our
terms, conditions and policies, to communicate with you, to administer the
Services, and for internal operations, including troubleshooting, data
analysis, testing, research, statistical, and survey purposes. Expert app’s
Terms and Conditions provide the contractual lawful basis for these processing
activities.
Expert app English Test
When
you take a test in the Expert app English Test, we will use your computer's camera
and microphone throughout the test to collect a Testing Video.
We
will process information in connection with the Expert app English Test
comprising given name(s), surname(s), date of birth, gender, native language,
country, secondary school, self-reported test scores for other exams,
application IDs, a picture or scan of a current, valid driver’s license,
passport or other government issued ID, your Testing ID, Testing Video,
biometric signals extracted from collected data, data about active software
processes, information on connected external peripherals, and volume of network
traffic, and answers to questions as part of the testing and evaluation process
in order:
o
To provide accurate testing results to Score
Recipient(s) (as defined below)
o
To compare your Testing ID to your Testing
Video to ensure that the person who registered for the examination (and whose
identity Expert app has validated) is the same person who took the examination.
In addition, this comparison may be carried out on biometric signals that have
been extracted from collected data.
o
To store and review the Testing Video
recording, the active software processes and the volume of network traffic to
validate that you took the examination without improper assistance
o
To evaluate your performance on the Expert app
English Test, to report results and to evaluate the usefulness, accuracy and
other aspects of the Expert app English Test
o
For our research team to validate and improve
the examination, in an anonymized format
o
To analyze audio recordings of verbal
responses to improve our ability to understand the spoken language
o
To share your Testing ID with your consent
upon initiation of a dispute by a Score Recipient
Expert
app’s Terms and Conditions provide the contractual lawful basis for these
English Test processing activities.
6.
Sharing your personal data with third
parties
Expert
app shares your personal data only when it is necessary to offer the Service,
legally required, or permitted by you.
We
will provide personal data to hosting providers such as Amazon Web Services,
search engine providers such as Google, analytics providers such as
Crashlytics.
These
data processors help us bring you the Service. For example, we may share your
information in order to detect where or how you encountered a bug when using
our mobile application. In connection with these operations, our service
providers will have access to personal data for a limited time. When we utilize
service providers for processing any personal data, we implement contractual
protections limiting the use of that personal data to the provision of services
to Expert app.
We
will be required to access and disclose personal data in response to lawful
requests, such as subpoenas or court orders, or in compliance with applicable
laws. Additionally, we will access and share account or other personal data
when we believe it is necessary to comply with law, to protect our interests or
property, to prevent fraud or other illegal activity perpetrated through the
Service or using the Expert app name, or to prevent imminent harm. This will
include accessing and sharing personal data with other companies, lawyers,
agents or government agencies.
Expert
app will share the complete and accurate results of Expert app English Tests
with such institutions, including universities, potential employers, or other
third parties, (collectively, “Score Recipients”) as specified when you
send your results after finishing a test or when you apply a coupon sponsored
by the Score Recipient before starting a test. These results will include your
test score, a video of the interview section of your test, and your written
responses to certain parts of the test. We will also share your full name, date
of birth, e-mail address, and the photo you take of yourself. We will never
share examination results with any party without your approval, except that
anonymized examination results will be used by Expert app and its partners to
improve the examination and for research and analysis. We will not share your
Testing ID with any Score Recipients, except with your consent upon initiation
of a dispute by a Score Recipient.
If
the ownership of all or substantially all of the Expert app business, or
individual business units or assets owned by Expert app that are related to the
Service, were to change, your personal data will be transferred to the new
owner. In any such transfer of information, your personal data would remain
subject to this section.
Expert
app will share aggregate or anonymous data collected through the Service,
including Activity Data, for purposes such as understanding or improving the
service.
7.
Data subject rights and data retention
You
also have the following rights in relation to the personal data we hold about
you, unless provided otherwise by local law:
o
To request access to, or erasure of, the
personal data we hold about you.
o
To request us to restrict the processing of
the personal data we hold about you.
o
To object to us processing personal data
relating to you.
o
Where you have given us consent to process
your personal data, you have the right to withdraw that consent at any time.
o
To export the personal data you have provided
to Expert app in a format that can be transferred electronically to a third
party.
o
To delete your account with Expert app by
following the instructions available through the Service.
Expert
app will retain your data until your account is deleted, after which point we
will retain anonymous data collected through the Service, including Activity
Data, which may be used by Expert app and shared with third parties in any
manner. Information associated with the Expert app English Test, including
examination results and your Testing Video, will be collectively deleted from
your Expert app account after five years have passed from the date you upload
your test, but anonymized examination data, including your examination results
and Testing Video, will be kept indefinitely by Expert app to improve the
examination and for research and analysis.
Please
note that some of these rights are not absolute. In some cases, we may refuse a
request to exercise particular rights if complying with it meant that we are no
longer able to meet our contractual obligation to provide you with particular
products and services. We will keep you informed as to the actions that we can
take when you make your request.
You
may also have the right to make a GDPR complaint to the relevant Supervisory
Authority. A list of EEA Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
and the UK here: https://ico.org.uk/global/contact-us/.
If you need further assistance regarding your rights, please contact us using
the contact information provided below and we will consider your request in
accordance with applicable law. In some cases our ability to uphold these
rights for you may depend upon our obligations to process personal information
for security, safety, fraud prevention reasons, compliance with regulatory or
legal requirements, or because processing is necessary to deliver the services
you have requested. Where this is the case, we will inform you of specific
details in response to your request.
8.
Third party websites and links
Please
note that you may have cookies placed on your computer by third party websites
that refer you to our Service. Although we do not share your personal data with
these third party websites unless it is reasonably necessary to offer the
Service, they may be able to link certain non-personally identifiable
information we transfer to them with personal data they previously collected
from you. Please review the privacy policies of each website you visit to
better understand their privacy practices. In addition, Expert app would like
to inform you that anytime you click on links (including advertising banners),
which take you to third party websites, you will be subject to the third
parties’ privacy policies.
Our
Services contain links to other sites operated by third parties. Expert app
does not control such other sites and is not responsible for their content,
their privacy policies, or their use of personal data, including any personal
or financial information collected by our third party payment processor to
process payments for in-app purchases. Expert app’s inclusion of such links
does not imply any endorsement of the content on such sites or of their owners
or operators except as disclosed on the Services. Any information submitted by
you directly to these third parties is subject to that third party’s privacy
policy.
9.
California privacy rights
Residents
of California have the right to:
o
Know what personal information we collect
about you and from where we collect it.
o
Access a copy of the personal information we
hold about you.
o
Understand how we process your personal
information and how it may be shared.
o
Opt out of having your personal information
shared with certain third parties.
To
make such a request, please send an email to support@expertapp.org.
10.
Children under age of digital consent
We
know that children deserve extra privacy protection. That’s why we treat child
users differently to ensure their parents are in control and we only collect
the bare minimum information we need to make Expert app work.
When
a user creates a Expert app account we collect their age and compare it to the
local standard of child online consent depending on the country they registered
in. We refer to users under this age as “child users”. Child users are
permitted to create a user account but we ask them to provide their parent’s
email address instead of their own. We also prevent child users from supplying
their own name because we don’t need that information.
After
registration we will send an email notifying the parent about Expert app’s
privacy and information practices regarding child users, including what personal
data we collect and how we use, share, and protect that personal data. The
email also explains how parents can request that Expert app access, change or
delete the personal data about their child.
Child
users receive the following special treatment:
o
Lessons are made age appropriate by removing
mature words like “beer” or “wine”.
o
Advertisements are set to family safe content.
o
The Profile page is hidden, preventing the
child from stating their name, location or bio.
o
Uploading an avatar photo is disabled.
o
Promotional emails are disabled.
o
Leaderboards are disabled.
o
Discussion forums are disabled.
o
The child’s profile is made private and hidden
from other users’ searches.
o
Other users are unable to follow the child.
o
The ability to follow other users or search
for other users is disabled.
o
The ability to send an invitation email is
disabled.
o
Finding friends on Facebook is disabled.
o
Social logins with Facebook, Google or Apple
are disabled.
o
Social follow buttons for Twitter, Facebook
and Instagram are disabled.
In
addition, all users under the age of 16 receive the following special
treatment:
o
Advertisements are set to non-personalised.
o
Third party behavioral tracking is disabled.
o
Third party analytics is disabled.
To
prevent restricted users from amending these features, the settings will be
hidden or grayed out. In the future, once we’re sure the user is old enough we
will automatically remove the restrictions, reset the settings to their
defaults and make the settings visible for them to configure how they choose.
With
regards to the Children's Online Privacy Protection Rule ("COPPA"),
Expert app only collects personal information from children under the age of 13
for the sole purpose of performing internal operations of the Service. If we
discover that we have unknowingly collected additional personal information
from these children we will delete it. If you believe this to be the case,
please contact us at support@expertapp.org.
11.
Links
The
Service may contain links to other websites. We are not responsible for the
privacy practices of other websites. We encourage users to be aware when they
leave the Service to read the privacy statements of other websites that collect
personally identifiable information. This Privacy Policy applies only to
information collected by Expert app via the Service.
12.
Information security
Expert
app has implemented administrative and technical safeguards it believes are
appropriate to protect the confidentiality, integrity and availability of your
personal data, Testing ID, User Photo, access credentials, and Expert app
English Test results. However, given sufficient resources, a determined
attacker could defeat those safeguards and may, as a result, gain access to the
data we seek to protect.
13.
Do Not Track
The
Service is not designed to respond to “do not track” signals sent by some
browsers.
14.
Contact Us
For
all data privacy inquiries and any questions or concerns you have about this
Privacy Policy, please contact our Data Protection Officer at support@expertapp.org
For
all support inquiries, please go to www.expertapp.org.org.
Last revised on
12th July, 2021