TONGO PRIVACY POLICY

Please read this Privacy Policy carefully before using Tongo.

This Privacy Policy is aimed to inform you (“You”) as a user of Tongo (the “Application”, “App”, “Service”) about the information Funplex Limited (“we”, “us”, “our”), having registered office at Karaiskaki 13, 3032, Limassol, Cyprus, as the Application developer, collects, how that information may be used, with whom it may be shared, and Your options about such use and disclosure. 

This Privacy Policy is incorporated into, and is subject to, the Application’s Terms of Use. 

By choosing to use our Service You: (i) agree to the collection and use of information in relation to this Privacy Policy, (ii) warrant and guarantee that You are over 16 years of age (or are a parent or guardian with such authority to agree to this Privacy Policy for the benefit of an individual under 16 years of age). Please do not use the Application or access the Service provided by it if You do not agree to this Privacy Policy.

What kind of information do we collect?

We may collect information, such as Your name and email address that You provide us with (via email or by other means) to obtain customer support services or for other purposes of communication that You initiate. We also collect information You provide: on your native language, purposes of App use, English level and preferences as regards English-learning process, such as your preferred time frame, favourite topics, genders etc.

We may also collect information that does not directly identify You, as listed below.

Information collected automatically

  • Usage information: information about the use of the App, such as frequency of use, engagement with particular features, which sections of the App user visits and common use patterns.
  • Device information: may include information specific to Your mobile device (e.g., OS Version, hardware model, unique device identifier, mobile network information); information about Your logging in, use of features, functions, or notifications on the device. We also collect and use Your Apple Identifier for Advertising (IDFA) and Google Advertising ID (AAID) to understand how You find our App. These number values are not permanently tied to Your device and, depending on Your operating system, You can reset it through Your device settings
  • Location: IP address, time zone, mobile service provider.

What do we collect this information for?

  • enhancing Your user experience on our Application by operating, maintaining, and providing You with all of the content and features of the Services, including via in-app experience personalization ("maintaining Service functionality purposes");
  • providing You with customer support. We may use Your Information to respond to Your requests for technical support, Service information or to any other communication You initiate (“customer support purposes”);
  • performing research and analysis about Your use of, or interest in, our products, services or content, or products, services or content offered by others (“analytics purposes”);
  • communicating with You via push notifications and/or through other digital methods about App updates (App information). You can opt out of receiving push notifications by changing the settings on Your device;
  • arranging of advertising campaigns, analysis of advertising campaigns effectiveness ("marketing purposes") to the extent permitted by the law;
  • detecting and resolving any fraud or other illegal or undesirable user behavior;
  • taking legally-required actions.

With whom do we share this information and how may we disclose it?

I. Service Providers

We may share Your information with third parties that perform certain services on our behalf, such as our authorized service providers or analytics providers. In general, the third-party providers engaged by us will only collect, use and disclose Your information to the extent necessary to allow them to perform the services they provide to us, e.g. facilitating our Service and analyzing how our Service is used. 

You can learn more about main service providers with whom we may share Your information as described above hereunder, along with links to such service providers privacy policies, which we recommend You to read:

1. AppsFlyer

We use AppsFlyer for analytics purposes, specifically for research and analysis of users’ interaction with the Application.

Appsflyer helps us to understand, in particular, how users find our App (for example, which advertiser served an ad that led You to our App in application store). Appsflyer also provides us with different analytics tools that enable us to research and analyze Your use of the Service.

In order to receive these services from Appsflyer, we share such data as:

  • device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier (“technical information”);
  • information relating to Your actions in the App, such as: downloads and installations of Applications, and other interactions, events and actions, such as add to cart, in-app purchases made, clicks, engagement time etc. (“engagement information”);
  • IP address (which may also provide general location information) and other unique identifiers (“technical identifiers”).

You can learn more about the AppsFlyer Privacy Policy here: https://www.appsflyer.com/privacy-policy/. Please note that You may cancel collection of Your information for and sharing it with AppsFlyer here: https://www.appsflyer.com/optout.

2. Amazon Web Services

We use Amazon Web Services (“AWS”), which is a hosting and backend service provided by Amazon, for data hosting and enabling our Application to operate and be distributed to its users.

You can learn more about the Amazon Privacy Policy here: AWS Privacy Notice and AWS Data Privacy FAQ.

3. Amplitude

We use Amplitude for analytics and customer support purposes, specifically to understand how customers use our App.

As for analytics purposes, Amplitude helps us to understand, in particular, how users find our App (for example, which advertiser had delivered an ad that led You to our App in app store). Amplitude also provides us with different analytics tools that enable us to research and analyze Your use of the Service, which helps us to decide what Application features we should focus on.

As for customer support purposes, Amplitude helps us to respond to Your requests for technical support. For example, it enables us to track Your interaction with our App and in order to detect particular technical issues with the App.

In order to receive those services from Amplitude, we share such data as:

  • Platform, device type (phone or tablet), device family, country, city, region, carrier, OS, time zone, language, IP Address, locale, referral source (“technical information”);
  • Your interaction with the App (i.e. taps on the particular screens) (“user related information”)
  • Unique identifiers.

Amplitude is EU-US Privacy Shield certified, which You can verify and learn more about here: https://www.privacyshield.gov/participant?id=a2zt000000001XZAAY&status=Active .

You can learn more about the Amplitude Privacy Policy here: https://amplitude.com/privacy .

4. Firebase

We use a number of Firebase (platform developed by Google) services for different purposes. In particular, we use:

  • Google Analytics for Firebase (powered by Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland)

As to iOS devices, we use Google Analytics for Firebase in order to assess app performace/minimize crashes, in complex with Firebase Crashlytics (see below). For Android devices, we use Google Analytics for Firebase not only to assess app performace/minimize crashes, but also to assess effectiveness of our advertizing camplaigns. In this regards, we may share/receive some of your data with/from Google, for example your Android Advertizing Identifier, IP address, fact of purchase, interactions with ads. 

Generally, within Google Analytics for Firebase service, Google only processes data based on our instructions, therefore, shall not use the data for its own, not related to described above, purposes. 

  • Firebase Crashlytics (powered by Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland)

Firebase Crashlytics is a Google Firebase service, which allows us to track application performance, i.e. we can discover the causes and severity of crashes in our App. In order to provide the services, Crashlytics collects your device-related and App-interaction data, such as the timestamp of when the crash occurred, technical characteristics of particular crash and your device characteristics etc. Crashlytics shall not use collected data otherwise as to App-related purposes.

Should you with to understand further how Google generally uses the data transferred from our App, please follow the links: www.google.com/policies/privacy/partners/ and https://firebase.google.com/support/privacy#data_protection.  

5. Amazon Mobile Analytics

We use Amazon Mobile Analytics, which is an Amazon service for collecting, visualizing and understanding app usage data at scale, to learn and analyse how our App is being used.

With the Amazon Mobile Analytics help we can collect and analyse the following information regarding our Application:

  • General – monthly active users; daily active users; new users; daily sessions; sticky factor; 1-day retention; average revenue per daily active user; daily paying users; average revenue per paid daily active user;
  • Active users – tracking how many users engage with our App daily and monthly and to monitor their stickiness to improve engagement, monetization and appeal;
  • Sessions – tracking how often our App is used on a given day and how often each user opens our App during a day;
  • Revenue – tracking in-app revenue trends to identify areas for monetization improvement;
  • Retention – tracking the rate at which users come back to our App on a daily and weekly basis.
  • In order to receive these services from Amazon Mobile Analytics, we share such data as:
    • Daily active users, monthly active users and new users;
    • Sticky factor (daily active users divided by monthly active users);
    • Session count and average sessions per daily user;
    • Average revenue per daily active user and average revenue per paid daily active user;
    • Day 1, 3 and 7 retention and week 1, 3 and 7 retention.

You can learn more about the Amazon Privacy Policy here: https://aws.amazon.com/privacy/ .

We recommend that You read all the privacy policies indicated above, so You can understand the manner in which Your information will be handled by these providers.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies with respect to the information we are required to provide to them for Your purchase-related transactions. For these providers, we recommend that You read their privacy policies so You can understand the manner in which Your information will be handled by these providers. For example, Apple and Google may be such third-party companies that provide payments and can be contacted through their websites: https://www.apple.com and https://play.google.com.

6. Facebook [for iOS devices only]

We have implemented a Facebook-powered feature into our App in order to oversee the App installs and App launches. This feature also helps Us to improve our Service by tracking performance of and customizing our ad campaigns. Consequently, We may share some of Your personal data, such as Apple’s Advertising Identifier (IDFA), your device information with Facebook.

7. Front (FrontApp, Inc., 1455 Market Street, 19th Floor, San Franisco, CA 94103)

In order to provide you with swift and smooth customer support we use Front - software allowing us to optimise users' and customer support's conversations. In this regard, Front receives and stores copies of all data related to your customer support requests, such as emails, purchase details, feedback etc.  

II. Law enforcement agencies and other public authorities.

We may use and disclose Your information to enforce our Terms of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, You or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

III. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Information on customers is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

International data transfers

Please note that our business is global, so when You provide Your information through our Service, the information may be sent to servers located in different countries around the world.

How You Can Access Information That You Provided Us With

If You would like to update, correct, receive or erase any information that You have provided to us in the course of customer support services or through other communication initiated by You, please contact us via email at contact@lango-app.com.

How You Can Stop Automated Collection of Your Information

You can stop all collection of information by the Application by uninstalling the Application from Your device. You may use the standard uninstall processes as may be available as part of Your mobile device or via the Application marketplace or network.

Please note that You may also reset Your Apple Identifier for Advertising (IDFA) and Google Advertising ID (AAID) using Your device settings:

iOS: go to “Settings” -> “Privacy” -> “Advertising” -> “Reset Advertising Identifier”.

Android: for Android 6.0 and higher – go to “Settings” -> “Google” -> “Ads” -> ”Reset Advertising Identifier”. For Android 5.2 and lower, use Google Settings app -> “Ads” -> ”Reset Advertising Identifier”.

Retention

We will retain Your information for as long as the Application is installed on Your mobile device or as needed to provide You with our Service. If You remove the Application, we will remove Your information and use copies of Your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How We Secure Your Information

Security is our highest priority. Our App has been designed with Your security and privacy in mind.

  • We protect the security of Your information by using encryption protocols and software;
  • We aggregate all Your information;
  • We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of Your information;
  • We employ Your information systematic backups, which are intended to reduce the risk from disk crashes and errors, such as accidental information deletion.

While we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we make all reasonable efforts to prevent it. However, You should bear in mind that submission of information over the Internet is never entirely secure.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Therefore, You are advised to check our Service occasionally to inform Yourself of any changes. We will notify You of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page. Your continued use of the Application after changes to the Privacy Policy have been posted will constitute Your acceptance of such changes.

CONTACT US

Please submit any questions, concerns or comments You have about this Privacy Policy or any requests concerning Your information via email to contact@lango-app.com.

Last updated October 29, 2021