Privacy Policy
Last Updated: May 17, 2026
This Privacy Policy describes the types of Personal Information (defined below) that Lingofonex may collect from all Users or that you may provide us when accessing and using our website and our iOS or Android mobile translation applications (collectively, the "Application"), which may be distributed under different names, brands, or storefront listings depending on the platform or marketplace, including Pakt Translator and Lingofonex. This Privacy Policy also describes our policies and procedures for the collection, use, maintenance, protection, and disclosure of your Personal Information when you access and use the Application, and informs you about your privacy rights and the choices you have with respect to your Personal Information. "Personal information" means any information that identifies, relates to, or could reasonably be linked with you or your household. For example, it could include your name, email address, records of products you have purchased, internet browsing history, geolocation data, and inferences from other personal information that could create a profile of your preferences and characteristics.
Please read this Privacy Policy carefully before accessing and using the Application to understand our policies and procedures regarding your Personal Information and how we will treat it.
Capitalized terms not otherwise defined below have the meaning given to them in our End User License Agreement.
Acceptance
By accessing and using our Application, you agree to the collection and use of your Personal Information according to this Privacy Policy. If you disagree with our policies, please do not download, access, or use the Application.
Updates
We reserve the right to modify this Privacy Policy anytime by posting an updated Privacy Policy on the Application. If we make changes, we will notify you by revising the date at the top of the policy. If we make any material changes, we may provide you with a notice on the Application. You are responsible for regularly reviewing this Privacy Policy, and your continued use of the Application after we make changes constitutes your acceptance of the updated Privacy Policy. If any modification is unacceptable to you, you shall cease using the Application. If you have any questions about this Privacy Policy or if you wish to exercise any of your rights under this Privacy Policy, you may contact us at info[at]lingofonex.com.
Applicability
The Application is designed with a privacy-first, on-device approach. Core functionality, including speech recognition, translation, text recognition, camera-based translation, and speech synthesis, is generally processed locally on your device to minimize the transmission and storage of User Content. However, certain operational, monetization-related, application-related, support-related, analytics-related, security-related, or advertising-related features of the Application may involve the transmission, processing, or storage of limited technical information, device information, usage information, diagnostic information, subscription status information, advertising identifiers, or related data by us or our third-party service providers, as further described in this Privacy Policy.
1. Personal Information We Collect About You
We may collect Personal Information from or about you in a variety of ways, including: (a) directly from you; (b) automatically through your access to or use of the Application; and (c) from third parties, service providers, App Distributors, business partners, or integrations associated with the Application.
The categories and types of Personal Information we collect may vary depending on how you access and use the Application, including the features you use, your device and Application settings, whether you use Free Access or Paid Features, and the third-party integrations or services enabled within the Application.
Personal Information We Collect Directly From You
While you use the Application, you may voluntarily provide us with certain Personal Information necessary to access Application features, communicate with us, request support, submit Feedback, or otherwise interact with us. The categories of Personal Information we may collect directly from you include:
Contact Information. Your name, email address, mailing address, phone number, or other contact information you choose to provide.
Business Information. Business name, website, business contact information, or related business details you voluntarily provide.
Device Permissions and Local Device Access. Depending on the features you use and the permissions you grant, the Application may access device features or information, such as your camera, microphone, photo library, speech recognition functionality, or local storage. Core translation-related processing is generally performed locally on your device, and we generally do not receive or store the related User Content unless you separately provide it to us, such as through support requests or Feedback submissions.
Communication and Support Information. Information contained in communications you send to us, including emails, support requests, Feedback submissions, customer service inquiries, attachments, screenshots, or other information you choose to provide.
Testimonials and Public Submissions. Testimonials, reviews, comments, survey responses, or other content you voluntarily submit to us or authorize us to publish.
Sensitive Personal Information
We do not intentionally request or require that you provide sensitive Personal Information, including, without limitation, information relating to financial account credentials, government-issued identification numbers, precise geolocation data, health information, biometric information, racial or ethnic origin, religious beliefs, sexual orientation, citizenship or immigration status, union membership, criminal history, or other information considered sensitive under applicable law. You should not submit, upload, transmit, share, or otherwise provide sensitive Personal Information through the Application or in communications with us.
We cannot control the information, content, materials, recordings, screenshots, images, attachments, Translations, support requests, Feedback, or other data that Users voluntarily choose to submit, upload, transmit, share, or otherwise provide through the Application or in communications with us. As a result, certain User Content or support-related materials may contain sensitive Personal Information. If and to the extent we have access to sensitive Personal Information that is not reasonably necessary for the operation, support, security, or legal compliance of the Application, we will use commercially reasonable efforts to delete such information in accordance with applicable law and our data retention practices.
Information We Automatically Collect From You
When you access or use the Application, our service providers and we may automatically collect certain technical, device, usage, analytics, and diagnostic information relating to your use of the Application. This information may include:
Device information, including device type, hardware model, operating system, operating system version, device language, mobile carrier, browser type, application version, and related technical configuration information;
Network and connection information, including IP address, approximate geographic region derived from IP address, network type, and connection status;
Usage and interaction information, including features accessed, screens viewed, actions taken within the Application, session duration, usage frequency, crash events, performance data, and other diagnostic or analytics information;
Mobile device identifiers and technical identifiers, including advertising identifiers, installation identifiers, device identifiers, or other identifiers associated with your device or use of the Application;
Log, telemetry, crash reporting, and debugging information generated in connection with your use of the Application; and
Information relating to downloads, updates, feature availability, subscription status, advertising interactions, or integrations associated with the Application.
Certain automatically collected information may be considered Personal Information under applicable law, including IP addresses, device identifiers, advertising identifiers, and similar technical information. Our service providers may use automatically collected information to operate, maintain, analyze, troubleshoot, secure, support, personalize, improve, monitor, protect, and develop the Application and related functionality, including analytics, fraud prevention, subscription management, advertising delivery, performance monitoring, and operational support.
Cookies and Third-Party Tracking Technologies
Our third-party service providers may use cookies, device identifiers, local storage, software development kits (SDKs), analytics tools, pixels, web beacons, and similar technologies to collect and store certain technical, usage, diagnostic, and device-related information in connection with your use of the Application.
Website Technologies
When you access the Application, our service providers and we may use browser cookies, local storage, session storage, pixels, or similar web technologies to:
operate and secure our website;
remember preferences and settings;
understand website usage and performance;
analyze traffic and interactions; and
improve the Application and related functionality.
You may be able to control certain cookie settings through your browser settings or device settings.
Mobile and Application Technologies
The Application does not generally use traditional browser cookies. However, the Application and our third-party service providers may use device identifiers, mobile analytics technologies, local storage, SDKs, advertising identifiers, and similar technologies to operate, maintain, secure, analyze, improve, personalize, support, and monitor the Application. These technologies may collect information such as:
device type and operating system;
application version and language settings;
usage activity and feature interactions;
crash reports and diagnostic information;
subscription or purchase status;
advertising identifiers;
installation identifiers; and
performance and analytics information.
Certain technologies may be necessary for the Application's operation, security, functionality, or performance, while others may support analytics, advertising, monetization, diagnostics, personalization, or similar operational purposes.
Consent and Controls
Where required by applicable law, we will obtain consent before using non-essential cookies or tracking technologies. Depending on your device, operating system, browser, or region, you may also be able to limit certain data collection or tracking through your browser, device, or operating system settings, or through advertising/privacy controls.
Third-Party Technologies
Third-party analytics, advertising, monetization, crash reporting, subscription management, remote configuration, or other service providers used in connection with the Application may also use cookies, SDKs, device identifiers, or similar technologies subject to their own privacy policies and terms. We do not control the privacy practices of third-party providers.
Website Analytics
We use website analytics that track and report website traffic on our website, but not our Application ("Website Analytics"). Website Analytics collects information about how our website performs and how our users navigate and use it, so we can improve its performance. We use Website Analytics as a third-party tracking service, but we don't use it to track you individually or collect your Personal Information.
Website Analytics may collect certain non-personally identifiable information over time, such as your IP address, browser type, internet service provider, referring and exit pages, timestamps, and similar data about your website use. We do not link this information to any of your Personal Information, such as your account name or email address.
Personal Information We Collect from Third Parties
We may receive Personal Information or other information relating to you from third parties, including:
App Distributors such as Apple or Google;
analytics, crash reporting, advertising, subscription management, monetization, or cloud-service providers;
customer support providers;
device or operating system providers; and
other service providers, operational vendors, or third parties that assist in providing, supporting, securing, distributing, monetizing, or improving the Application.
The information we may receive from third parties may include account-related information, subscription or purchase status, transaction confirmations, device identifiers, advertising identifiers, analytics information, crash reports, technical information, diagnostic information, usage information, support-related information, or other information reasonably necessary to operate or support the Application.
We generally do not intentionally receive User Content or Translation data from third parties except where voluntarily provided by you or as otherwise described in this Privacy Policy.
2. How We Use Your Personal Information
We use the Personal Information you provide, or we collect:
To present our Application to you;
To provide and maintain the functionality of the Application, including monitoring the usage of our Application;
To notify you about changes to our Application;
To allow you to participate in interactive features of our Application when you choose to do so;
To provide customer support;
To provide you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those you have already purchased or enquired about, unless you have opted not to receive such information;
For our internal business purposes, such as data analysis, audits, and so forth;
To gather analysis or valuable information so that we can improve our Application;
To fulfill our obligations and enforce our rights arising from any contracts you entered into with us;
To monitor the usage of our Application;
To detect security incidents and protect against deceptive, illegal, or unauthorized activities;
To comply with applicable law;
To evaluate and/or conduct a divestiture, restructuring, dissolution, merger, or other transfer or sale of some or all of our assets;
In any other way we may describe when you provide the information; and
For any other purpose with your consent.
3. How We Share and Disclose Your Personal Information
Where permissible under applicable law, we may share your information in the following situations:
With Service Providers. We may share your Personal Information with service providers, contractors, and other third parties we use to support our business, and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
For Business Transfers. We may share or transfer your Personal Information in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
As Aggregated Information. We may disclose aggregated information about our Users, and information that does not identify any individual, to our business partners and other third parties.
To Enforce Our Terms of Use. We may disclose your Personal Information to enforce and administer our End User License Agreement and any other agreements we entered into with you.
To Protect Our Rights. We may disclose your Personal Information to protect the rights, property, or personal safety of our company, its employees, its members, and members of the public.
For Legal Compliance. We may disclose your Personal Information to comply with applicable law, a court order, or legal process, including to respond to: (a) notices of intellectual property infringement, (b) claims that your actions or content uploaded by you to the Application violates the rights of third parties, (c) government or regulatory requests, and/or (d) investigate the use of or respond to alleged violations or infringement of third-party content.
With Your Consent. We may disclose your Personal Information for any other purpose with your consent.
Our Third-Party Service Providers
We may use third-party service providers, SDKs, APIs, App Distributors, cloud providers, analytics providers, advertising providers, payment processors, and operational service providers in connection with the Application. These providers may process limited technical information, device information, usage information, subscription status information, or other Personal Information, as described in this Privacy Policy and in accordance with their own privacy policies.
| Provider | Applies To | Privacy Policy / Terms | Description of Processing Activities |
|---|---|---|---|
| Firebase Analytics (Google) | Apple / Android | firebase.google.com/support/privacy | Analytics, usage measurement, diagnostics, performance monitoring, and Application improvement. |
| Firebase Crashlytics (Google) | Apple / Android | firebase.google.com/support/privacy | Crash reporting, diagnostics, error logging, debugging, and Application stability monitoring. |
| Firebase Remote Config (Google) | Apple / Android | firebase.google.com/support/privacy | Remote configuration, feature flag management, messaging configuration, and Application optimization. |
| Cloud Storage for Firebase (Google) | Apple / Android | firebase.google.com/support/privacy | Hosting, delivery, caching, and distribution of downloadable resources, language files, configuration files, and related Application assets. |
| Google AdMob | Android Only | policies.google.com/privacy | Advertising delivery, ad measurement, monetization, advertising diagnostics, and related advertising functionality. |
| Google Play Store | Android Only | policies.google.com/privacy | App distribution, purchase processing, subscription management, billing, updates, licensing, security, and related Application services. |
| Apple App Store | Apple / iOS | apple.com/legal/privacy | App distribution, in-app purchase processing, subscription management, updates, licensing, and certain platform-level services. The Application may utilize Apple-provided iCloud synchronization or key-value storage functionality to synchronize limited Application state (such as language entitlements or usage counters) across the User's devices associated with the User's Apple iCloud account. Lingofonex does not control or access information stored solely within the User's personal iCloud account through these Apple-provided services. |
| RevenueCat | Apple / iOS | revenuecat.com/privacy | Subscription management, entitlement validation, purchase synchronization, subscription analytics, and monetization functionality. |
| Superwall | Apple / iOS | superwall.com/privacy | Paywall presentation, monetization experiments, audience routing, purchase optimization, analytics, and related subscription functionality. |
| Apple Push Notification Service | Apple / iOS (if enabled) | apple.com/legal/privacy | Push notification delivery and related notification functionality. |
| Other Advertising or Monetization Providers | Apple / Android | Varies by provider | Advertising delivery, monetization, analytics, mediation, attribution, diagnostics, or related operational functionality if additional providers are integrated in the future. |
Crash Reporting and Diagnostics
We use Firebase Crashlytics and related Firebase services provided by Google to help us monitor, diagnose, maintain, and improve the stability, security, functionality, and performance of the Application. When the Application crashes, encounters an error, or behaves unexpectedly, Firebase services may collect certain technical, diagnostic, and device-related information, which may include:
Device type, hardware model, and operating system version;
Application version, runtime environment, and configuration information;
Crash logs, stack traces, and diagnostic reports;
Timestamp, session state, and technical information relating to the event;
Device identifiers, Firebase installation identifiers, or similar technical identifiers; and
Performance, stability, and usage diagnostics relating to the Application.
We use this information to identify and resolve bugs, improve performance and reliability, diagnose technical issues, maintain compatibility, and improve the overall operation of the Application.
Although this information generally does not directly identify you by name, email address, or similar direct identifiers, certain information collected through these services may nevertheless constitute Personal Information under applicable law.
Firebase services used in connection with the Application are operated by Google and are subject to Google's Privacy Policy and applicable Firebase Terms of Service. We do not use Firebase Crashlytics to track your behavior across applications or for marketing purposes. Crashlytics does collect or derive certain attributes, described here.
Depending on your device, operating system, region, or Application settings, you may be able to limit certain analytics, diagnostics, or crash reporting functionality through your device settings or Application settings where such controls are available.
Cloud Storage and Downloadable Components
The Application may use cloud-based storage, hosting, content delivery, or file distribution services, including services provided through Firebase or other third-party providers, to deliver downloadable components, language resources, feature modules, configuration files, updates, or related Application functionality to your device. When the Application accesses these services, third-party providers may receive limited technical, diagnostic, or request-related information, which may include:
Device and application metadata;
Installation identifiers or similar technical identifiers;
Request logs and download activity;
Network and connection information; and
Technical information necessary to facilitate secure and efficient delivery of Application resources.
We use these services to provide, maintain, optimize, secure, update, and improve the Application and related functionality. We generally do not associate cloud storage request activity with your direct identity, and we do not intentionally use these services for behavioral advertising or cross-platform advertising profiling.
Payment Processing and Purchases
Purchases of Paid Features, subscriptions, passes, lifetime unlocks, or other monetized functionality offered through the Application are processed through the applicable App Distributor or payment provider, including, without limitation, Apple, Google, or their respective payment and billing systems. When you initiate a purchase, the applicable App Distributor or payment provider processes the transaction directly. We do not collect, process, store, or have access to your complete payment card information or full billing details used to complete such transactions. App Distributors, payment providers, and related third-party services may collect and process certain information in connection with purchases and subscriptions, including:
Account identifiers;
Device identifiers;
Transaction history;
Subscription status;
Purchase confirmations;
Regional or tax-related information; and
Related billing or technical transaction information.
We may receive limited transaction-related information from App Distributors, payment providers, RevenueCat, or related service providers, such as subscription status, entitlement status, renewal status, cancellation status, product identifiers, and purchase confirmations. We use this information solely to provide, manage, maintain, secure, support, and validate access to Paid Features and related functionality.
Purchases, billing, subscriptions, renewals, cancellations, refunds, Family Sharing availability, and related payment functionality are also subject to the applicable App Distributor's or payment provider's terms, conditions, and privacy policies.
Advertising
Certain portions of the Application, including certain Free Access functionality, may display advertisements, sponsored content, promotional content, or other advertising-supported functionality. Such advertisements or promotional content may be delivered by third-party advertising, monetization, analytics, or mediation providers.
Our third-party providers may use device identifiers, advertising identifiers, IP addresses, approximate geographic region, usage information, or other limited technical information to deliver, measure, manage, support, limit, personalize, or improve advertising, monetization, analytics, or related Application functionality.
Depending on your device settings, region, App Distributor permissions, consent choices, and applicable law, advertisements displayed within the Application may be contextual, non-personalized, personalized, interest-based, or otherwise configured by the applicable advertising provider or platform.
We do not use User Content for cross-platform behavioral advertising profiling, nor do we sell User Content to third parties for advertising purposes. Third-party advertising and monetization providers may collect, process, combine, or use information in accordance with their own privacy policies, terms, and practices. We do not control the privacy practices or technologies of third-party advertising providers.
Depending on your device, operating system, region, or platform settings, you may be able to limit certain advertising-related data collection or personalization through your device privacy settings, advertising settings, App Tracking Transparency settings, advertising identifier controls, or similar platform controls.
Third-Party Use of Cookies
Certain portions of the Application, including Third-Party Content, analytics functionality, advertising-supported functionality, monetization services, App Distributor functionality, or integrated third-party services, may use cookies, pixels, web beacons, SDKs, device identifiers, local storage, advertising identifiers, or similar technologies to collect technical, usage, diagnostic, or device-related information in connection with your use of the Application.
When you use the Application, third parties generally use mobile SDKs, device identifiers, advertising identifiers, local storage, or similar mobile technologies rather than traditional browser cookies. Depending on the Application, your device settings, your region, your consent choices, applicable law, and the configuration of third-party services, these technologies may be used to:
provide, operate, maintain, secure, and improve the Application;
measure performance, engagement, and analytics;
support monetization or advertising functionality;
limit fraud, abuse, or unauthorized activity;
personalize or optimize certain content or functionality; and
support App Distributor, analytics, advertising, or subscription-related functionality.
Third-party providers may collect, process, combine, associate, or use information in accordance with their own privacy policies, terms, and practices. We do not control the privacy practices or technologies used by third-party providers. Depending on your browser, device, operating system, region, or platform settings, you may be able to control certain cookies, tracking technologies, analytics, advertising identifiers, or personalization settings through browser settings, device settings, App Tracking Transparency settings, advertising/privacy settings, or similar platform controls.
For more information about advertising-related controls, you may also review the privacy and advertising settings provided by your device manufacturer, operating system provider, browser provider, or App Distributor.
4. How We Secure Your Personal Information
We use commercially reasonable administrative, technical, organizational, and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, loss, misuse, or destruction. The Application may use encryption, secure communication protocols, authentication controls, access restrictions, cloud security measures, device-level protections, and other security technologies intended to help protect Personal Information processed in connection with the Application.
Core translation-related functionality is generally processed locally on your device, and we do not store User Content on our servers for this purpose. However, certain support-related, operational, analytics-related, monetization-related, diagnostic, synchronization, cloud-based, or third-party integrated functionality may involve the transmission, processing, or storage of limited information as described in this Privacy Policy.
You are responsible for maintaining the security of your device and any information stored locally on it, including, without limitation, by using passcodes, encryption, backups, biometric authentication, operating system updates, and other device-level security protections. We are not responsible for the security, loss, destruction, interception, or unauthorized access of information stored locally on your device, or for any resulting loss, destruction, interception, or unauthorized access, arising from your failure to maintain appropriate device security. Although we strive to use commercially reasonable safeguards to protect Personal Information, no method of electronic transmission, storage, or processing is completely secure, and we cannot guarantee absolute security.
If you believe your interaction with the Application is no longer secure, or if you have questions about security, you may contact us at info[at]lingofonex.com.
5. How You Can Manage Your Personal Information
Depending on your jurisdiction and applicable law, you may have certain rights relating to your Personal Information, including the right to request access to, correction of, deletion of, restriction of, or information regarding certain processing of your Personal Information, subject to applicable legal limitations and exceptions. Because the Application's core functionality is generally processed locally on your device, much of your User Content and related information may be stored only on your device and may not be accessible to us. You may be able to manage, modify, delete, export, or remove certain locally stored information directly through your device settings or by deleting the Application.
If you wish to submit a privacy-related request regarding Personal Information that we may maintain, process, or control, you may contact us at info[at]lingofonex.com. We may request information necessary to verify your identity before responding to your request. We will use commercially reasonable efforts to respond to verified requests within the timeframes required by applicable law. In certain circumstances, we may retain information as required or permitted by applicable law, including for legal, security, fraud prevention, tax, accounting, operational, or compliance purposes.
Certain Personal Information may also be maintained or processed by third-party service providers, App Distributors, analytics providers, advertising providers, or payment processors, subject to their own privacy practices and procedures.
6. Retention of Your Personal Information
We retain Personal Information for as long as reasonably necessary to provide the Application, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce agreements, protect the security and integrity of the Application, and support legitimate business and operational needs. Because the Application's core functionality is generally processed locally on your device, certain User Content and related information may be stored only on your device and may not be retained by us.
We may retain technical information, analytics information, crash reports, subscription records, operational logs, support communications, security-related information, and related records for reasonable retention periods determined by applicable law, operational requirements, fraud prevention needs, accounting requirements, dispute resolution, security purposes, or legitimate business interests. We may also retain aggregated, anonymized, de-identified, or statistical information that does not reasonably identify you for analytics, research, operational, security, or improvement purposes for longer periods where permitted by applicable law. When we no longer reasonably need Personal Information for the purposes described in this Privacy Policy, we will take commercially reasonable steps to delete, de-identify, anonymize, or securely dispose of such information, unless retention is otherwise required or permitted by applicable law.
7. International Transfers and Processing
The Application is operated in the United States and may use service providers, cloud providers, analytics providers, App Distributors, advertising providers, payment processors, and other third-party providers that process information in the United States and other countries. As a result, your Personal Information may be transferred to, stored in, accessed from, or processed in jurisdictions outside of your country, state, or region of residence, including jurisdictions that may not provide the same level of data protection as the laws of your home jurisdiction.
By accessing or using the Application, you acknowledge that your Personal Information may be processed in the United States and other jurisdictions as described in this Privacy Policy. Where required by applicable law, we will take commercially reasonable and appropriate measures designed to protect Personal Information transferred across jurisdictions, including through:
contractual protections;
operational, administrative, and technical safeguards;
Standard Contractual Clauses or similar approved transfer mechanisms;
data transfer agreements;
consent mechanisms where permitted by law; or
other legally recognized transfer mechanisms available under applicable law.
Core translation-related functionality is generally processed locally on your device, and we do not transfer or store User Content on our servers in the United States or elsewhere for the purpose of providing core translation functionality. However, certain support-related, operational, analytics-related, monetization-related, cloud-based, or third-party integrated functionality may involve the transmission, processing, or storage of limited information as described in this Privacy Policy.
If you have questions regarding international data transfers or the safeguards we apply, you may contact us at info[at]lingofonex.com.
8. Opting Out of Marketing Emails
If you provide us with your email address or otherwise opt in to receive promotional or marketing communications from us, we may send you emails relating to the Application, updates, features, promotions, announcements, or related information. You may opt out of receiving marketing or promotional emails at any time by clicking the "unsubscribe" link included in the applicable communication, following the instructions provided in the communication, or contacting us at info[at]lingofonex.com.
Please note that even if you opt out of marketing communications, we may still send you non-promotional communications relating to the Application, your account, support requests, purchases, subscriptions, security matters, legal notices, or other transactional or operational communications.
9. Third-Party Content and Services
The Application may contain, integrate with, access, display, or provide links to Third-Party Content (as defined in the applicable End User License Agreement), including, without limitation, third-party websites, applications, SDKs, APIs, App Distributors, analytics providers, advertising providers, payment providers, cloud services, monetization providers, or other third-party functionality or services (collectively, "Third-Party Services"). This Privacy Policy does not apply to the privacy, security, data collection, or information handling practices of Third-Party Services except as expressly described in this Privacy Policy. Third-party providers may independently collect, process, store, use, disclose, combine, or transfer information in accordance with their own privacy policies, terms, and practices.
When you interact with Third-Party Content or Third-Party Services, including through advertisements, App Distributor functionality, payment systems, analytics services, cloud services, integrated SDKs, or external links, your information may be processed directly by the applicable third party. We do not control and are not responsible for the privacy, security, content, availability, or data practices of Third-Party Content or Third-Party Services. Your access to and use of Third-Party Content and Third-Party Services is at your own risk. We encourage you to review the privacy policies, terms, and practices of any Third-Party Services before interacting with them or providing Personal Information.
10. Personal Information of Minors
The Application is not directed to children under 16, and we do not knowingly collect Personal Information directly from children under 16. If you are under the age of 16, you are not permitted to access or use the Application without any parental consent or permissions that may be required under applicable law. If we become aware that we have collected Personal Information from a child under the age of 16 in a manner inconsistent with applicable law, we will take commercially reasonable steps to delete such information and restrict or discontinue access to or functionality as appropriate. If you believe that a child under the age of 16 may have provided us with Personal Information, please contact us at info[at]lingofonex.com.
11. California Supplement
California users may have additional rights under California Privacy Laws (defined below).
Additional Definitions Applicable to California Privacy Laws
"CCPA" or "California Consumer Privacy Act" means California Civil Code § 1798.100 et seq.
"Consumer," "Business," "Sell," and "Service Provider" will have the meanings given to them in the CCPA.
California Consumer Privacy Act ("CCPA")
If the processing of your Personal Information is subject to the CCPA, you have the right to:
Request us to disclose the categories and specific pieces of Personal Information we collect, use, disclose, and sell;
Know the categories of Personal Information that we collect and the purposes for which we collected or used such Personal Information, and whether that information is sold or shared;
Know the categories of sources from which the Personal Information was collected;
Know the categories of third parties with whom we share or to whom we sell your Personal Information;
Know whether we collected or sold your Personal Information for business or commercial purposes;
Request deletion of Personal Information we collected from you, subject to certain exceptions;
Opt out of the sale of their Personal Information; and
Not receive discriminatory treatment by us for exercising their rights set out in the CCPA.
Categories of Personal Information Disclosed for a Business Purpose
The following describes the categories of Personal Information that we may have disclosed for a business or commercial purpose during the 12 months preceding the date this Privacy Policy was last updated.
We may disclose Personal Information to service providers, App Distributors, cloud providers, analytics providers, advertising providers, payment processors, operational vendors, customer support providers, professional advisors, governmental authorities, or other third parties as reasonably necessary to provide, operate, secure, support, improve, monetize, distribute, maintain, or comply with legal obligations relating to the Application.
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Identifiers: Real name, alias, email address, online identifiers, Internet Protocol address, device identifiers, advertising identifiers, Firebase installation identifiers, account-related identifiers, or other similar identifiers.
Parties with whom this category of Personal Information may be shared include: Service providers, App Distributors, our business partners, and third-party vendors to whom you or your agents authorize us to disclose your Personal Information in connection with the Application.
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Categories of Personal Information described in California Civil Code §1798.80(e): Name, mailing address, telephone number, or other contact information voluntarily provided by you.
Parties with whom this category of Personal Information may be shared include: service providers, App Distributors, customer support providers, payment processors, operational vendors, professional advisors, and third-party vendors or providers involved in the operation, support, security, compliance, or functionality of the Application.
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Commercial Information: Records of purchases, subscription status, transaction confirmations, entitlement status, purchase history, subscription renewals, cancellations, refunds, or other information relating to Paid Features or monetization functionality.
Parties with whom this category of Personal Information may be shared include: App Distributors, payment processors, subscription management providers, analytics providers, monetization providers, customer support providers, and third-party vendors or providers involved in billing, purchases, subscriptions, monetization, analytics, fraud prevention, operational support, or Application functionality.
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Internet or Other Electronic Network Activity Information: Usage activity, feature interactions, crash reports, analytics information, diagnostic information, session information, device interactions, performance information, or other information relating to your use of the Application.
Parties with whom this category of Personal Information may be shared include: service providers, analytics providers, crash reporting providers, cloud providers, advertising providers, App Distributors, operational vendors, and third-party vendors or providers involved in analytics, diagnostics, performance monitoring, monetization, advertising, fraud prevention, security, support, or Application functionality.
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Geolocation Information: Approximate geographic region derived from IP address, device settings, or network information.
Parties with whom this category of Personal Information may be shared include: service providers, analytics providers, advertising providers, App Distributors, cloud providers, operational vendors, and third-party vendors or providers involved in analytics, advertising, localization, fraud prevention, security, support, or Application functionality.
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Audio, Electronic, Visual, or Similar Information: Information voluntarily provided through support requests, screenshots, attachments, Feedback submissions, communications with us, or similar interactions.
Parties with whom this category of Personal Information may be shared include: customer support providers, cloud providers, operational vendors, professional advisors, service providers, and third-party vendors or providers involved in support, security, diagnostics, compliance, or Application functionality.
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Inferences Drawn From Personal Information: Preferences, usage patterns, subscription activity, analytics-derived insights, or other inferences relating to use of the Application.
Parties with whom this category of Personal Information may be shared include: analytics providers, advertising providers, monetization providers, operational vendors, service providers, and third-party vendors or providers involved in analytics, monetization, personalization, performance monitoring, operational support, or Application functionality.
Personal Information may be collected, used, or disclosed for business and commercial purposes, including the following examples:
To operate and improve our Application;
To provide you with our Application, respond to your inquiries, and give you the necessary support;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
As described to you when collecting your Personal Information or as otherwise outlined in the CCPA;
For internal administrative and auditing purposes; and
To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Do Not Sell My Personal Information
California residents may have the right to opt out of the "sale" or "sharing" of Personal Information as those terms are defined under applicable California privacy laws.
We do not sell Personal Information for monetary compensation. However, certain limited disclosures involving advertising identifiers, analytics technologies, device identifiers, or similar technologies used in connection with advertising, analytics, monetization, or operational functionality could be considered "sharing" under California law, depending on how such laws are interpreted or applied. You may submit a request relating to your California privacy rights by contacting us at info[at]lingofonex.com.
Depending on your device, operating system, browser, App Distributor, region, or applicable law, you may also be able to limit certain advertising or tracking-related data collection through device settings, advertising/privacy settings, App Tracking Transparency settings, or similar Application controls.
California Requirements for Minors
If you are a California resident under the age of 18 and applicable law grants you the right to request removal of certain content or information that you have publicly submitted or posted through the Application, you may contact us at info[at]lingofonex.com to request removal where such functionality is available.
Please note that removal requests may not ensure complete or comprehensive removal of all content or information, particularly where retention is required by law, necessary for operational, security, compliance, or legal purposes, or where content has been copied, reposted, cached, archived, or otherwise retained by third parties.
Do Not Track Features
Certain web browsers and devices may offer privacy settings or features such as "Do Not Track" (DNT), Global Privacy Control (GPC), App Tracking Transparency (ATT), advertising identifier controls, or similar privacy preference mechanisms.
At this time, there is no universally accepted standard for recognizing or responding to all DNT browser signals or similar automated privacy preference signals across websites, applications, devices, and platforms. As a result, the Application may not respond to all such signals in every circumstance.
Depending on your browser, device, operating system, region, or applicable law, you may be able to control certain tracking, analytics, advertising, or personalization practices through browser settings, device settings, operating system privacy controls, advertising settings, App Tracking Transparency settings, or similar platform controls.
For additional information regarding advertising and tracking-related controls, please review the applicable settings and privacy controls provided by your browser provider, device manufacturer, operating system provider, or App Distributor.
California's Shine the Light Law
Under California Civil Code Section 1798.83 (commonly known as California's "Shine the Light" law), California residents may request information regarding whether a business has disclosed certain categories of Personal Information to third parties for those third parties' direct marketing purposes. We do not knowingly disclose Personal Information to third parties for their own direct marketing purposes as contemplated by California's Shine the Light law.
If you are a California resident and wish to submit a request relating to your California privacy rights, you may contact us at info[at]lingofonex.com.
12. EU Supplement
Users of the Application located in the European Economic Area (EEA), the United Kingdom, or Switzerland may have additional rights regarding their Personal Information under applicable privacy and data protection laws, including the European Union General Data Protection Regulation (GDPR), the UK GDPR, the UK Data Protection Act, the Swiss Federal Act on Data Protection, and related laws and regulations.
Exercising Your Privacy Rights
Individuals located in the EEA, the United Kingdom, or Switzerland may have certain rights regarding their Personal Information under applicable privacy and data protection laws, subject to applicable legal limitations and exceptions. Depending on applicable law, these rights may include the right to:
request access to Personal Information we maintain about you;
request correction or updating of inaccurate or incomplete Personal Information;
request deletion or erasure of certain Personal Information;
request restriction of certain processing activities;
object to certain processing activities;
request portability of certain Personal Information;
withdraw consent where processing is based on consent; and
lodge a complaint with a supervisory authority or data protection authority.
Because core translation-related functionality is generally processed locally on your device, certain User Content and related information may remain stored only on your device and may not be accessible to us. To exercise your privacy rights, please contact us at info[at]lingofonex.com. We may request information necessary to verify your identity before responding to your request. We generally do not charge a fee for responding to privacy rights requests unless permitted by applicable law, including where requests are manifestly unfounded, repetitive, excessive, or abusive.
If you believe that we have not adequately addressed your concerns regarding the processing of your Personal Information, you may contact your local supervisory authority or data protection authority.
Legal Basis for Processing
Where required by applicable law, including under the GDPR, UK GDPR, or similar privacy laws, we rely on one or more lawful bases to collect, use, disclose, process, or otherwise handle Personal Information. Depending on the circumstances, these lawful bases may include:
processing necessary to perform a contract with you or to provide the Application and related functionality;
your consent;
compliance with legal obligations;
protection of vital interests;
public interest purposes where applicable; and
our legitimate interests, including interests relating to operating, securing, maintaining, improving, monetizing, supporting, analyzing, distributing, protecting, or developing the Application, provided that such interests are not overridden by your rights and freedoms.
We may also process Personal Information as reasonably necessary to:
provide customer support;
manage subscriptions, purchases, and monetization functionality;
detect fraud, abuse, security incidents, or unauthorized activity;
enforce agreements, policies, or legal rights;
comply with legal or regulatory obligations; and
maintain the functionality, integrity, performance, and security of the Application.
By accessing or using the Application, you acknowledge that certain processing activities are necessary for us to provide the Application and fulfill our contractual obligations relating to the Application and associated services.
13. South and Latin America Supplement
Individuals located in South America, Latin America, Central America, or other jurisdictions with applicable privacy or data protection laws may have additional rights regarding their Personal Information under applicable law, including, without limitation, Brazil's Lei Geral de Proteção de Dados (LGPD), Argentina's Ley de Protección de los Datos Personales (Law No. 25.326), and similar privacy or data protection frameworks.
For purposes of this section, "Personal Information" generally refers to information relating to an identified or identifiable natural person and may include contact information, device identifiers, technical information, usage information, support-related information, or other information described in this Privacy Policy.
Depending on your jurisdiction and applicable law, you may have certain rights relating to your Personal Information, including the right to:
confirm whether we process your Personal Information;
request access to the Personal Information we maintain about you;
request correction of inaccurate, outdated, or incomplete Personal Information;
request deletion, anonymization, or blocking of certain Personal Information;
request portability of certain Personal Information;
object to or request restriction of certain processing activities;
withdraw consent where processing is based on consent;
request information regarding our data processing practices and third-party disclosures; and
submit complaints to your applicable data protection authority or regulatory authority.
Because core translation-related functionality is generally processed locally on your device, certain User Content and related information may remain stored only on your device and may not be accessible to us. To exercise your privacy rights, please contact us using the contact information provided in this Privacy Policy. We may request information necessary to verify your identity before responding to your request, as permitted by applicable law. Certain rights may be limited or subject to exceptions under applicable law. We will respond to verified requests within the timeframes required by applicable law.
14. Ukraine Supplement
If you are located in Ukraine, we process Personal Information in accordance with the Law of Ukraine "On Protection of Personal Data" No. 2297-VI and other applicable laws, regulations, or requirements relating to privacy, data protection, electronic communications, consumer protection, or cybersecurity. This section supplements the other terms of this Privacy Policy and applies specifically to individuals located in Ukraine.
Your Rights
Subject to applicable law, you may have certain rights regarding your Personal Information, including the right to:
receive information regarding the processing of your Personal Information;
request access to the Personal Information we maintain about you;
request correction, updating, restriction, blocking, or deletion of certain Personal Information;
object to certain processing activities;
withdraw consent where processing is based on consent; and
submit a complaint to the Ukrainian Parliament Commissioner for Human Rights (Ombudsman) or another applicable authority.
Because core translation-related functionality is generally processed locally on your device, certain User Content and related information may remain stored only on your device and may not be accessible to us.
International Data Transfers
The Application may use service providers, cloud providers, analytics providers, App Distributors, advertising providers, payment processors, and other third-party providers that process information in the United States and other countries outside Ukraine. As a result, your Personal Information may be transferred to, stored in, accessed from, or processed in jurisdictions outside Ukraine that may not provide the same level of data protection as Ukrainian law.
Where required by applicable law, we will take commercially reasonable and appropriate measures designed to protect Personal Information transferred across jurisdictions, including through contractual protections, operational safeguards, technical safeguards, consent mechanisms where permitted by law, or other legally recognized transfer mechanisms.
Core translation-related functionality is generally processed locally on your device, and we do not transfer or store User Content on our servers outside Ukraine for the purpose of providing core translation functionality. However, certain support-related, operational, analytics-related, monetization-related, cloud-based, or third-party integrated functionality may involve the transmission or processing of limited information as described in this Privacy Policy.
Availability of the Application
Access to the Application may be interrupted, delayed, degraded, restricted, or unavailable due to circumstances beyond our reasonable control, including war, armed conflict, cyber incidents, governmental actions, sanctions, internet outages, infrastructure disruptions, power interruptions, telecommunications failures, or related events affecting Ukraine or other regions. We are not responsible for interruptions, delays, loss of functionality, or unavailability resulting from such circumstances. If you have questions regarding this Ukraine Privacy Rights Supplement or wish to exercise your rights under applicable law, please contact us using the contact information provided in this Privacy Policy.
15. Contact Information
If you have any questions or complaints about this Privacy Policy or our handling of your Personal Information, please contact us at info[at]lingofonex.com.