1. Terms and Definitions
1.1. For the purposes hereof, the following terms and definitions are used:
Web-site - web-site with domain name “lingvoninja.com”.
We (Noirix) - Noirix Limited Liability Company.
You (User) – any individual that is using functional features of the Services and has reached the age of full legal capacity in accordance with the legislation of the country of their citizenship.
Services - the English language learning platform “Lingvo ninja” (including the respective chatbot in Telegram, Viber and VK) and website with the domain name “lingvoninja.com”.
2.1. This Policy shall govern any interaction between Noirix and users related to personal data when using the Services.
2.2. This Policy neither governs nor determines the rights and obligations of third parties. It also does not apply to third-party applications or software available to users for integration with the Services. Thus, if you integrate any third-party applications with our Services, we will not be able to control how such applications process your personal data.
2.3. Please do not use the Services if you do not agree with the provisions and scope hereof.
3. Who determines the purposes and means of personal data collection?
3.1. The purposes and means of how your personal data is collected in these Services are determined by the following legal entity:
4. Personal data we collect
4.1. Personal data is any information that could enable direct or indirect identification of a person (e.g., their name, passport details, online identifier, etc.).
4.2. In accordance herewith, personal data may be collected both directly and indirectly.
(1) Personal data are collected directly when you provide them voluntarily (e.g. when registering in the Services).
4.3. We collect the required minimum of your personal data for the purposes hereof:
(1) account data: name, surname, date of birth, gender/sex, location, time zone, country of residence, email address, phone number (only if using Viber), photo;
(2) user data: chat ID, user ID, user nickname, user actions in the Services;
(3) payment information: the user's transaction list.
5. Data Processing, Storage and Protection
5.1. “Processing” is understood as at least one of the following: storage, modification, retrieval, disclosure, structuring, use, destruction as well as any other action with respect to your personal data.
5.2. We will process your personal data only for the following purposes and on the following legal grounds:
|Data type||Processing purposes||Legal basis||Retention period|
|Account data||We process your account data so that you can use all the functionality of the Services.||Legal interest in providing services and improving them.||Until the user account is deleted.|
|User data||We process your user data so that you can use all the functionality of the Services.||Legal interest in providing services and improving the Services||Until the user account is deleted.|
|Payment information||We process your payment information in order to resolve disputes if they arise, as well as to enable the use of paid features within the Services.||Performance of the contract||Within 5 years from the last use of the Services.|
5.3. Subject to data anonymisation, your personal data may be used by Noirix for any other purposes.
5.4. We do not not use automated decision-making tools (including profiling) in personal data processing. Automated decision-making tools primarily include those systems that process your personal data without human intervention to make decisions that may have potential legal consequences for you.
5.5.Your personal data will be stored on the servers of our counterparties that we are using for operating our Services.
5.6. We use Amazon Web Services for operating our Services. Therefore, your data will be stored on the servers of the following legal entity:
Amazon Web Services EMEA SARL (Luxembourg)
Address: L 1855 38 Avenue John F. Kennedy, Luxembourg
5.6. Employees of Noirix shall also take all necessary organisational, legal and technical measures available to us for protection of your personal data. Users of the Services shall also be responsible to the maximum possible extent for the provision of accurate account details, keeping passwords and any other information required for authorisation confidential and its protection from unauthorised access by third parties.
5.8. Any personal data collected and processed hereunder shall be properly protected unless:
(1) you consent to their disclosure;
(2) such personal data are anonymised;
(3) such personal data are subject to disclosure under the applicable law.
5.9. We will do our best to keep your personal data protected. However, despite any possible measures taken on our part, we cannot guarantee full protection of the Services against information security risks.
6. Transfer and Disclosure
6.1. The following third parties may have access to the personal data you are providing us:
(1) Amazon Web Services EMEA SARL (Luxembourg)
Address: L 1855 38 Avenue John F. Kennedy, Luxembourg
AWS may have access to the personal data that you provide to us because we use their services because we use their services to host our Services.
(2) Google Inc. (Ireland)
Address: Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Google may have access to the personal data that you provide to us because we use their services because we use their GeoAPI service for checking information related to the user's location. The data is transmitted to Google in an anonymized form, indicating only the coordinates of latitude and longitude and without indicating the user's personal data.
(3) Amplitude, Inc. (USA)
Address: 631 Howard Street, Floor 5, San Francisco, CA 94105
Amplitude may have access to the personal data that you provide to us because we use their services because we use their services for logging user actions in the Services so that make further improvement in them.
(4) bePaid (Belarus)
Address: 104 Dzerzhinsky Ave., office 1403/1, Minsk, Belarus, 220116
bePaid may have access to the personal data that you provide to us because we use their service to process payments.
(5) Telegram Messenger LLP (UK)
Address: 71-75 Shelton Street Covent Garden London United Kingdom
Telegram may have access to the personal data that you provide to us because we use their API for operating our chat-bot.
(6) Viber Media S.à r.l. (Luxembourg)
Address: 2, rue du Fossé, L- 1536 Luxembourg, Grand Duchy of Luxembourg
Viber may have access to the personal data that you provide to us because we use their API for operating our chat-bot.
(7) LLC “V Kontakte” (Russia)
Address: prem. 1-N, bld. 12-14, Lit. A, Khersonskaya st., St. Petersburg, Russia, 191024
VK may have access to the personal data that you provide to us because we use their API for operating our chat-bot.
6.2. To ensure the provision of our services, your personal data may also be transferred to a legal entity created after reorganisation of Noirix should it be necessary.
6.3. Please note that disclosure of your personal data may be required in accordance with the law and judicial procedures or at the request of public bodies of the country of your stay or other countries. Your personal data will be disclosed if it is necessary for the purposes of national security, law enforcement, protection of the rights and legitimate interests of Noirix and third parties or for other substantial public interest purposes.
7. Children's Personal Data
7.1. To the extent to which it is not prohibited by the applicable law, we do not authorise the use of our Services by individuals who have not reached the age of full legal capacity in accordance with the legislation of the country of their citizenship. We do not collect and process (at least knowingly) their personal data without the consent of their legal representatives.
8. User Rights
8.1. The rights of users related to the collection and processing of personal data shall be determined in accordance with the applicable law.
8.2. Your rights with respect to the collection and processing of personal data may be determined in accordance with applicable data protection law.
In accordance with applicable data protection law you may access, change and/or make additions to, delete, restrict processing and migration of, object to or withdraw your consent to the processing of your personal data as well as opt-in/opt-out and lodge a complaint to the supervisory authority.
8.3. To exercise any of your rights above and any other rights guaranteed to you by applicable law and if you have any related questions, write to: firstname.lastname@example.org. For issues related to your personal data please contact: email@example.com.
8.4. Noirix reserves the right to verify your identity before exercising any rights at your request. In case we are not able to exercise any of your rights or provide any information, we will also explain the reasons to you.
9. Final Provisions
9.1. This Policy may be amended and (or) modified at any time of the Services operation. In this case, a notice with information about the changes accompanied by the new version of the Policy and date of its adoption will be published in the Services. The User of the Services must read and acknowledge the new version hereof.
9.2. The Policy is an agreement between us and the User about the use of the Services. Any other pre-existing written or oral agreements or arrangements with respect to such use are hereby cancelled.
9.3. If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.
9.4. Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.
9.5. This policy has been drawn up in Russian and English. In the event of any textual discrepancy, the Russian version prevails.
order of the director of Noirix Limited Liability Company (Noirix LLC) dated November 02, 2020
Noirix Limited Liability Company (Noirix LLC) TIN 692149027 was registered by the Minsk Regional Executive Committee on October 18, 2019
Address: Belarus, 220005, Minsk, pr. Nezavisimosti, 39, unit 2H, office 80.
Working hours: on weekdays from 10:00 to 19:00 (Minsk time)