Legal
Privacy Policy
(International Version)
Last updated: 01.09.2026
1. Scope of this Privacy Policy
This Privacy Policy applies to Lingualeo users worldwide, except users whose personal data processing is governed by a separate Privacy Policy applicable in the Russian Federation. Personal data of users located in the Russian Federation is processed in accordance with a separate Privacy Policy governed by Russian law.
The Russian-language Privacy Policy applicable to such users is available at: https://lingualeo.com/ru/blog/polozhenie-o-zashhite-personalnyih-dannyih/
This Privacy Policy describes how EDTECH TECHNOLOGY LLC (“Company”, “we”, “us”, “our”) collects, uses, stores, discloses, and protects personal data of users of the Lingualeo website and mobile applications (the “Services”).
Lingualeo is a language learning service, including the Lingualeo website, mobile applications, software, and related features operated by the Company.
EDTECH TECHNOLOGY LLC, a company registered in the Republic of Armenia (Registration No. 290.110.1311308, TIN: 02309255), acts as a Data Controller for all processing activities described in this Privacy Policy.
The Company operates the Lingualeo Services under an exclusive license agreement granting the right to use the LINGUALEO trademark and related intellectual property assets.
If you have any questions regarding this Privacy Policy or the processing of your personal data, please contact us at: support@lingualeo.com.
2. Categories of Data We Collect
Providing personal data is voluntary; however, some features of the Service may not be available without such data.
We may collect and process the following categories of personal data:
2.1. Data provided directly by the user
— Name, email address
— Password (hashed)
— Data from social login: Google, Facebook, Apple ID (public profile info, email)
— Language learning preferences and settings
2.2. Data related to usage of the Service
— Progress, exercises, content, learning history
— AI chat messages (if the user uses the Lingualeo GPT-powered chatbot)
— Search queries within the app
— Logs of interactions with features
2.3. Technical data
— IP address
— Device identifiers (IDFA, GAID, Firebase ID)
— Browser type, OS version
— Location derived from IP (approximate, not precise)
2.4. Cookies and similar technologies
We use: necessary cookies, functional cookies, analytics cookies, advertising cookies. See Section 10 for more details.
2.5. Data from third-party analytics
For international users: Google Analytics, Firebase, AppsFlyer, Facebook Analytics.
For users located in certain regions: Yandex Metrica.
We do not store raw credit card data. Payment data is processed by trusted payment providers (Google Play, Apple App Store, Xsolla).
3. Processing of Data Related to AI Features (GPT Chat)
The Company provides an optional AI-powered chat feature within the Lingualeo Service using third-party LLM providers (e.g., OpenAI).
3.1. Data sent to AI provider
Only messages you explicitly enter into the AI chat interface are transmitted to the AI engine.
3.2. Explicit Consent Required
In accordance with Apple App Store Review Guidelines and international privacy standards:
— Users see a separate consent screen before the AI chat is activated.
— The consent screen explains what data is shared and for what purpose.
— The user must tap “Agree / Continue” to activate AI features.
— Consent can be withdrawn at any time (“Disable AI features”).
Without explicit permission, AI features remain disabled.
3.3. No training on user data
Data transmitted to the AI provider is not used to train public models and is handled in accordance with the provider’s data protection commitments.
4. Legal Bases for Processing (GDPR/UK GDPR)
We process personal data based on the following legal grounds:
| Purpose | Category of Data | Legal Basis |
|---|---|---|
| Account registration and Service delivery | Name, email, social login | Contract (Art. 6(1)(b)) |
| Learning progress tracking | Usage data | Contract |
| Analytics and service improvement | Analytics data, cookies | Legitimate interest (Art. 6(1)(f)) |
| AI Chat feature | User messages | Explicit consent (Art. 6(1)(a)) |
| Marketing communications | Email, consent prefs | Consent (Art. 6(1)(a)) |
| Payments | Transaction metadata | Contract |
5. Purposes of Processing
We use the data for:
— Creating and managing user accounts;
— Providing language learning functionality;
— Personalizing recommendations;
— AI-powered learning tools;
— Handling subscriptions and purchases;
— Analytics and statistical research
— Fraud prevention and security
— Marketing communications (with consent)
6. Processing of Children’s Data
Lingualeo may be used by users under the age of 16.
6.1. EU, UK, EEA
We require parental consent when:
— the user is under the applicable age of digital consent (13–16 depending on the country), and
— the user wants to access AI features or provide personal data.
6.2. COPPA (USA)
For users under 13 in the United States:
— We collect only necessary data
— We do not allow access to AI chat
— Additional parental verification is applied where required
7. Data Retention
We retain personal data according to these rules:
| Category | Retention Period |
|---|---|
| Account data | Until the account is deleted |
| Learning data | Until account deletion |
| AI chat logs | 30–90 days (depending on provider settings) |
| Analytics data | 24 months |
| Payment metadata | 7 years (legal obligations), but no card numbers stored |
| Cookies | According to cookie type (see Section 10) |
After expiration, data is deleted or anonymized.
8. Sharing of Personal Data
We may share data with:
8.1. Service providers (Processors)
Access to personal data is granted only to Company employees, contractors, and authorized service providers who require such access to perform their duties and ensure the proper functioning of the Service:
— Cloud hosting (AWS, GCP, Azure)
— Payment processors (Apple, Google, Xsolla (payment processing))
— Analytics services (Google Analytics, Firebase, AppsFlyer, Yandex Metrica)
— AI-technology providers (OpenAI or equivalent)
All processors act under a Data Processing Agreement (DPA).
8.2. Legal obligations
We may disclose personal data:
— when required by a court or law enforcement
— when necessary to protect rights or prevent fraud
We do not sell personal data.
9. International Data Transfers
We may transfer data outside the EU/EEA, including to the United States.
Transfers are made only if one of the following is in place:
— Standard Contractual Clauses (SCCs)
— EU/US Data Privacy Framework (where applicable)
— Additional technical/security safeguards
10. User Rights
Users have the following rights:
— Right of access
— Right to rectification
— Right to erasure (“right to be forgotten”)
— Right to restriction of processing
— Right to data portability
— Right to object
— Right to withdraw consent at any time
— Right to lodge a complaint with the competent data protection authority in your country of residence or with the relevant supervisory authority.
You may exercise your rights by contacting: privacy@lingualeo.com
11. Cookies and Tracking Technologies
We use:
— essential cookies (required for operation)
— functional cookies
— analytics cookies
— advertising cookies
Users can:
— accept or reject non-essential cookies
— change cookie preferences at any time
— disable cookies in browser settings
Some features may not function if cookies are disabled.
12. Account Deletion and Data Removal
Users may delete their account directly in the app or request deletion via: support@lingualeo.com
Upon deletion:
— data necessary for legal obligations is retained
— all other data is deleted or anonymized
When an account is deleted, all non-essential personal data is automatically removed unless its retention is required by applicable law.
13. Changes to the Privacy Policy
We may update this Policy from time to time.
The latest version will always be available at:
https://lingualeo.com/ru/blog/privacy-policy-en/
Material changes will be notified in-app or via email.