Privacy Policy

Version 2026 – 1st February

Any amendments or updates to this Policy will take effect immediately upon publication on www.lingutor.com.

1. Scope of this Privacy Policy

This Privacy Policy outlines how Lingutor.com (hereinafter "we" or "the Company") collects, uses, and protects personal data. It applies to:

• Visitors of www.lingutor.com (including api.lingutor.com, lingutor.com, universitetas.lt and other subdomains),
• Users of our mobile or desktop applications (hereinafter "Application"),
• Customers and other users of our platform and services (hereinafter "Services").

Please read this Policy carefully. It explains how we handle your personal data. The Policy may change over time; we recommend checking it each time you visit our website. The most recent version is always available online.

Our Contact Information:

• Legal entity code: 305591065
• Email: info@lingutor.com

2. Why and What Data We Collect

2.1. For Providing Services

We collect personal data to deliver the Services and allow full use of the Lingutor.com platform.

Data Collected:

• Game security information, such as device details, used to ensure a fair gaming environment.
• Account information, including nickname, name, username, surname, user ID, email address, learning statistics and etc.
• Device information, such as device identifier, model, operating system, network, screen, system performance data etc.
• Student-provided data: uploaded photos, manually added words, lesson/chapter titles, selected settings, completed reports, and other entries.
• Data analytics information, including device details, identifiers, app attribution data (which may be collected via third parties) etc.
• Location information, such as country/region details, IP address (used only to determine general location, without disclosing your precise location) etc.
• Game data, including in-game activity logs, game statistics etc.
• In-app chat data, such as text etc.
• In-app purchase and transaction records.
• Customer support information.
• User-submitted content, including survey and marketing feedback, prize distribution details, user-uploaded content etc.

Legal basis: Performance of a contract (Article 6(1)(b) GDPR)
Retention period: While Services are provided, and longer if required for legal obligations, disputes, or claims.

2.2. For Newsletters and Marketing

We may use your email or phone to send news, offers, or surveys.

Legal basis: Consent (Article 6(1)(a) GDPR)
Retention period: Duration of Services + 3 years after termination. You can unsubscribe anytime via email links.

2.3. Communication with Us

We collect your name, contact information, messages, attachments, and communication history.

Legal basis: Consent (Article 6(1)(a) GDPR)
Retention period: 10 years from the end of the communication, longer if necessary for legal purposes.

2.4. Social Network Interactions

We may process data from social networks: name, contact info, comments, likes, follows, messages, photos, feedback, and ratings.

Legal basis: Consent (Article 6(1)(a) GDPR)
Retention period: 10 years

2.5. Website Usage and Cookies

We automatically collect data when you visit lingutor.com:

• IP address, operating system, user ID, activity logs
• Cookies (see Section 7)

Legal basis: Legitimate interest (Article 6(1)(f) GDPR)

3. Data Sharing

3.1. Within the EEA

• Amazon Web Services or other EU-based cloud providers
• IT, accounting, legal, and marketing service providers
• Website hosting and content management providers
• Payment service providers
• Government or law enforcement authorities

3.2. Outside the EEA

• Payment processors (e.g., Paysera) using Standard Contractual Clauses (SCC)
• Social networks and advertising platforms (e.g., Facebook, Google) using SCC

4. How do we protect your personal data?

When processing and storing your personal data, we implement organisational and technical measures to ensure the protection of personal data against accidental or unlawful destruction (e.g. regular data backup), alteration, disclosure, as well as against any other unlawful processing. Secure use of our website is ensured by one of the world's most prominent Secure Socket Layer (SSL) certificates. The information sent between the user's browser and our server is encrypted with an SSL certificate. Details of the certificate can be found at www.ssls.com.

5. Your Rights

Under GDPR, you have the following rights:

1. Right to be informed (GDPR, Articles 12-14)

2. Right of access (GDPR, Article 15)

3. Right to rectification (GDPR, Article 16)

4. Right to erasure ("right to be forgotten", GDPR, Article 17). Teachers can delete data by signing in and then via Settings → Delete in their account. Students must request deletion by email (info@lingutor.com). Parents may request deletion for minors. Deleting the application triggers automatic deletion of personal data(after some time data will be deleted because of no activity), more information in Terms & Conditions.

Attention! Conditions for erasure:

- Data is no longer necessary for the original purpose

- Consent is withdrawn with no other legal basis for processing

- Objection under Article 21(1) GDPR without overriding legitimate grounds

5. Right to restrict processing (GDPR, Article 18)

Attention! You only have the right to restrict the processing of your data when:

- When data is inaccurate

- When processing is unlawful, but you do not want erasure

- When data is no longer needed but required for legal claims

- When objecting to processing under Article 21(1), unless overridden by legitimate reasons

6. Right to data portability (GDPR, Article 20)

7. Right to object (GDPR, Article 21)

You can exercise these rights via info@lingutor.com. Complaints can also be submitted to the State Data Protection Inspectorate in Lithuania: ada@ada.lt.

6. Third-Party Websites

Our website may link to third-party websites or services. We are not responsible for their privacy practices. Please review their privacy policies directly.

7. Cookies

We use essential, marketing, and statistics cookies to improve website performance and user experience.

Examples of Cookies:

• _ga – Statistics; distinguishes users; expires 2 years
• _gid – Statistics; distinguishes users per session; expires 24 hours
• _gat – Statistics; throttles requests; expires 1 minute
• _fbp – Marketing; Facebook Pixel; expires 90 days
• _fbc – Marketing; tracks ad clicks; expires 90 days
• _hjAbsoluteSessionInProgress – Statistics; Hotjar session; expires 30 min
• _hjIncludedInSessionSample – Statistics; session sampling; expires 1 day
• _hjIncludedInPageviewSample – Statistics; pageview sampling; expires 1 day
• token – Functional/Security; authentication token; session or 3 hours
• session_id – Functional; user session; session
• lang – Functional; language preference; 1 year
• cookie_consent – Functional; user consent choice; 1 year
• thirdparty_ads – Marketing; third-party ad interactions; 30 days
• analytics_optout – Statistics; opt-out for analytics; 1 year

8. Contact Us

For questions about this Policy or your personal data, contact us at info@lingutor.com