Privacy Policy
Last Updated: November 10, 2024
Welcome! This Privacy Policy explains how OOK Group S.R.L ("we" or "us") collects, uses, and shares your personal information while you use our AI application that allows you to chat in English and learn English ("Application").
We may make changes to this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we will notify you via email if we have your email address on record, or via a notice on the Application prior to the change becoming effective.
1. What kind of personal information does OOK Group S.R.L collect?
We aim to minimize how much personal information we collect from users when they use the Application.
"Advertising ID", which means the resettable and unique identifier associated with your mobile phone or tablet that is used by advertisers for ad tracking.
"Location Information", which means general information about the location from which you're using the Application (e.g. IP address, country, and city).
"Device Information", which means technical information about your Device. When we refer to Device Information, this means your Device ID, your internet service provider (ISP), your browser and browser plug-in types, operating system and operating system version, jailbreak information, network information, the brand and manufacturer of your Device, the language you've set for your Device, the version of the Application installed on your Device, and the name of your carrier.
When you register for an account on our Application, we will collect your name and email address to register you and create your user profile. We will also collect information about your age, native language, and interests to personalize the lessons and content provided to you through the Application.
Personal Information Purpose(s)
When You Use the Application
Name and email address – Registration When you create an account on our Application, we will collect your name and email address to register you and create your user profile.
Age, native language, and interests – Personalization When you create an account, we will also collect information about your age, native language, and interests to personalize the lessons and content provided to you through the Application.
Location Information, Device Information – Customer Support You have the option to contact our customer support team directly from the Application. When you do, we will collect and use this information to respond to your requests and/or comments.
Advertising IDs, Location Information, and Device Information – Analytics – for more information, please see Section 4. Advertising – for more information, please see Section 5.
2. Do third parties have access to my personal information?
Yes. Like most companies, we use tools from service providers to help us with various parts of our business ("Service Providers"), and depending on the service we need, these Service Providers may have access to your personal information. For example, we use a Service Provider's email software to manage our Newsletter subscriptions, and if you have given us your email address to subscribe to Newsletters, then your email address will be shared with that Service Provider. We also use Service Providers for hosting, customer support, and mobile analytics. For a list of the Service Providers who have access to your personal information, please contact us at [email protected].
We contractually require all Service Providers to treat your personal information as confidential information and to only use it for the services we need. However, we do not have direct control over how Service Providers use your personal information and we cannot guarantee that our Service Providers will use your personal information as required in our contract with them. For this reason, we are not responsible for our Service Providers' misuse of your personal information.
In addition to our Service Providers, our Ad Partners may also have access to your personal information. We've dedicated a separate section about advertising and our Ad Partners, so please check that out in Section 5. We may also share your personal information for our legitimate business and legal purposes as described in Section 8.
3. How long will OOK Group S.R.L keep my personal information?
How long we store your personal information will depend on the purpose that we originally collected it. We will not retain personal information for longer than is necessary for our business or for legal requirements.
4. How is my personal information used for analytics?
As an online business, it is important for us to know how users interact with our Application. We and our Service Providers will collect your Location Information, Device Information, and Advertising IDs so that we can deliver our Application services to our users, measure, analyze, and improve performance of the Application, and to continually update and develop our Application.
5. How is my personal information used for advertising?
A. Ad Partner Technologies
To help us keep our Application running, we show ads in our Application with the help of third-party advertising partners ("Ad Partners"). We integrate Ad Partners' technologies into our Application which are then used by the Ad Partners to determine what kind of ads to display to you.
i. Do Ad Partners Collect My Personal Information?
In order to show you ads that you might find interesting and/or relevant ("Targeted Ads"), Ad Partners collect and use your Advertising ID, Location Information, and Device Information. If location services are enabled in your Device settings, the Ad Partners may additionally collect your geolocation information. Because these Ad Partners' technologies control what kind of personal information is collected from your Device and how it is used, we encourage you to review their respective privacy policies. A list of our Ad Partners can be provided upon request.
ii. How to Opt-Out of Receiving Targeted Ads.
If you do not want to receive Targeted Ads on your mobile Device, your mobile Device may give you the option to opt-out of receiving Targeted Ads on all apps on your Device. On Android Devices, you may opt-out by enabling the "Opt out of Ads Personalization" setting. On iOS Devices, you may opt-out by enabling the "Limit Ad Tracking" setting. Please note that if you opt-out of receiving Targeted Ads, you will still receive contextual ads, which are non-targeted ads related to the content of the Application you are using.
B. Ads for the Application on Third-Party Websites and/or Apps
In addition to running ads in our Application, we also run ads to promote our Application in third-party websites and/or apps. When we run our own ads in third-party websites and/or apps, Service Providers help us optimize and measure performance of our ads and use their own tracking technologies to track Application installs and clicks and/or impressions of our ads. In some cases, we will share your hashed or anonymized Advertising ID with our Ad Partners so that the Ad Partner can help us market and promote our Application. In these cases, Ad Partners perform as OOK Group S.R.L's Service Providers and we contractually require such Ad Partners to only use your personal information on our behalf. If you wish to opt-out of your personal information being shared with Ad Partners in this way, please contact us at [email protected].
6. Children's personal information.
We do not knowingly collect children's personal information without parental consent, except as permitted under applicable laws such as the U.S. Children's Online Privacy Protection Act (COPPA) and the EU General Data Protection Regulation (GDPR). For example, OOK Group S.R.L, its Service Providers, and its Ad Partners may collect personal information, such as IP addresses and other persistent identifiers, from children under 16 strictly to support OOK Group S.R.L's internal operations and/or legitimate interests, such as analytics and to serve children with contextual ads. If you are a parent of a child using the Application, you may review or have your child's personal information deleted and refuse the further collection of his/her personal information by contacting us at [email protected]. Please contact us at [email protected] if you believe we are collecting a child's personal information in violation of COPPA or the GDPR and we will delete this information as quickly as possible. For a list of OOK Group S.R.L's Service Providers, please contact us at [email protected].
If we want to change how we use personal information collected from children, we will first notify you by either posting an update on the Application and you will be required to review, sign, and send to OOK Group S.R.L a consent form to approve how we will use your child's personal information.
7. Cookies and similar tracking technologies.
We and our Service Providers use cookies, local storage, e-tags, or similar technologies on the Application to conduct analytics as described in Section 4 above and to optimize the Application's functionality and performance.
8. Push notifications.
After downloading the Application, you will be asked to accept or refuse push notifications. If you accept push notifications, we will collect and use push notification tokens to send you Application-specific notifications on your mobile Device. You may disable push notifications at any time by going to your Device settings.
9. Sharing your personal information for business/legal reasons.
A. Business Transfers. As we continue to develop our business, we may reorganize as a business entity, acquire entities, subsidiaries, or business units, or enter into joint ventures with third-parties. In any of these types of transactions, any information you provide may be one of the transferred business assets (subject to any pre-existing privacy notice unless you consent otherwise). In the event that all or substantially all of our assets are acquired or we merge with a third-party, your information will likely be one of the transferred assets. You understand and agree that we reserve the right to transfer any information collected from you in the case of any such transfer. In such event, we will use reasonable efforts to notify you before information about you is transferred and becomes subject to a different privacy policy.
B. Legal. We may disclose information you provide to respond to subpoenas, court orders, requests from authorities, and other legal process, and to establish/exercise our legal rights. We may also disclose your information to defend against legal claims when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We may share your information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, and situations involving potential threats to the physical safety of any person, violations of our Terms of Use, or as otherwise required by law.
10. How do I access, manage, update, or delete my personal information?
Please submit a request to delete your personal information and stop any further collection of personal information to us at [email protected]. If you want to access, manage, or update the personal information that OOK Group S.R.L has collected about you, please contact us at [email protected].
11. For users in the European Union and Brazil.
A. Legal Basis for Processing. Our legal basis for collecting, using, and sharing your personal information will depend on the purpose for which we use your personal information. Typically, we will rely on the following legal bases for processing your personal information: (i) your consent; (ii) where our processing is in our legitimate interest or in the legitimate interest of our Ad Partners or Service Providers; or (iii) where our processing is necessary to perform a contract with you (e.g. to make the Application accessible to you). If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.
B. Your Personal Information Rights. If you would like to exercise your rights of access, rectification, erasure, restriction of processing, data portability, and/or your right to object to the processing of your personal information, please follow the instructions described in Section 10. If you would like to opt-out of your personal information being shared with our Ad Partners, please follow the instructions in Section 5(a)(ii).
C. Transfer of Personal Information Outside of the EU and Brazil. Because our Service Providers are located in countries outside of the European Union and Brazil, your personal information will be transferred to other countries that may not offer the same level of data protection as the laws of your country of residence. We rely on model contractual clauses for such transfers.
D. How to File Complaints. If you believe your rights under the GDPR have been violated, you may lodge a complaint with the supervisory authority of your country of residence. For contact information for your supervisory authority, please visit here.
12. OOK Group S.R.L's contact information.
If you have any questions about our Privacy Policy or about our use of your personal information, then you may contact us at:
OOK Group S.R.L
str. Pușkin 32, Chisinau, Moldova