FALOU APP – Privacy Notice

Last Update: January 31st, 2022

Thanks for using Falou - a mobile application brought to you by MOYMER NEGÓCIOS E SERVIÇOS EM TECNOLOGIA LTDA. (“MOYMER”). FALOU APP is a language learning platform and the data related to the use of it is controlled by MOYMER. When we say “FALOU”, “our”, “we” or “us”, we’re talking about MOYMER and this Privacy Notice applies specifically to FALOU APP.

This Privacy Notice explains how FALOU APP collects, uses, and shares information about you when you access or use our mobile application, websites and other online products and services (collectively, the “SERVICES”), and when you contact our customer service team, engage with us on social media, or otherwise interact with us.

We reserve the right to update this Privacy Policy at any time by posting an updated version on our SERVICES. The updated version will take effect on the date of publication. If we feel there will be significant changes, we will notify you by any of the communication channels available to us or via SERVICES. All revisions will be assumed approved by you after the notice period has expired.

If you have questions or comments about our Privacy Policy, please contact us at legal@moymer.com.

For capitalized terms not defined in this Privacy Policy, please refer to our Terms of Service for their respective definitions.

Information we may collect

FALOU APP collects information that is required in the process of enabling use and related to the usage of FALOU APP, as they are indispensable for the performance of the contract held between us, as detailed below:

Usage Information: Whenever you use FALOU APP, we collect usage information, such as the languages you’re practicing, the number of minutes you’ve practiced, the lessons you’ve completed, your level of proficiency in a language, your nickname and other similar types of usage information.

Transactional Information: We may collect information about the transaction when you make a purchase or return, such as the product description, price, subscription or free trial expiration date, and the time and date of the transaction.

Log Information: We may collect standard log files when you use our SERVICES, such as app version, access times and dates, screens viewed and your IP address.

Device Information: We may collect information such as the hardware model, operating system and version, mobile network information, connection type, carrier, and region from the mobile device or computer you use to access our SERVICES.

Direct Contact Information: we may collect and process your personal data when you contact us through our e-mail addresses, social media or any other contact means. These activities are performed to respond to your inquiries and provide the information you request. This information may be used to contact you later, for example, to communicate with you, send you updates and other information that may be of interest to you. You can decide to stop getting these updates by contacting us.

The majority of the app's features may be accessed without entering any personal information or registering with the platform, and these features are immediately available after the user downloads the app. Some features of the app require you to create an account using your Apple or Gmail account. You supply us with information associated with your Apple or Gmail accounts by using them, which may include your name, language preferences, demographic data, location, account ID number/token, and email address). Please note, the FALOU APP doesn’t have control over how any third party uses or discloses the personal data it collects about you.

When you subscribe to become a Premium member, we still don’t collect your personal data. The subscription process is held by third parties, especially your own device’s application store, who just send us a token to confirm the validity of the financial transaction.

Information third parties may collect about you

To be able to correct your speech pronunciation, you have to authorize the use of your device’s speech recognition technology, which may involve the collection of personal data by your device’s manufacturer, such as Apple or Google, for example. In this case, we recommend you to consult your device’s manufacturer about their privacy and data protection policies and practices, as this data may be used by the third party for its own purposes.

Besides that, FALOU APP has some connections with other services, our partners, specially related to analytics and advertising, like Facebook, Google, Flurry, Amazon, Amplitude, Chartboost and Tenjin. These activities are based on our legitimate interest and in our partners legitimate interest, as this data is important to support and enhance the services provided to you. To better understand how third parties process personal data, we recommend you to visit their privacy policies.

FALOU APP may present to you links to access websites and / or other third party applications, with their own content and privacy policy. It is highly recommended that you check the rules of such policies.

It is important to notice that your mobile device may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID), which may help you to control the processing of your information.

Use of Information

FALOU APP uses the information it collects as necessary to provide our SERVICES, to comply with legal and contractual obligations, and to support our legitimate interests in maintaining, improving, and advertising our SERVICES. These includes understanding how our SERVICES are used and how our SERVICES, campaigns, and other activities perform; gaining insights that help us allocate our resources and efforts more efficiently; marketing, promoting, and selling our SERVICES; providing customer and technical support to our users; and protecting and safeguarding our SERVICES, ourselves, the organizations and individuals with whom we work.

FALOU APP operates in several countries around the world. Therefore, please note that if you reside or use our SERVICES in a territory subject to data protection laws where "consent" is the only or most appropriate legal basis for processing data in the manners described in this Policy (generally or specifically with respect to the types of data you expect or choose to have processed by or through the SERVICES), your consent to our Terms of Use and this Privacy Policy will be deemed to be your consent to the processing of your data for all purposes described herein. If you wish to withdraw this consent, please contact us at help@moymer.com.

Promotional Communications: you have the option of opting out of Falou promotional emails by following the instructions contained in these emails or by contacting our team at help@moymer.com. If you opt out of Falou's promotional emails, we may still send you non-promotional emails, such as those about your account.

How we share your information

FALOU APP shares your personal data only when it is necessary to offer the SERVICES, legally required, or permitted by you, as better explained below:

If you want to, you may share information with third party social media:

FALOU APP may offer the option for you to use your own device’s sharing mechanisms, which let you share your progress and other content with other media. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

In some cases, we may share your information with third parties:

• With service providers, sellers, and partners. We may share information about you with service providers who perform services on our behalf, sellers that provide goods through our services, and business partners that provide services and functionalities to bring you the Service;

• If MOYMER gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes;

• We may share non-personally-identifiable information (such as anonymous usage data, referring/exit pages, platform types, asset views, etc.) with interested third parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions and/or functionality on Moymer.

In some cases, we may share your data with third parties for legal reasons:

• Comply with any valid legal process, government request, or applicable law, rule, or regulation;

• Investigate, remedy, or enforce potential Terms of Service violations;

• Protect the rights, property, and safety of us, our users, or others; or

• Detect and resolve any criminal (including fraud or stalking), security or technical issues.

How long we keep your content

We will retain your data and information as long as needed to provide you the SERVICES as well until needed to the performance of the contract held between us.

Please be aware that we will not be able to delete any content you have shared with others or with social media sites, which only you can do directly in your social media provider. You should understand that users who see the content you provide can always save it using any number of techniques: screenshots, in-app functionality, or any other image-capture or audio recording technology. It’s also possible, as with any digital information, that someone might be able to access messages forensically or find them in a device’s temporary storage.

We do not retain personal data longer than is necessary for the purposes for which it is processed, unless applicable law requires longer retention.

Your data rights

Our goal is to give you simple and meaningful choices over your information. You have the rights to:

• Access personal data we hold about you and to ask that your personal data be erased, corrected, or made available in a portable form;

• Request us to restrict or stop processing the Personal Data we hold about you;

• Withdraw a consent you previously gave us to process your Personal Data, if any;

• Change your mobile device permission settings to enable or disable access to the microphone, camera, photos, location services, or push notifications;

• Contact us at help@moymer.com asking us to stop sending you emails;

• Stop using the FALOU APP at any time. If you stop using our Service we will automatically stop receiving information about you;

• Delete your account directly on your own device or by sending an email to help@moymer.com;

• You have the right to file a complaint about our privacy practices with a supervisory authority. Please, you can always visit this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en. Otherwise, if you live in Switzerland, you can visit this FDPIC website for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html. Lastly, if you live in the United Kingdom, please refer to this website for contact details: https://ico.org.uk/global/contact-us/.

Data Location

We and our authorized Service Providers keep, store and process personal data at the various locations where we operate around the world, including in the U.S., Brazil and the EU, to the extent necessary for the proper performance and provision of our services or as required by law.

Although data protection laws may vary from country to country, MOYMER, its affiliates and Service Providers are committed to protecting personal information in accordance with this Privacy Policy, customary industry standards, and the appropriate legal mechanisms and contractual terms that require adequate data protection, notwithstanding any lesser legal requirements that may apply in the jurisdiction to which such information may be transferred.

Security

We take reasonable precautions to protect personal information from misuse, loss and unauthorized access. Although we cannot guarantee that personal data will not be subject to unauthorized access, we have physical, electronic and procedural safeguards in place to protect personal information, as well as our partners and service providers. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. If MOYMER identifies a security breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. MOYMER may also post a notice on the MOYMER website, via email or through a FALOU APP message if a security breach occurs.

Children

Our SERVICES are not intended for anyone under the age of thirteen (13). If you are under the age of thirteen (13) you may not use FALOU APP. If you are between thirteen (13) and eighteen (18) years old, you must review this Privacy Policy with your parent or guardian. If you find that your minor child has provided us with personal information without your consent, please contact us at help@moymer.com.

California Residents Rights

California residents have the right to:

• Know what personal data we collect about you and from where we obtain it;

• Access a copy of the personal data we hold about you;

• Understand how we process your personal data and how we may share it;

• Opt out of having your personal data shared with certain third parties;

• Request the deletion of your Falou account and personal data.

To make such a request, please send an email to help@falou.app.

Contact Us

If you have questions or comments about our Privacy Policy, please contact us:

All messages should be sent to: legal@moymer.com

MOYMER NEGÓCIOS E SERVIÇOS EM TECNOLOGIA LTDA.

Rua Domingos de Morais, 2187

Vila Mariana, São Paulo, SP, BRAZIL, CEP 04035-000