The provisions below govern the use of the LANGZ service (“Service”), developed by the company PRO USER APLICATIVOS LTDA, enrolled in the CNPJ under No. 27.810.317/0001-40, hereinafter referred to as “PROUSER”, headquartered in the City of São Paulo, SP, Brazil. By accessing or using any part of the Service, you declare that you have read, understood, and agree to be bound by these terms of the PRIVACY POLICY, as currently in force in the terms of use. PROUSER may change, update, or alter these Terms. If you do not agree to comply with these terms of the PRIVACY POLICY, you are not authorized to use, access, or participate in the Service.
1. Privacy policy
1.1 PROUSER cares about your personal data, which is why we have prepared this document to explain how we collect, use, and share it. This Policy details the personal data that PROUSER (“PROUSER”, “we”, or “our”) receives from you, how we process it, and your rights and obligations regarding your personal data.
1.1.1 Change to the Privacy Policy: PROUSER reserves the right to change this privacy policy at any time by publishing the updated version on the websites. In the event of a material change in the processing of personal data, you will be informed in advance and will have the opportunity to review the revised policy before deciding to continue using our services.
Data we collect
1.2. Activity data: By using the Service, you submit information and content to your profile. We also generate data about your use of our Services, including your involvement in educational activities on the Service, or the sending of messages.
1.2.1 Automatically collected data: By using the Service, we automatically collect technical information about your device and application usage, including: IP address, device type and model, operating system and version, advertising identifiers (IDFA on iOS and GAID on Android), approximate location data (based on IP), access logs and app usage, and information about crashes and app performance.
1.2.3 Voice and conversation data with Orb: When using Orb, our conversational AI, we collect text messages and audio sent by the USER during conversation sessions, as well as automatically generated transcripts. Since voice recordings constitute personal data under Law No. 13,709/2018 (LGPD), their processing complies with the guidelines of this Policy and applicable legislation.
1.2.4 Use of data for AI improvement: Texts and audios sent to Orb may be used, in an anonymized and aggregated manner, to improve the artificial intelligence models that make up the Service. No data that allows the USER to be individually identified will be used for this purpose without their express consent.
1.2.5 Legal basis for data processing: The processing of the USER’s personal data by PROUSER is carried out based on the following legal bases provided for in Law No. 13,709/2018 (LGPD):
(a) Performance of contract: processing necessary for the provision of the contracted Service, including account creation and management, learning personalization, and operation of Orb;
(b) Consent: processing for sending marketing communications, use of voice data for AI training, and other purposes exceeding the performance of the Service;
(c) Legitimate interest: processing for fraud prevention, Service security, feature improvement, and performance analysis, provided that the fundamental rights or interests of the USER do not prevail;
(d) Compliance with legal obligation: processing necessary to meet requirements of competent authorities or court orders.
1.2.6 International data transfer: The Service uses infrastructure and analytics providers such as Google Cloud Platform, Firebase, and Crashlytics, whose servers may be located outside of Brazil. In such cases, PROUSER adopts contractual and technical measures to ensure that the level of protection of the USER’s personal data is equivalent to that required by the LGPD, in compliance with Art. 33 of Law No. 13,709/2018.
Product research and development
1.3 Product research and development: We may contact you to participate in product research activities, satisfaction surveys, using the phone number and/or email provided by you when registering in the app. This may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information provided will be used to test, improve, and develop our products. In these cases, we may record video, audio, and text transcripts of this feedback, along with any additional contact information you provide, and we will retain this data for two years. You may request a copy of all research-related data you have provided to us.
Information obtained by third parties
1.4 Information obtained by third parties: To support and enhance the Service, we work with a variety of third-party advertising networks, marketing analytics service providers, and website and mobile application analytics companies, such as Google, Facebook, and other Networks (collectively, “Third-Party Advertising Service Providers”). These third-party advertising service providers collect and use personal data about your visits and use of the website and mobile app in order to offer you personalized ads and content to meet your preferences and likely interests, or to better understand the effectiveness of advertising. Aggregated demographic and interest data will also be used for market research purposes.
1.4.1 We use Google Analytics, which is a data analysis tool that helps us understand how users engage with the website and mobile app. Like many services, Google Analytics uses first-party cookies to track user interactions, such as in our case, where they are used to collect information about how users use our app. This information is used to compile reports and to help us improve our app. The reports provide usage insights without identifying individual visitors. Learn more about cookies and privacy information from Google Analytics. You can opt out of Google Analytics without affecting how you use the app. For more information on how to opt out of being tracked by Google Analytics across all websites you use, visit this Google page.
1.4.2 By providing information through our Platforms, the user is subject to the conditions for collecting, using, storing, and sharing personal data in accordance with this Privacy Policy.
1.4.3 In addition, your mobile devices may offer settings that allow you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS Advertising ID and Google Android Advertising ID).
1.4.4 Please note that opting out does not prevent all ads from being displayed to you. If you have been impacted by any online advertising of the SERVICE, whether on websites, Apps, or social networks, this does not mean that PROUSER has access to your personal information. These third-party advertising service provider networks do not provide us with any of your information unless you interact with the advertising (banner, link, landing page, etc.).
1.4.5 Our customer service channels are third-party platforms such as: WhatsApp, Google Play, Apple, and email to handle cases according to the user’s needs. These communication platforms comply with legal data protection requirements.
Use of information obtained by PROUSER
1.5 Use of information obtained by PROUSER: PROUSER may occasionally send you service-related announcements and product changes through the general operation of the Service. We will send reminder notifications to support the teaching methodology. We process your data to help provide the Service and offer personalized features, to understand and improve our Service, and to keep our Service secure. We may share anonymous data collected through the Service, including Activity Data, without limitation. As a company, it is essential that we enter into our contract with the best possible service, and it is in our legitimate interest to perform these processing functions. We may also use the WhatsApp channel to share information about our app and encourage its use.
Sharing your personal data with third parties
1.6 Sharing your personal data with third parties: PROUSER shares your personal data only when necessary to offer the Service, legally required, or permitted by you. We will provide personal data to hosting providers, such as Google Cloud Platform, Firebase, and analytics providers such as Crashlytics. These data processors help us provide the Service. For example, we may share your information to detect a problem/bug/crash while using our mobile app. When we use service providers to process any personal data, we implement contractual safeguards that limit the use of such personal data to providing services to PROUSER. We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. In addition, we will access and share account or other personal data when we deem it necessary to comply with the law, protect our interests or property, prevent fraud or other illegal activities perpetrated through the Service or using the LANGZ name, or prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents, or government agencies.
Information security
1.7 Information Security: PROUSER has implemented security rules, procedures, and tools that it believes to be appropriate to protect the confidentiality, integrity, and availability of the user’s personal data. However, with sufficient resources, a determined attacker may, as a result, gain access to the data we seek to protect.
1.7.1 Langz does not directly collect or process credit card data or financial information. Access to the Service is made available through commercial partners, such as telephone carriers, which are responsible for processing payments in accordance with their own privacy and security policies. All communication between the app and PROUSER’s servers is carried out using encryption (SSL/TLS), ensuring security in the transmission of the USER’s data.
Contact
1.8. For all questions about data privacy and any questions or concerns you have about this Privacy Policy, please contact suporte@prouser.co.
Data subject rights
1.9 Data subject rights: Pursuant to Law No. 13,709/2018 (LGPD), the USER has the right, at any time and upon request to the channel suporte@prouser.co, to: (a) Confirmation: know whether we carry out the processing of your personal data; (b) Access: obtain a copy of the personal data we hold about you; (c) Correction: request the correction of incomplete, inaccurate, or outdated data; (d) Anonymization, blocking, or elimination: request the anonymization, blocking, or elimination of unnecessary or excessive data or data processed in non-compliance with the LGPD; (e) Portability: request the transfer of your data to another service provider; (f) Elimination: request the deletion of personal data processed based on your consent; (g) Information on sharing: know with which third parties we share your data; (h) Revocation of consent: withdraw consent at any time, without prejudice to the lawfulness of processing carried out previously; (i) Opposition: oppose processing carried out based on legal grounds other than consent, if not in compliance with the LGPD. Requests will be answered within up to 15 (fifteen) business days.
Communication of security incidents
1.11 Communication of security incidents: In the event of a security incident that may result in relevant risk or damage to the USER, PROUSER will communicate the fact to the National Data Protection Authority (ANPD) and to affected data subjects within a reasonable time frame, as required by Art. 48 of Law No. 13,709/2018, informing: the nature of the affected data, the data subjects involved, the technical and security measures adopted, and the risks related to the incident.
2. Storage and account deletion
2.1 Users’ personal data collected and stored by PROUSER will be used exclusively for the operationalization, provision, maintenance, use, support, enhancement, and continuous improvement of the application during the period of use of the Service, in strict compliance with applicable personal data protection legislation.
2.2. Personal data is stored as follows:
(a) Registration data (email, phone, name): maintained for the duration of the account and deleted after user request.
(b) Activity data and pedagogical progress: maintained during the duration of the account and deleted within 30 (thirty) days after closure.
(c) Conversation data with Orb (texts and audios): retained for up to 30 (thirty) days from each session, being automatically deleted after this period.
(d) Data necessary to comply with legal obligations: maintained for the period required by applicable legislation, even if the account has been closed.
(e) In the event of an account deletion requested by the user, the process will be carried out within up to 15 business days.
2.2.1. The subscriber may request the editing of some of their Personal Data. The user may also request updates, changes, or corrections to their data in certain cases, especially if it is incorrect.