Privacy Policy

A. Conclusion and management of Clients’ contracts

To facilitate the provision of services online (including the execution of the contract and the completion of the specific order, communication with the user of the Website and sending information messages about the stages of the contract, providing clarifications related to the order and, in general, information on the purchases made). For this purpose, we may collect the following data, within the limits of the needs: Identification data: name and surname, the company you represent, industry, you position; Contact details: phone number/e-mail address, delivery address, billing address, Financial data: payment data, Account data: services history, favorite services, Client relationship data and Services interaction data.

Legal grounds: conclusion and execution of the contract with you when we talk about processing operations that have a close connection with our contractual relationship and our legitimate interests: to prove the performance of our contractual obligations or the imputation of non-performance of the contract; to ensure the quality of our services and proper management of the relationship with Clients; to keep adequate records of the orders placed and/or the instructions specific to the related contractual relationships; proper communication with you to ensure the proper delivery of services and adequate information on our services; facilitating the placement of orders, their tracking and their modification/ cancellation; providing benefits for Clients loyalty.

How long do we keep your data (depending on the specific situation): the data closely related to the contract and the customer account will be kept for the entire duration of the contractual relationship, plus at least another 3 years after the termination; in the event of disputes/investigations/procedures, the data and documents will be kept for the duration of their development, and for a period of 3 years from the final settlement. 

What happens if you do not provide us with the data from the standard forms / or requested by our colleagues: the data we ask you for is mandatory for the proper conclusion / modification and execution of the contract. The refusal to provide those data marked by us as mandatory may prevent the conclusion of the contract, affect its proper performance, lead to the cancellation or suspension of the services, as the case may be.

 

B. Billing and payment processing

Such includes: (i) processing the payments you make - payment to our bank accounts or reimbursements made by us; (ii) issuing invoices for the services purchased, collecting the correct amounts, or repaying the correct amounts on request; (iii) communicating with you to ensure the correct payment of the services/clarify the status of a payment; 

We use the following categories of data: Identification data (such as your first and last name), position; Contact details (such as business address, e-mail address, telephone number); Account data (such as invoices, payment history, history of any other information related to the payment of the services, gift cards); Financial data, as well as any other information you request/provide to us or the person acting for you. 

Legal grounds: our legitimate interests: to ensure the payment in good conditions of the services, validate payments with errors, facilitate the delivery of orders on time in case of erroneous payments, ensure the processing of payments in an efficient and easy way for Clients; the conclusion and execution of the contract with you; our legal obligations: to include certain information in invoices or to request certain information in case of reimbursement of amounts of money, to keep records of orders and related payments, to make available information and report to public authorities.

How long do we keep your data (depending on the specific situation): billing-relevant information (including contracts), payment records and documents relating to the settlement of payments, will be kept for 10 years from the time of the end of the financial year in which it was issued/concluded; correspondences with you related to the above purpose will be kept for the duration of the relationship with you (as long as you have an active account with us), for a maximum of 10 years after creation; 

What happens if you do not provide us with the data from the billing order forms or requested by our colleagues: the requested data is mandatory for the proper processing of the payment and the issuance of invoices to you; without them we cannot issue you the invoices according to the law, respectively the payments cannot be processed properly and thus we will not be able to provide the services to you/the company you represent, your services being suspended/terminated, as the case may be.

 

C. Assistance and management of the relationship with Clients, respectively: 

• informing about the amounts owed to us, the status of payments and / or consequences of non-compliance with the contracts you have concluded with us; 

• managing any questions or requests, including complaints you or other persons may have regarding our services/contractual relationship with us, including to provide you with any information required by law; 

• sending messages about services purchased or benefiting from free of charge (so-called 'functional messages'). 

We would like to keep you informed about various aspects related to the services you have bought, for example regarding the modification of our terms and conditions or the removal of some services from the Website, the termination of the contract, or other accessories for the services necessary for their operation. 

We use the following data: Identification data (such as name, surname); Contact details (such as e-mail address, telephone number, home address, mailing address); Client relationship data (such as delaying services delivery, services defects, payment errors and any other issues raised by you); any other data provided by you by means of the requests and documents submitted in support thereof; any other data in the categories listed above related to the relationship with you necessary for the settlement of requests.

Legal grounds: conclusion and execution of contract for orders placed by you or for you, in relation to activities closely related to the contract; our legitimate interests to ensure the proper performance of the contract and a good relationship with you and to defend our rights and interests in judicial, administrative or similar proceedings, or to properly manage any request you submit to us and to improve our services; specific legal obligations in the field (e.g., the processing of certain data on a mandatory basis in the form dedicated to the complaint and for settlement, the obligation to send you the invoice for your order, etc.); your consent if you contact us by phone and the call is recorded. 

 

How long do we keep your data (depending on the specific situation): during the resolution of your request and after the settlement for a duration of 3 years for the solved claims, respectively for the duration of any disputes / procedures and for a duration of 3 years after their final settlement, or, as the case may be, for other durations imposed according to our legal obligations. 

What happens if you do not provide us with the data from the standard forms / or requested by our colleagues: the data we request from you is mandatory for the proper resolution of your requests. Your refusal to provide that data may prevent or affect the full resolution of your request. (e.g., refusal due to lack of sufficient information, delays, partial settlement, etc.), and implicitly the services, if they depend on the resolution of your request. If you choose to contact us through another communication channel operated by a third party (e.g. WhatsApp, Facebook) we will share your personal data with the owner of this channel to confirm that you are a user of this service. We recommend that you check your privacy settings and read the privacy policy of the respective operators to obtain more detailed information on how they use the personal data of users of the services they provide. If you do not agree to the recording of calls, you can contact us on the other communication channels.

 

D. Promoting our image and services. Improving the relationship with Clients

For the purpose of communicating commercial materials, newsletters and / or alerts from LinguaNova, consisting of information on service offers, invitations to participate in campaigns and lotteries, studies, questionnaires, opinion polls, vouchers and / or gift vouchers offered on birthdays sent by electronic mail (e-mail, SMS, M.M.S.), push notifications, social media platforms on which you have an account and / or phone call, for marketing purposes, respectively to promote LinguaNova services and to improve the experience offered on our Website. 

What data we use: Identification data: name, surname; Contact details: e-mail address, telephone number, postal address; Data regarding your qualification; Client relationship data; Account details.

Legal grounds: regardless of the type of services we use: 

• calls (human or automated), e-mails, online channels – based on your consent; 

• mailing address to promote you our services and our activity (post / courier) – based on our legitimate interest in keeping you up to date about the services that may be of interest to you. If you no longer wish to receive such communications, please send us your opposition at the coordinates at the end of this Policy; 

• your choice marketing and respectively the proof of acknowledgment of this privacy policy – based on our legitimate interest in keeping a record of compliance with our specific obligations in the matter and in defending our rights and interests, if any.

You can unsubscribe from these communications at any time by clicking the “unsubscribe” link or button in our messages or by writing to us at info@linguanova.live.  If you withdraw your consent or do not provide us with contact details for this purpose from the start, you will no longer receive commercial communications from us by e-mail, telephone (including automated calls) or online channels.

How long we keep your data (depending on the specific situation): we keep your marketing option and respectively the proof of acknowledgment of this privacy policy during the period when it is not withdrawn, respectively for a period of 3 years from the withdrawal, and by way of exception, during any procedures / disputes / controls involving these data.

 

E. Economic, financial and administrative management. 

We process your personal data to optimally organize and streamline our work. In this regard, we can use the data, among others: to improve and optimize the activity of LinguaNova as well as our services; to support our position in various investigations, administrative and judicial procedures, litigations, etc. in which LinguaNova is involved; in the context of various analyses, internal audit procedures and/ or investigations carried out by LinguaNova, on its own initiative or as a result of receiving a referral from a third entity (including public authorities); management of controls/investigations triggered by public authorities.  

We use Account Data, Identification Data, Contact Details, depending on the typology of the investigation / purpose pursued; Financial Data, Client Relationship Data.

Legal grounds: our legitimate interest to improve our services and relationship with Clients, to optimize and streamline our activity, including by sharing data with our affiliates, but also to defend our interests and rights, to properly manage the payment process for the services provided, to adequately research the activity and identify potential irregularities, respectively to comply with the requirements of public controls; our legal obligations, such as to issue invoices in a certain format, to transmit them in a certain way, to keep records and supporting accounting documentation. 

We can obtain the data from: the competent authorities (for example, the O.P.C.), when circulating with new notifications on complaints / referrals / other aspects; other persons, who may provide us with data according to your request, when acting as your proxies in relation to LinguaNova; our financial and banking service providers, for payments made directly by you to our bank accounts; other service providers, depending on the specifics of the investigation. 

How long we keep your data (depending on the specific situation): during the investigations/procedures/audits, including the recovery procedures and after the settlement for a period of 3 years; during any disputes, if any, and 3 years after receipt of a final decision, for the duration imposed by the public authorities, within the limits of their competences. 

What happens if you do not provide us with the data: the data we request from you is mandatory for the proper resolution of the investigated situations. The refusal to provide data in line with the legal provisions may affect our contractual relationship.

 

F. Defending the rights and interests of LinguaNova and our Clients

We use any of the data categories in the LinguaNova systems, appropriate to the type of procedure/investigation/litigation/official audit. 

Legal grounds: our legitimate interests to defend our rights and interests in the context of situations in which LinguaNova's image and interests would be exposed or affected, respectively to keep evidence of our rights and interests as well as our compliance with specific legal obligations (for example, solving complaints within the time limit required by law or data protection, the manner of settlement, identification and proof of identification of clients/other individuals before making changes in orders/providing customer account data, etc.); our legal obligations, such as those to comply with the requests of public authorities / courts / other public institutions that have the power to impose certain processing operations on us; the obligation to archive certain documents/information according to the archiving rules or other regulations applicable to LinguaNova; the obligation to notify confidentiality/security incidents to the competent authorities, etc. 

 

From where we may obtain the above data: from any of the sources mentioned in the above purposes, as well as from the authorities, institutions or courts involved.

How long we keep your data (depending on the specific situation): for the duration required by the specific legal provisions; where there are no rules, during the procedure/audit/investigation/dispute, and for a period of 3 years from the end of that procedure, taking into account the limitation period applicable to the specific situation; for the duration imposed by the competent authority/institution/court, according to the legal provisions; for the duration requested by you for the protection of your rights and interests or of a third person who has a legitimate interest in doing so. 

What happens if you do not provide us with the data: In certain situations, refusing to provide us with data may result in your contractual or civil liability in relation to LinguaNova, other persons whose rights/interests would be affected.

 

G. Fulfillment of legal obligations 

For the fulfillment of the legal obligations’ incumbent on LinguaNova in the context of the services provided through the Website, including the obligations in tax matters, as well as in archiving matters. (e.g., issuing tax invoices related to the services or granting the guarantee associated with such). Any of your personal data above may be processed. 

Legal grounds: The processing of your data for this purpose is necessary based on legal obligations when the law expressly provides for the processing of certain data – e.g. providing the guarantee, the obligation to archive certain documents / information according to the archiving rules or other applicable regulations; the obligation to notify confidentiality / security incidents to the competent authorities, respectively our legitimate interest in complying with legal obligations involving certain processing, where the law does not establish exactly what data will be processed, such as those to comply with the requests of public authorities / courts / other public institutions that have the competence to impose certain processing operations on us; the obligation to notify confidentiality/security incidents to the competent authorities, etc. 

What happens if you do not provide us with the data: In certain situations, refusing to provide us with data may result in your contractual or civil liability in the relationship with us, or may even lead to the termination / non-conclusion of the contract with you if we are talking about mandatory data for our relationship.

 

H. Mergers and Acquisitions 

If we are involved in a corporate law transaction (for example, merger, spin-off or sale of the business), we will share or, as the case may be, receive your personal data from the entities involved. We transfer/receive your personal data and for the purpose of integrating databases with the clients of the companies involved in the transaction. For this purpose, we transfer certain Contact Details, Account Details or other data related to you to the companies involved in the transaction as a beneficiary for the integration of customer databases in the transfer in which you are already a client of the other entity involved in the transaction. In the transfer of a planned corporate transaction (e.g., in which our Group or we buy or sell a business), we may use (communicate to the party involved in the transaction) your personal data, personal information to identify and plan the best way to realize any commercial opportunities and possible improvements quickly and efficiently in services in the transfer of that corporate transaction. For example, we may communicate or obtain certain Client data, such as Contact Details, Account Details (e.g., the type of offers/benefits used). As a rule, this information will be transmitted/received in pseudonymized or anonymized form. In all cases, we will additionally communicate or process (as the case may be) personal data only based on an appropriate analysis and risk mitigation measures to ensure that they are not prevalent fundamental rights of the data subjects that could be affected. 

Legal grounds: the legitimate interest of us and/or the third-party entity (party to the transaction) to identify, plan and implement the best way to realize any commercial opportunities and database integration when appropriate and possible service improvements, or your consent quickly and efficiently. 

How long we will keep the data: the data extracted for this purpose will not be kept separately longer than during the acquisition process and for 3 years after its conclusion. If they are the subject of formal procedures, disputes, the retention periods specific to these purposes will apply.