Customer Privacy Notice

Last Updated: October 20, 2025

Who are we?

With this Privacy Notice, we aim to inform you as Lingo Fun Inc. ("LingoFun", "Company", "We") whose address is 16192 Coastal Highway, Lewes, Delaware 19958, United States of America, as the data controller, about the processing of your personal data within the scope of the EU General Data Protection Regulation ("EU GDPR").

LingoFun offers services that include learning foreign languages through play via its dedicated product designed for children aged 4 to 12 ("Services") via the LingoFun Kids mobile application, available for download on the Apple App Store and Google Play, and the website https://lingofun.co/tr (collectively referred to as the "Platform(s)"). These Services also include real-time tracking and management of children's language learning progress by parents and teachers through monitoring and reporting systems provided on the Platforms, staying informed about updates by participating in surveys or subscribing to newsletters, and engaging in real-time communication via AI-powered chatbots/digital assistants available on the Platforms.

Contact details

If you have any issues, queries or complaints regarding the processing of your personal data, you can contact by email to:

Data Protection Officer

Email: dpo@lingofun.co

What information we collect

We collect or use the following personal data:

  • Identity Information: name-surname, date of birth
  • Contact Information: email address, country and city
  • Transaction Security: IP address, log records, password
  • Location: location data
  • Customer Transaction Information: In the event of your participation in the survey, the evaluation information you provide within the scope of the survey, your LingoFun ID, LingoFun account username, request and complaint details, rating and evaluation data, information regarding language development status, time spent on LingoFun, and the difficulty level experienced in different sections, information regarding the subscription type
  • Marketing: usage habits
  • Finance: information on whether the payment has been made, order amount, date of order, information on the purchased product, information on the benefitted discount (if any)
  • Auditory: Spoken responses given to questions within the game that require a verbal answer

Purposes and legal bases of the processing

Data CategoriesProcessing PurposesLegal Bases
LocationProviding personalized services based on your locationExplicit consent of the data subjects as per Art. 6(1)(a) of the GDPR
Identity Information
Contact Information
Marketing
Implementation of personalized advertising, campaign promotions, and marketing activitiesExplicit consent of the data subjects as per Art. 6(1)(a) of the GDPR
Contact Information
Identity Information
Customer Transaction Information
Creating accounts on platforms and managing account processes, receiving and evaluating suggestions for improving business processes, managing customer relationship processes including communication activities, tracking and resolving requests and complaintsProcessing is necessary for the performance of a contract to which the data subject is party as per Art. 6(1)(b) of the GDPR

Processing is necessary for the purposes of the legitimate interest pursued by the controller as per Art. 6(1)(f) of the GDPR
Transaction Security
Customer Transaction Information
Execution of technical notifications, updates, and security advisories, including confirmations, and provision of technical support within this scope

Conducting activities in compliance with the legislation and exercising rights arising from the applicable legislation in the event of a potential legal dispute
Processing is necessary for the compliance with a legal obligation to which the controller is subject as per Art. 6(1)(c) of the GDPR
Contact Information
Finance
Tracking of payment processesProcessing is necessary for the purposes of the legitimate interest pursued by the controller as per Art. 6(1)(f) of the GDPR

Processing is necessary for the performance of a contract to which the data subject is party as per Art. 6(1)(b) of the GDPR
AuditoryUsing Services in sections of the game that include speakingProcessing is necessary for the performance of a contract to which the data subject is party as per Art. 6(1)(b) of the GDPR
Contact Information
Customer Transaction Information
Preparing and presenting customized game/training/section organizations for users, implementing tracking and reporting systems related to the language development process

Conducting activities aimed at developing and improving platforms and services in line with user experiences
Processing is necessary for the performance of a contract to which the data subject is party as per Art. 6(1)(b) of the GDPR

Processing is necessary for the purposes of the legitimate interest pursued by the controller as per Art. 6(1)(f) of the GDPR

Who we share your personal data with

Your personal data mentioned above are shared with third party outsourced suppliers from whom we receive infrastructure services for purposes of receiving services related to information technology infrastructure and server hosting services.

Additionally, we would like to note that we may share your personal data with authorized public institutions and organizations, strictly limited to the purposes of fulfilling our legal obligations and providing information to authorized individuals, institutions, and organizations in accordance with lawful requests and demands.

How we collect your personal data

We collect your personal data directly from you when you register and create your account, communicate with us in relation to support requests and use our products and services. In such case, LingoFun collects name-surname, date of birth, email address, country and city, IP address, log records, password, location, survey evaluations, LingoFun ID, account username, request and complaints, language developments status, time spent on levels, usage habits and auditory data.

LingoFun may also collect your personal data indirectly from the business partners (such as AppStore), when you make in-game purchases that are processed by that business partner application and subject to that business partner's application's terms of service and privacy policy.

How long we keep your personal data

We will not keep your personal data for any longer than is necessary for the purposes for which we collect it and legal requirements to which we are subject.

Automated decision making

We use automated decision making to direct users to the right ads and promotions based on their past behaviour, interactions or demographics if we obtain customers' consent for such processes. Via automated decision making, users only receive ads and promotional offers that match their interests and past interactions.

Types of personal data we use for automated decision making consist of country, order amount, date of order, information on the purchased product, IP address, log records, information on the benefitted discount (if any), usage habits and behaviour analysis.

Profiling

We use profiling to provide you with a personalized learning experience, and to improve our service quality. Via profiling, users are also targeted for promotional campaigns.

Types of personal data we use for profiling consist of date of birth, language development/level, email address, country and city, IP address, log records, and usage habits.

Your rights

You have the following rights under the GDPR. Which lawful basis we rely on may affect your data protection rights which are in brief set out below.

  • Right of access - You have the right to ask us for copies of your personal data. You can request other information such as details about where we get personal data from and who we share personal data with.
  • Right to rectify - You have the right to ask us to correct or delete personal data you think is inaccurate or incomplete.
  • Right to erasure - You have the right to ask us to delete your personal data.
  • Right to object - You have the right to object to the processing of your personal data.
  • Right to restrict processing - You have the right to ask us to limit how we can use your personal data.
  • Right to data portability - You have the right to ask that we transfer the personal data you gave us to another organization, or to you.
  • Right to withdraw your consent - When we use consent as our lawful basis you have the right to withdraw your consent at any time.
  • Right to not to be subject to a decision based solely on automated processing - You have right to not to be subject to a decision based on automated processing which produces legal effects/significantly affects you.
  • Right to launch a complaint - You have right to launch a complaint with your local data protection authority.

By using LingoFun, you acknowledge that you have read and understood this Privacy Notice and agree to the processing of your personal data as described herein.