Effective Date: February 1, 2018

SpeakApp Inc. d/b/a Conversifi (“Conversifi”, “we”, “us”, or “our”), recognizes the importance of privacy. In this Privacy Policy, we describe how we collect, use, and disclose information that we obtain about visitors to our website conversifi.com (the “Site”), users of the Conversifi web-based application (the “App”), and the services available through our Site and App (such services, along with the Site and App, are hereinafter collectively referred to as the “Services”).

By using any of our Services, you agree that your information, including personal information, will be handled as described in this Privacy Policy. You further agree that you will respect the privacy of other Conversifi users, such as by not sharing coaching videos outside of the Services. Your use of our Services, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this Privacy Policy.

Information We Collect

We collect information about you directly from you and automatically through your use of our Services. We may combine all of the information we collect about you from these various sources.

• Information We Collect Directly From You. We may collect certain information directly from you. If you register with us, we may collect information from you, such as your email address, password, Conversifi handle, city, country, native language, country where native language was learned, and university course information. We will also collect any other information that you provide to us through our Services, such as your name, photo, gender, date of birth, phone number, and videos / recordings of your conversations with other Conversifi users.

• Information We Collect Automatically. We automatically collect information about your use of our Services, which we may combine with other information we have about you. Such information may include, without limitation: domain name; browser type; device ID; operating system type; device name and model; pages or screens you view; links you click; Internet protocol (“IP”) address; when and the length of time you visit or use our Services; and the referring URL, or the webpage that led you to our Services.

User Content

You may post content to our Services, such as lessons-learned and comments (collectively, “User Content”), and any other information that you would like to be available on our Services. If you post User Content to our Services, that User Content, and related information, such as the Conversifi handle, city, and country may be available to other users, including coaches, classmates, and Conversifi users you follow, and we cannot prevent such information from being used in a manner that may violate this Privacy Policy, the law, or our users’ personal privacy.

How We Use Your Information

We may use your information, including personal information and User Content, for the following purposes:

• Providing and Improving Our Services. To provide and maintain our Services; to improve our Services; to develop new features or services; to authenticate users; to facilitate payments and communications; to perform technical operations, such as updating software; and for other customer service and support purposes. Please note that in order to evaluate and improve our Services, we may watch video recordings that you create or share through our Services.

• Tailoring Content. To tailor the content and information that we may send or display to you, and to otherwise personalize your experiences while using our Services.

• Marketing and Communications. To communicate with you about your account and use of our Services; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes.

• Research and Analytics. To analyze how you interact with our Services; to monitor and analyze individual and collective usage trends; and for other research, analytical, and statistical purposes.

• Protecting Rights and Interests. To protect the safety, rights, property, or security of Conversifi, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, complaints, or technical issues; to prevent or stop activity that Conversifi, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, legally actionable, or inappropriate activity; to use as evidence in litigation; to conduct audits; and to enforce this Privacy Policy and our Terms of Service.

• Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

How We Disclose Your Information

We may disclose your information, including personal information and User Content, in the following ways:

• Convesifi Users. We will disclose your information – such as your Conversifi handle, your current city and country, the country where you learned the relevant language of discussion, your feedback on a session, and your social posts made on Conversifi – with other Conversifi users. If you engage in conversations with other Conversifi users, then your information, including voice and video recordings, may be shared with those conversation partners. If you use Conversifi as part of a college or university course, we will also share information with your instructor, including a report of your activities on Conversifi.

• With Your Knowledge or Consent. We may disclose your information to other third parties with your knowledge or consent. For example, you may choose to share posts and other content from our Services to social media platforms (e.g., Facebook).

• Service Providers. We will disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf. For example, we share information with mLab, which is a cloud database service. To learn more about mLab’s privacy practices, please see the mLab Privacy Policy.

• Affiliates. We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Policy.

• Business Transfers. We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.

• Protecting Rights and Interests. We may disclose your information to protect the safety, rights, property, or security of Conversifi, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, complaints, or technical issues; to prevent or stop activity that Conversifi, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, legally actionable, or inappropriate activity; to use as evidence in litigation; and to enforce this Privacy Policy and our Terms of Service.

• Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.

• Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for research, compliance, marketing, advertising, or other purposes.

Cookies and Other Tracking Mechanisms

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Services. We or our service providers may combine this information with other personal information we collect from you.

Cookies. We or our service providers may use cookies to track visitor activity on our Site. A cookie is a text file that a website transfers to your computer’s hard drive for record-keeping purposes. We or our service providers may use cookies to track user activities on our Site, such as the pages visited and time spent on our Site. Most browsers allow users to refuse cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies may not be able to browse certain areas of the Site.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with our Services to track the activities of users of our Services, help us manage content, and compile statistics about usage of our Services. We or our service providers may also use clear GIFs in emails to our users to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third-Party Analytics

We use third-party analytics companies to evaluate use of our Services. We or our service providers use these tools to help us understand use of, and to improve, our Services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.  To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do Not Track Disclosure

Our Site does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com/.

Third-Party Links

Our Services may contain links to third-party websites or applications. Any access to and use of such linked websites or applications is not governed by this Privacy Policy but instead is governed by the privacy policies of those third-party websites or applications. We are not responsible for the information practices of such third parties.

Security

We have taken steps to help protect the personal information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your device login information private.

Your Choices

• Correcting or Deleting Personal Information. You may correct or request deletion of your personal information by updating your profile or emailing us at support@conversifi.com. Please note that we may retain certain information about you as required by law or as permitted by law for legitimate business purposes (e.g., in accordance with our record retention policies or to enforce our Terms of Service).

• Opting out of Email Communications. We may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email or emailing us at support@conversifi.com. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving marketing emails from us, we may still send you non-promotional emails (e.g., about your account with us).

Children

Our Services are not targeted to children under thirteen (13) years of age, and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.

Contact Us

If you have questions about the privacy aspects of our Services, please contact us at support@conversifi.com.

Changes to this Privacy Policy

This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes, including any material changes, to this Privacy Policy on our Site.