PRIVACY POLICY
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Welcome and thank you for your interest in SPEEQO. You are reviewing Privacy Policy to be used with use of SPEEQO’s products. If you have any questions, please feel free to contact us at support@speeqo.com

GENERAL  
This privacy policy ("Policy") describes how the personally identifiable information ("Personal Information") you may provide on the speeqo.com and SPEEQO’s products, software, and range of services (collectively, referred to as the “Products” and or "Services") is collected, protected, and used. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy is a legally binding agreement between you ("User", "you" or "your") and SPEEQO Limited ("SPEEQO", "we", "us" or "our"). By accessing and using the Products and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

TONELINGO PROVISIONS
We offer a product named "tonelingo" that processes data on behalf of third parties, specifically capturing feedback from users. The data processed by "tonelingo" is governed by the respective privacy policies of the third parties we serve. We act as a data processor in this regard, and any data collected is solely for the purpose of providing feedback analysis to our third-party clients. Users of third-party services that utilize "tonelingo" should refer to the respective service's privacy policy for more information on data handling and rights.

CONSENT
Before processing data related to speech analysis, explicit consent is obtained. This consent is given by users during registration, in certain applications when submitting an audio recording, or by clicking on a button which reasonably suggests that your Contribution will be submitted. Users are always recorded with full knowledge and awareness.

AUTOMATIC COLLECTION OF INFORMATION
Our top priority is customer data security. We may process only minimal user data, only as much as it is absolutely necessary to maintain the Products and Services or as much information you decide to willingly provide to us. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Products and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the speeqo.com website who is not registered and is not using the Products under their registered email.

COLLECTION OF PERSONAL INFORMATION
You can access and use the speeqo.com website without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features on the Products, you may be asked to provide certain Personal Information (for example, your name, your organisation name and e-mail address). You are required to use unique Student ID for any person under age of 18 years old, which will help prevent revealing any information by which such person could be identified a specific, identifiable individual.

Everything that you post, add, upload or make accessible to the Products is considered a “Contribution” to the Products. We receive and store any information you knowingly provide to us when you create an account, make a Contribution, or fill any online forms. We perform analysis of some of your Contributions. Some of the Contributions you make may include metadata related to such Contributions, such as the location where it was made. While performing analysis of some of your Contributions, new data is created and stored and such data is separated from any personal information by which the subjects could be identified.

When required, the collected information may include the following:
- Personal details such as name, gender, age etc.
- Account details such as user name, unique user ID, Student ID, password, etc.
- Any other materials you willingly submit to us as a Contribution such as audio recordings, video recordings, feedback, etc.

USE AND PROCESSING OF COLLECTED INFORMATION
In order to make the Products and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
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- Create and manage user accounts
- Improve products and services
- Send administrative information
- Respond to inquiries and offer support
- Request user feedback
- Improve user experience
- Enforce terms and conditions and policies
- Protect from abuse and malicious users
- Respond to legal requests and prevent harm
- Run and operate the Products and Services

Processing your Personal Information depends on how you interact with the Products and Services, where you are located in the world and if one of the following applies: (1) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law; (2) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (3) processing is necessary for compliance with a legal obligation to which you are subject; (4) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (5) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract. It's also worth noting that processing information without relying on consent is not our standard practice.
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COOKIES AND TRACKERS
The website uses cookies, commonly found on startup websites selling B2B products, to enhance user experience. Users have the option to opt-out by rejecting these cookies. Currently, the only tracker used is Google Analytics. However, there's a possibility of incorporating more trackers in the future as needed.

BILLING AND PAYMENTS
In case of services requiring payment, we request payment account information, which will be used solely for processing payments. Payments are currently made by money order and we collect the payment information you give us and securely store it.

MANAGING INFORMATION
You are in control of whether or not you give us personal information and you are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Products and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so by asking administrator of your account or simply by contacting us. Personal information of Users associated with the organisation which is our customer is retained while the customer relationship is in place or until we are advised that the User is no longer associated with that customer.

DISCLOSURE OF INFORMATION
Depending on the requested Products and Services or as necessary to complete any transaction or provide any service you have requested, we may share your information with your consent with our trusted third parties that work with us, any other affiliates and subsidiaries we rely upon to assist in the operation of the Products and Services available to you. We do not share Personal Information with unaffiliated third parties. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. We may share your Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. These third parties are given Personal Information they need only in order to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes.

We will disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and Personal Information will likely be among the assets transferred.

RETENTION OF INFORMATION
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

TRANSFER OF INFORMATION
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire with us using the information provided in the contact section.

RETENTION AND AUDITS
Personal information is retained for as long as necessary to fulfil legal obligations or agreements. After this period, the data is deleted. Regular privacy audits are conducted to ensure GDPR compliance and address any potential vulnerabilities.

DATA MINIMIZATION
SPEEQO ensures that only the minimum required data to ensure accurate outputs and results is collected and processed.

THE RIGHTS OF USERS
You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (1) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (2) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (3) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (4) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (5) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (6) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (7) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

THE RIGHT TO OBJECT TO PROCESSING
Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.

GDPR DATA PROTECTION RIGHTS
If you are a resident of the European Economic Area (EEA), you have certain data protection rights and SPEEQO aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

- You have the right to request access to your Personal Information that we store and have the ability to access your Personal Information.
- You have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request us to complete the Personal Information you believe is incomplete.
- You have the right to request the erase your Personal Information under certain conditions of this Policy.
- You have the right to object to our processing of your Personal Information.
- You have the right to seek restrictions on the processing of your Personal Information. When you restrict the processing of your Personal Information, we may store it but will not process it further.-  You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- You also have the right to withdraw your consent at any time where SPEEQO Limited relied on your consent to process your Personal Information.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

CALIFORNIA PRIVACY RIGHTS
In addition to the rights as explained in this Policy, California residents who provide Personal Information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the Personal Information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please contact us.

Furthermore, California residents have the right to opt-out of the sale of their Personal Information which may include selling, disclosing or transferring Personal Information to another business or a third party for monetary or other valuable consideration. To do so, please contact us.

EXERCISE OF YOUR RIGHTS
Any requests to exercise your rights can be directed to SPEEQO through the contact details provided in this Privacy. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

PRIVACY OF ANY PERSON UNDER THE AGE OF 18 YEARS OLD
We recognize the need to provide further privacy protections with respect to Personal Information we may collect from any person under the age of 18 years old ("Minor") and take many special precautions to protect the privacy of minors. We do not require any person under the age of 18 years old to disclose more information than is reasonably necessary to use the Products and Services. We encourage any person under the age of 18 years old to consult with their educators or parents before submitting any information to any online resource, including our Products and Services. We believe educators and parents should be involved in use of the Products and Services, and the online activities of their Minors and we suggest that educators and parents do their best to provide their Minors with a safe and friendly online environment.

DO NOT TRACK SIGNALS
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Products and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your personal information.

NEWSLETTER
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

LINKS TO OTHER RESOURCES
The Products and Services may contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Products and Services and to read the privacy statements of each and every resource that may collect Personal Information.

INFORMATION SECURITY
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (1) there are security and privacy limitations of the Internet which are beyond our control; (2) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (3) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

DATA BREACH
In the event we become aware that the security of the Products and Services has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will send you an email.

CHANGES TO THE POLICY
We reserve the right to modify this Policy or its terms relating to the Products and Services from time to time in our discretion and you be notified of any material changes to the way in which we treat Personal Information. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Products and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

ACCEPTANCE OF THE POLICY
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Products and Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Products and Services. We urge you to discontinue using our Products and Services immediately.

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may send an email to support@speeqo.com.
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This document was last updated on 18th of August 2023