Sololearn Privacy Policy

Last revised: April 4, 2024

We at Sololearn know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing our website(s) (including https://www.sololearn.com), products, services and applications (the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of Sololearn’s Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

What does this Privacy Policy cover?

This Privacy Policy defines what information we collect from you when you access or use Sololearn, Inc. (“our”, “we”, “us”) Services, how we use and protect it, with whom we share it, and what controls and rights you have over your information. We gather various types of information from our users, as explained in more detail below, and we use this information internally in connection with our Services, including to: personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some of your information with third parties, but only with your permission and consent, as described below.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT IS INCORPORATED IN THE TERMS OF USE FOR SOLOLEARN AND CONSTITUTES A LEGALLY BINDING CONTRACT BETWEEN YOU AND SOLOLEARN. YOUR ACCESS OR USE OF THE SOLOLEARN SERVICES IN ANY WAY MEANS THAT YOU AGREE TO ALL OF THESE TERMS, AND THESE TERMS WILL REMAIN IN EFFECT WHILE YOU ACCESS OR USE THE SERVICES. THESE TERMS APPLY TO ALL VISITORS, USERS, AND OTHERS WHO ACCESS OR USE THE SERVICES. IF YOU DISAGREE WITH ANY PART OF THESE TERMS, THEN YOU MAY NOT ACCESS OR USE THE SERVICES.

Will Sololearn ever change this Privacy Policy?

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. This policy is effective as of the date listed above. We will notify you if we make any material changes to this Privacy Policy by posting a notice on our website and the Sololearn application or by other means that are consistent with applicable law. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used.

What information does Sololearn collect?

Information You Provide to Us:

We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect information such as your name, age, email address, and third-party account credentials (for example, your log-in credentials for Facebook or Google). If you provide your third-party account credentials to us or otherwise sign in to the Services through a third party site or service, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy; for example, when you log-in through your Google account, we automatically receive your name and email address. Certain information may be required to register with us or to take advantage of some of our features.

We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses or email you about your use of the Services. Also, we may receive confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive marketing communications from us, you can unsubscribe our mailing list by clicking the link at the bottom of the email you have received, or by emailing us at data.privacy@sololearn.com (please use “Unsubscribe” in the subject line).

Information Collected Automatically:

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, general location, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.

Our advertising partners may also transmit cookies to your browser or device, when you click on ads that appear on the Services. Also, if you click on a link to a third-party website or service, a third party may also transmit cookies to you. From the moment you click on a link of a third party, the privacy and your information treatment is governed by the terms of the third party you visit. In any case, while we enable third parties to place their ads and offer their services through our Services, we ensure that those third parties have strong data protection procedures and systems in place. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services. You can turn off third party tracking cookies and manage your cookie setting using the cookie banner on our website and the settings on your mobile device.

When you interact with our AI playground within our AI courses or our AI chatbot Kodie, we transmit your content to OpenAI, L.L.C. or its affiliates, who provide the technology that powers Kodie and the AI playground. Please be aware that if you include personal information in your AI queries, your personal information will be transmitted to OpenAI. Your use of Kodie and the AI integrations in our AI courses, including the content you submit, is also governed by OpenAI’s privacy policy and other terms and conditions (https://openai.com/policies).

We may use this data we collect automatically, as described above, to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve our Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting and useful to as many users as possible.

Information Collected From Other Websites:

Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy.

How and Why Sololearn Uses Your Personal Information

We only use your personal information if we have a specific and proper reason for doing so. For example, we might use your personal information in order to comply with our legal and regulatory obligations, to provide the Services to you, to comply with your requests related to the Services, where you have given your consent, or for our legitimate interest or those of a third party (e.g., a business or commercial reason to use your information that is not overridden by your own rights and interests).

The table below provides examples of how we use (process) your personal information and our reasons for doing so:

How we may use your personal information	Our reasons
To provide the Services to you	For the performance of our agreement with you
To prevent and detect fraud against you or Sololearn	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Processing necessary to comply with professional, legal and regulatory obligations that apply to our business	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information; and to comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Updating and enhancing customer records	To comply with our legal and regulatory obligations; and for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Marketing our services and those of selected third parties to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

How will Sololearn share any of the Personal Information it receives?

We may share your information with third parties as described in this section:

Information that’s been anonymized

We may anonymize your information so that you are not identified as an individual and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

Advertisers

We allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.

We may deliver a file to you through the Services (known as a “web beacon”) from an ad network. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site. You may be able to opt-out of web beacon tracking conducted by third parties through our Services by adjusting the settings on your browser, using the cookie management banner on the website, or adjusting the privacy settings on your mobile device.

Analytics service providers

To support, develop, and enhance the Services, we use analytics services, including those provided by Fabric Technology (owned by Google Inc.), Facebook, Inc. and Google Inc. (collectively, “Analytics Services”) to analyze how you interact and engage with the Services so that we can learn and make enhancements to offer you a better experience. These Analytics Services use cookies, web beacons and/or other technologies to collect information about your use of the Services and other websites, and they may track your activity on the Services and other websites over time. Information collected by the Analytics Services may include your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. Information from Analytics Services may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver content targeted to your interests on our Services and other websites and better understand your online activity. Google Inc.’s (“Google”) ability to use and share information collected by Google Analytics about your use of the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. To learn more about how Google collects and processes data and the choices Google may offer to control these activities, you may visit: http://www.google.com/intl/en/policies/privacy/partners/

Third Party Businesses

In certain situations, businesses or third-party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). In case a third party business is associated with such a transaction or service, we will share your information with that third party business only to the extent that it is related to such transaction or service. While we have no control over the policies and practices of third party websites or businesses, we require those third parties to have strong and secure privacy and information protection systems in place. At the same time, if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

Service Providers

We employ hosting providers, payment processors, and other service provider companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. In such cases, we take measures to ensure these agents are bound by strict confidentiality obligations and do not have any right to use your information we share with them beyond what is necessary to assist us.

User Profiles and Submissions

Certain user profile information, including your name, location, and any video or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings allow you to limit the other users who can see your information in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your public user profile, along with any information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.

Business Transfers

We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, information could be one of the assets transferred to or acquired by a third party. Such transfer will be governed by strict confidentiality terms and protection of your information will be guarded to the extent possible.

Protection of Sololearn and Others

We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Sololearn, our employees, our users, or others.

Personal Information We Have Sold or Disclosed for a Business Purpose.

We do not sell your personal information to third parties.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., your name, postal address, Internet Protocol address, email address, or other similar identifiers);
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);

Is my Information secure?

Your account is protected by a password for your privacy and security. If you access your account via a third-party site or service, you may have additional or different sign-on protections via that third-party site or service. You must prevent unauthorized access to your account and information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

At Sololearn, we work hard to protect and safeguard your information to the extent possible. A number of technical measures and procedures aimed at preventing unauthorized access, destruction, loss, release and misuse are being implemented during our day to day activities. Among such measures are data anonymization and encryption, as viable and necessary, recurrent review of procedures and protection systems, restriction of access of the number of employees handling your information and binding those with strict confidentiality and legitimate use obligations. However, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

What Information can I access and what choices do I have?

Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:

name and password;
email address; and
user profile information, including images and videos you have uploaded to the site.

You may also request us to:

update and edit;
delete (see more on deletion below);
stop processing (see more on consent withdrawal below);
send you in machine readable format;
and transfer to a third party, if feasible,

your information by sending us an email at data.privacy@sololearn.com.

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records.

You may also request deactivation of your account by contacting us at data.privacy@sololearn.com. Some information may remain in our records after your deletion of such information from your account.

By using our Services you provide us with your consent to our use of your information per the terms of this Privacy Policy. At the same time you may withdraw your consent at any point and request us to stop processing your data, as indicated above. This notice, however, will not affect the legitimacy of our use and processing of your information during the period prior to the receipt of your consent withdrawal notice.

You may have additional rights regarding your personal information under various data laws, including the General Data Protection Regulation (GDPR), the Brazilian General Data Protection Law (LGPD), and the California Consumer Privacy Act (CCPA), and other national, state, and local data laws, certain of which are addressed below.

Where is my Personal Information Held?

Sololearn is based in the United States, and personal data collected by Sololearn worldwide (including within the European Economic Area) may be transferred to the United States for processing and storage. For example, we may import your personal data into the United States to fulfill our contractual obligations to you. By using the Services or submitting personal data to Sololearn, you consent to the transmission of your information outside your own country to be stored in the United States. We take steps to ensure that any such transfer complies with data protection law and that all personal information is secure, including, where appropriate, putting in place standard contractual clauses or implementing other lawful tools and processes for transferring personal information.

How long do you preserve my information?

The preservation period of your information depends on the type of information and the reasons why we gather it. In any case, when it is necessary to extend the preservation period for a longer time for the reasons described below, we ensure that your information is encrypted or anonymized, is used only in an aggregate manner, and does not directly identify you.

Information we collect when we register your account is retained while your account is active, unless you request us to delete the information and/or deactivate the account. However, we may continue to retain your information after deactivation for a reasonable timeframe to provide you with an enhanced service in case you choose to re-activate your account.

When we receive a request to delete your information, we will start removing it from your account. However, if you have shared information with your friends and third parties while using our Services that shared information will still be available on the Services for those with whom you had shared it.

We may also continue to preserve information we believe in good faith is necessary to retain to:

comply with laws and regulations and provide to law enforcement agencies; promote
research and development;
preserve our business records;
conduct our business operation.

Your rights under the General Data Protection Regulation (GDPR) and the Brazilian General Data Protection Law (LGPD).

If you reside in the European Economic Area (EEA), or in Brazil, you may have the following additional rights under the GDPR or the LGPD:

The right to access (i.e., the right to be provided with a copy of your personal information);
The right to rectification (i.e., the right to require us to correct any mistakes in your personal information);
The right to be forgotten (i.e., the right to require us to delete your personal information – in certain situations);
The right to restriction of processing (i.e., the right to require us to restrict processing of your personal information – in certain circumstances, e.g., if you contest the accuracy of the data);
The right to data portability (i.e., the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations);
The right to object (e.g., the right to object to your personal information being used for direct marketing, and in certain other situations, to object to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests);
The right to withdraw consent (i.e., where processing is based on your consent, you have the right to withdraw that consent – without affecting the lawfulness of processing based on consent before its withdrawal);
The right to information regarding consent (i.e., to obtain information about the possibility or providing or denying your consent and the consequences of such consent or denial of consent); and
The right not to be subject to automated individual decision-making (i.e., the right not to be subjected to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you).

We will not discriminate against you if you choose to exercise any of these rights. You can exercise your rights under the GDPR or the LGPD by contacting us at data.privacy@sololearn.com (please use “GDPR” or “LGPD” in the subject line as applicable).

LGPD Data Protection Officer: data.privacy@sololearn.com

The GDPR also gives individuals in the EEA the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. You also have the right to lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies.

Your rights under the California Consumer Privacy Act (CCPA) and other U.S. state consumer privacy laws.

Consumers in certain U.S. states have the right to request any of the following information from us regarding personal information collected about you during the preceding 12 months:

The categories of personal information collected about you.
The categories of sources from which the personal information is collected.
The business or commercial purpose for collecting or selling personal information.
The categories of third parties with whom we share personal information, if any.
The specific personal information collected about you. For personal information sold or disclosed to a third party for a business purpose, you have a right to know the categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and the categories of personal information that we disclosed about you for a business purpose.

We will provide this information free of charge up to two (2) times in any twelve (12) month period within 45 days of receiving your verifiable request (including verification of your identity and your residency), subject to delays and exclusions permitted by law. Specific personal information about you or your account that is categorized as sensitive or confidential may be redacted.

As a resident of certain U.S. states, you have the right to request that we delete any personal information that we have collected about you. We will honor this request subject to the range of exclusions permitted by law. For example, we are not required to delete personal information if it is necessary to complete a transaction or reasonably used for an ongoing business relationship or if it is used internally in a lawful manner that is compatible with the context in which the consumer provided the information.

As a resident of certain U.S. states, you also have the right to opt out of the sale of your personal information to third parties. If you opt out, we will not sell or transfer your information to any third party except as otherwise authorized by law. We are permitted to transfer data to a service provider even if you opt out. A “service provider” is a business that agrees not to use your information for any purpose other than providing the services specified in our contract. We are also allowed to transfer your data to a third party where you direct the transfer or direct us to interact with the third party. For example, if you direct us to use a specific payment method to pay for your order, even if you have opted out, we will still transfer the data necessary to process your order.

We will not discriminate against you if you choose to exercise any of these rights. Residents of states with these types of privacy laws may exercise the rights described above by contacting us as follows:

By email: data.privacy@sololearn.com (please use “Privacy Request” in the subject line)

By form submission: www.sololearn.com/privacy-request

Please note that in order for a request to be verifiable, you may be required to confirm information that we have on file for you; including email address, phone numbers, full names, addresses and other information. We reserve the right to deny a consumer request if the identity of the requesting party cannot be confirmed.

Special Note on Treatment of Minors’ Information.

The Services are not intended for use by anyone under the age of 13. As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at info@sololearn.com.

How to Contact Us.

If you have any questions or concerns regarding our privacy policies or the information we hold about you, or to exercise your rights, including your rights under the GDPR, LGPD, or CCPA, please contact us at data.privacy@sololearn.com (please use “Data Privacy Rights” in the subject line).