Privacy Policy
- General
This Privacy Policy applies to
Artlexis websites, mobile apps, and related services
(“Service”). By using the Service, you
agree with EUP’s collection, use, and sharing of your personal information in accordance with the
terms of this Privacy Policy. Certain Artlexis services are subject to additional or different terms.
Please note that EUP is
constantly testing and improving our product features. Any features discussed in this Privacy Policy may
not be available to all users or in all jurisdictions.
- Information We Collect
When you use the
Service, EUP may collect the following personal information about you.
a. Account Registration
To register for a Artlexis account, you may provide us with your age and email
address. In some countries, you may also provide us with your phone number.
You may also register for
a Artlexis account using certain social logins,
such as Google and Facebook. If you register for Artlexis using a social login, EUP may receive
information about you from your social login provider, including your email address and contacts.
You
can manage your Artlexis account and social
logins from your settings.
b. Profile Page & User-Generated
Content
After you register for your Artlexis account, a profile page will be created for you
(“Profile”). Your Profile will be populated
by information you submit, such as your name, username, bio, and profile picture (“User-Generated Content”). Your age, phone number, and email
address are not included in your public Profile and are not considered User-Generated Content under this
Privacy Policy. Other Artlexis users may be able to
search for your Profile using your name, username, email address, or phone number.
Your Profile will
also include information about your learning progress, such as the languages you are learning, your
learning statistics, and your achievements. Moreover, your Profile will show a list of your followers
and other users you follow.
By default, your Profile is public, and visible to other Artlexis users and
anyone else on the Internet. In addition, your User-Generated Content may be publicly visible. If your
Profile is public, third-party websites or web scrapers may be able to read, collect, and use your
public information for their own purposes. However, you can set your Profile to private in your
settings.
You may be able to submit comments that will supplement other users’ Profiles and
other users may be able to submit comments that will supplement your Profile. Any comments you submit
are considered User-Generated Content under this Privacy Policy. You can delete comments you submit or
comments that other users submit to your Profile.
EUP may scan or review any User-Generated Content,
or share your User-Generated Content with a third-party content moderation service provider, to ensure
compliance with our Terms and Conditions of Service. EUP may restrict or delete User-Generated Content
if it violates our Community Guidelines or for any other reason.
c.
Artlexis Premium
If you subscribe to the premium plan, you will be
able to access all the features included in the premium package, as listed on the app earlier, for the
duration of your subscription. If you are unable to use them, please contact us for assistance and
resolution.
d. Speaking
Activities
Some activities involve you speaking into the Artlexis app. To recognize speech, your audio may be sent to a
third-party provider. Additionally, EUP may collect and analyze your speech to help us understand the
effectiveness of our lessons and to improve the product. You may skip speaking activities.
EUP may
also collect and analyze your speech to help us understand the effectiveness of our lessons and to
improve the product. You may choose not to share your audio with us for product improvement purposes in
your settings. Any audio you agree to send to EUP is anonymized when it reaches our servers to ensure
that no trace of your personal information remains attached to the audio.
e. Activity Data & IP Addresses
When you use the
Service, we may generate data about your use of the Service, which may include your browser and device
data, device ID, log data, and IP address. We will also
generate data regarding your engagement in educational activities on the Service.
We may recommend
other Artlexis users for you to follow, and for other
users to follow you, based on a shared IP address, such as other users on the same WiFi network. We may
also use your IP address to display a location on your profile, which you may disable at any time. We
will retain your IP address for no more than thirty (30) days, unless exceptional circumstances require
longer retention.
f. Cookies
When you access
the Artlexis website, we store certain data from your
browser using cookies. A cookie is a piece of data stored on the user’s computer tied to data
about the user. We use session ID cookies to confirm that users are logged in. If you do not want your
data to be collected by cookies, there is a simple procedure in most browsers that allows you to deny or
accept the cookie feature. However, cookies may be necessary to provide you with certain features
available on the website (e.g., customized information).
g. Google
Analytics
We use Google Analytics, which is a web analytics tool that
helps us understand how users engage with our website. Like many services, Google Analytics uses
first-party cookies to track user interactions, as in our case, where they are used to collect
information about how users use our site. This information is used to compile reports and to help us
improve our site. These reports disclose website trends without identifying individual visitors.
- How We Process Your Information
EUP
may process your personal information according to the following legal bases: to
provide products or services you request, to promote EUP’s legitimate interests, to comply with
legal obligations, and with your consent. In particular, EUP may process and share your personal
information in the following ways:
a. Providing and improving the
Service
EUP will process your personal information to
provide and improve the Service. For example, we will use the information you provide to maintain your
Profile and learning progress, display your Profile to other users (unless you make it private),
personalize learning content, detect and fix bugs, perform research, and provide customer service to
you.
EUP may share personal information with third parties that help us provide or improve the
Service, including hosting providers, search engine providers, analytics providers, support providers,
and payment processors. EUP may also share your information with third-party vendors that support
product features such as AI, speech recognition, and content moderation.
If you redeem a promotion
code to gain a Artlexis subscription, we may share
data regarding your usage of Artlexis with the
organization that provided the promotion code to you.
b. Communicating
with you
EUP will use the email address or phone
number you provide to send you the following types of messages:
- Essential messages to support the operation of the
Service.
- Messages to support the Artlexis teaching methodology and reinforce your learning, such as
learning tips, reminders to practice, and progress reports.
- Notifications about friend requests and your friends’ progress
on Artlexis.
- Announcements regarding changes to the Service or
products.
- Announcements of new Artlexis products, services, offers, or research
opportunities.
You may opt-out of receiving non-essential messages in your settings.
c. Complying with law and preventing harmful activities
EUP may process and share personal information if necessary to comply
with legal requests, such as subpoenas or court orders. EUP may share personal information when we believe
it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal
activity, to assist law enforcement, or to prevent imminent harm. This may include sharing information with
other companies, lawyers, agents, or government agencies.
d. Personalized
advertising
EUP may process and share your personal
information for the purpose of providing you with personalized advertising. To provide personalized
advertising, we work with a variety of third-party advertising networks, marketing analytics service
providers, and website analysis firms, such as Google, Facebook, Oath, and Unity. These third-party
advertising service providers collect and use personal information about your visits to and use of the
Service, as well as other websites, in order to serve you with advertisements and content tailored to meet
your preferences and likely interests, and better understand ad effectiveness. Aggregate demographic and
interest data will also be used for market research purposes.
You can opt out of receiving personalized advertising in your settings. In addition,
your mobile devices may offer settings that let you make choices about the collection, use, and transfer of
mobile app information for personalized ads (for example, Apple iOS’ Advertising ID and Google
Android’s Advertising ID). Users in certain jurisdictions (including the European Union and United
Kingdom) are opted out of personalized advertising by default, but may opt in.
e. Anonymous information
EUP
may process aggregated, de-identified, or otherwise anonymous or anonymized
information for any purpose. Such information is not considered personal information.
- Your Data Subject Rights
You also
have the following rights in relation to the personal information we hold about you, in addition to any
other rights required by applicable law:
- Know what personal information we have collected about
you.
- Access a copy of the personal information that we hold about
you.
- Know what personal information about you we have shared with
third parties.
- Request information about whether we sell your personal
information.
- Know whether your personal data is sold
We do not sell your personal information for monetary gain. However, certain data
sharing activities, such as with service providers for advertising or analytics, may be classified as a
"sale" under some laws
- Opt out of the sale of your personal information.
- Opt out of the sharing of your personal information with third
parties.
- Object to our processing of your personal information.
- Request that we limit our use of your sensitive personal
information to what is necessary to perform the services you requested.
- Not be discriminated against for exercising your data subject
rights.
- Request access to the personal data we collect about you
- Request that we delete any personal information we have collected
from you.
- Request that we correct any inaccurate personal information about
you.
- Export the personal information you have provided to EUP in a
format that can be transferred electronically to a third party.
- Withdraw any consent you previously gave us to process your
personal information.
- Delete your Artlexis account by following the instructions in the Service.
- Lodge a complaint with a supervisory authority if you believe
that your personal data has been processed in violation of applicable data protection laws
You may update or correct your information, and exercise certain opt-out rights, in
your settings page. To make another privacy-related
request, please send an email to [email protected].
Please note that
these rights are not absolute and EUP may refuse requests to exercise data subject rights if there is a
legitimate reason, such as if we cannot authenticate your identity, if the request could violate the rights
of a third party or applicable law, or if the request could interfere with a EUP service or prevent us from
delivering a service you requested.
You may also have the right to make a GDPR complaint to the relevant
Supervisory Authority.
- Data Retention
EUP will generally retain your personal information until your account is deleted. However,
EUP may retain certain information longer if necessary to provide our Service, defend our legitimate
interests or those of third parties, comply with legal requirements, resolve or defend ourselves in
disputes, investigate misuse or disruption of the Service, or perform agreements. We may also retain
anonymous data indefinitely.
- Do Not Track
The Service is not
designed to respond to “do not track” signals sent by some browsers.
- Links to Third-Party Websites
The
Service may contain links to other websites. EUP is not responsible for the content or privacy practices
of other websites, including any personal or financial information collected by third-party payment
processors. We encourage users to be aware of the privacy policies of other websites they visit. This
Privacy Policy applies only to information collected by EUP. Any time you click on a link (including
advertising banners) or submit your personal information to a third-party website, you will be subject
to that third party’s privacy policies.
- Privacy Policy Updates
We may update
our Privacy Policy to reflect changes to our information practices. If we do this and the changes are
material, we will post a notice that we have made changes to this Privacy Policy on the Website for at
least seven (7) days before the changes are made, and we will indicate the date these terms were last
revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective
at the end of that seven (7) day period.
- Data Transfer
EUP is based in Vietnam and processes data in Vietnam, which may not provide equivalent levels of
data protection as your home jurisdiction. EUP may transfer the data of users outside Vietnam to
Vietnam.
Decree No. 13/2023/ND-CP on Protection of Personal Data
(“Decree 13”)
EUP has responsibility for the processing of personal
information it receives under the Decree 13 Principles and subsequently transfers to a third party
acting as an agent on its behalf. EUP shall remain liable under the Decree 13 Principles if its agent
processes such personal information in a manner inconsistent with the Decree 13 Principles, unless EUP
proves that it is not responsible for the event giving rise to the damage.
The Ministry of Public
Security of Vietnam has jurisdiction over EUP’s compliance with the Decree 13 Principles. EUP may
disclose personal information in response to lawful requests by Vietnamese authorities, including to
meet national security or law enforcement requirements.
- Supplemental Terms in Certain Jurisdictions
In some jurisdictions, the Service may be subject to supplemental privacy policies or
local laws. For users in those jurisdictions, the applicable supplemental privacy policies and local
laws will take precedence over this Privacy Policy to the extent they conflict.
- Compliance with Regulations
California Consumer Privacy Act (CCPA): California
residents have the rights outlined above, including the right to request access, deletion, or correction of
personal data, and the right to opt-out of data sales or sharing, as well as other rights provided under the
CCPA. For CCPA-specific inquiries, email us at [email protected].
Virginia Consumer Data Protection Act (VCDPA): Virginia
residents have the right to access, correct, delete, and obtain a copy of their personal data, as well as
other rights provided under the VCDPA. To exercise these rights, contact us at [email protected].
General Data Protection Regulation (GDPR): Users in the EU
have rights under the GDPR, including access, correction, deletion, portability, and the right to restrict
or object to data processing, as well as other rights provided under the GDPR. Requests can be sent to
[email protected]
.
Lei Geral de Proteção de Dados (LGPD): Brazilian users have rights under the LGPD, including access, correction, deletion, and
portability of their data, as well as other rights provided under the LGPD. Requests can be sent to
[email protected]
.
- Contact Us
EUP
TECHNOLOGY.,JSC is the data controller of your data for the purposes of
the General Data Protection Regulation (“GDPR”) and any relevant local legislation.
EUP’s headquarters are located within Vietnam at: Room 802, 8th Floor, 315 Truong Chinh Building,
Khuong Mai Ward, Thanh Xuan District, Hanoi City, Vietnam
For all data privacy inquiries and any questions or concerns you have about this
Privacy Policy, please contact us at [email protected] or visit our
websites: https://eupgroup.net/
Data Protection Officer (DPO): We have appointed a Data
Protection Officer (DPO) to oversee compliance with data protection regulations. If you have any questions
or concerns regarding your data, you may contact our DPO:
Name: Mr. Nguyen Tuan Minh
Email: [email protected]
Phone: (+084) 386171800