This Privacy & Cookie Policy explains how Langu collects, uses, stores and shares personal data when you use our website, platform, virtual classroom, messaging tools, booking tools, payment features, support channels and related services. Langu is operated by E-Polyglot Ltd, trading as Langu, a company registered in England and Wales under company number 08883623, with registered office at 124 City Road, London, England.

In this policy, “Langu”, “we”, “us” and “our” mean E-Polyglot Ltd. “You” means any person using Langu, including students, parents or guardians, teachers, company-sponsored students, company clients, website visitors and other users.

For data protection purposes, Langu is usually the controller of the personal data we collect and use through the platform. This means we decide why and how your personal data is processed. You can contact us about privacy matters at [email protected].

This policy applies to personal data we process about:

• students;
• parents and guardians;
• teachers and teacher applicants;
• company-sponsored students;
• company clients and sponsoring organisations;
• visitors to heylangu.com;
• people who contact us for support, sales or other enquiries.

Langu is not intended for children to register directly. If a student is under 18, their account must be registered and managed by a parent or legal guardian. We do not require students to provide their date of birth, so we may not always know whether a student is under 18. Where a parent or guardian uses Langu on behalf of a child, we may process personal data relating to both the parent or guardian and the child for the purposes described in this policy.

The personal data we collect depends on how you use Langu.

Students, parents and guardians

We may collect and use:

• name;
• email address;
• time zone;
• account login details;
• optional profile photo, if provided;
• optional language level or learning information, if provided;
• booking history;
• lesson history;
• trial lesson history;
• paid lesson history;
• teachers booked;
• payment history;
• total spend and account activity;
• registration date;
• last login date;
• reviews and ratings;
• messages sent through Langu;
• information shared in the virtual classroom, including whiteboard content, uploaded files, shared materials and lesson-related notes;
• support requests and communications with Langu;
• technical, usage and device data.

For normal B2C users, we do not require phone numbers, postal addresses or dates of birth.

Teachers and teacher applicants

We may collect and use:

• name;
• email address;
• country, location and time zone;
• profile photo;
• profile video or video introduction, if provided;
• biography and teaching description;
• qualifications, experience and application answers;
• CV, LinkedIn profile or similar application materials, where provided;
• phone number, only if included by you in application materials such as a CV or LinkedIn profile;
• languages, subjects, lesson types and services offered;
• prices, availability and package settings;
• profile content and uploaded materials;
• ratings and reviews;
• booking, lesson and payout history;
• commission rate and payment records;
• tax/VAT status or related information;
• payout details, where needed to arrange payment through our payout providers;
• messages sent through Langu;
• information shared in the virtual classroom;
• support requests and communications with Langu;
• profile performance, activity, availability, response, ranking and usage data.

We do not currently require formal ID verification, DBS checks or background checks from teachers, although we may introduce identity verification or similar checks in the future.

Company clients and company-sponsored students

Where lessons are arranged or paid for by an employer, school, organisation or other sponsoring company, we may collect and use:

• company contact names;
• work email addresses;
• company name;
• billing and contract information;
• names and email addresses of sponsored students;
• account creation details;
• lesson usage and attendance data;
• lesson dates and times;
• booking and cancellation data;
• teacher names;
• level or progress information, where relevant;
• progress notes or reports where requested;
• billing, spend and administrative data.

Company clients may provide us with the names and email addresses of employees or other sponsored students so that we can create accounts for them. Company-sponsored students normally book their own lessons. Employers or sponsoring organisations do not receive direct access to student accounts.

We do not normally share student-teacher message contents with sponsoring companies, unless this is necessary for a serious investigation, legal obligation, safeguarding concern, misuse issue, dispute or similar exceptional reason.

Website visitors and platform users

We may collect technical and usage data, including:

• IP address;
• browser type and version;
• device type;
• operating system;
• approximate location derived from IP address;
• pages visited;
• referral source;
• date and time of visits;
• page response times;
• clicks, scrolling, session behaviour and interactions;
• cookie identifiers;
• analytics and advertising identifiers;
• interactions with emails and in-app messages;
• error logs and diagnostic data.

This data may be collected through cookies, pixels, tags, scripts, analytics tools, advertising tools, support tools and similar technologies.

We do not intentionally ask users to provide special category data, such as health information, religious beliefs, political opinions, trade union membership, biometric data, sexual orientation or detailed racial or ethnic origin information.

However, users may choose to share sensitive information in messages, whiteboards, support conversations, teacher profiles, CVs, uploaded materials or lesson content. If you choose to share this information, we will only process it where reasonably necessary to provide the platform, deliver support, investigate concerns, comply with legal obligations, protect users or enforce our terms. We do not sell sensitive personal information, and we do not use it for unrelated commercial purposes. We will not share sensitive information with third parties except where necessary to provide our services, comply with the law, protect users or as otherwise described in this policy.

Please avoid sharing sensitive information unless it is necessary.

We use personal data for the following purposes:

Purpose	Examples of data used	Lawful basis
Creating and managing accounts	Name, email, login details, time zone, account activity	Contract; legitimate interests
Providing the Langu platform	Account data, booking data, messages, classroom data, technical data	Contract; legitimate interests
Matching students and teachers	Teacher profiles, availability, prices, ratings, student booking preferences, activity data	Contract; legitimate interests
Processing bookings and lessons	Booking history, lesson times, teacher/student details, classroom data	Contract; legitimate interests
Processing payments and payouts	Payment history, transaction data, payout information, commission records	Contract; legal obligation; legitimate interests
Managing refunds, chargebacks and disputes	Booking data, payment records, messages, ratings, support history, technical logs	Contract; legitimate interests; legal obligation
Supporting students, teachers and company clients	Support messages, account data, booking data, technical data	Contract; legitimate interests
Monitoring platform safety and quality	Messages, usage data, complaints, reviews, behaviour data, technical logs	Legitimate interests; legal obligation where applicable
Preventing fraud, spam, abuse and off-platform circumvention	Messages, IP addresses, account activity, payment data, technical logs	Legitimate interests; legal obligation where applicable
Safeguarding users	Messages, complaints, reports, account activity, lesson-related data	Legitimate interests; legal obligation where applicable
Managing teacher applications and profiles	Application data, CV/LinkedIn details, profile content, availability, performance data	Contract steps; legitimate interests
Ranking and displaying teachers	Availability, ratings, reviews, response behaviour, performance data, profile quality, usage data	Legitimate interests
Company-sponsored lesson administration	Sponsored student names/emails, attendance, usage, progress, billing data	Contract; legitimate interests; legal obligation where applicable
Marketing Langu services	Name, email, usage data, preferences, marketing interactions	Legitimate interests; consent where required
Analytics and product improvement	Usage data, device data, analytics data, behaviour data, error data	Legitimate interests; consent where required for cookies
Legal, tax and compliance	Transaction records, account records, communications, billing data	Legal obligation; legitimate interests

Where we rely on legitimate interests, we consider whether our interests are overridden by your rights and freedoms.

Where we rely on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect processing that took place before consent was withdrawn.

Messages sent through Langu between students and teachers are not considered private communications.

We may access, review and monitor messages and related platform activity for purposes including:

• providing and improving the platform;
• supporting students and teachers;
• investigating complaints or disputes;
• preventing spam, scams, fraud or abuse;
• enforcing our student and teacher terms;
• safeguarding users;
• detecting inappropriate, unlawful or harmful behaviour;
• detecting off-platform contact or payment circumvention;
• maintaining platform quality and integrity.

We may also process content shared in the virtual classroom, including whiteboards, uploaded files, shared materials, chat content and lesson-related notes.

Langu does not currently provide routine lesson recording and does not routinely record live lessons.

We may use automated systems, including AI-based or machine-assisted tools, to help detect spam, scams, inappropriate content, abusive behaviour, safeguarding concerns, off-platform contact, payment circumvention, quality issues or other misuse of the platform. We may also use translation software or APIs to translate teacher-generated content, reviews, profile information or similar content.

Automated tools may flag, block, delay or escalate messages or content for review. We may make final decisions manually or with the support of automated systems.

We may use algorithms and automated tools to help sort, rank, recommend or display teachers on Langu.

Factors may include availability, profile completeness, lesson history, ratings, reviews, response behaviour, student engagement, conversion, reliability, subject/language relevance, platform activity, performance data and other quality or operational signals.

Teacher applications are currently reviewed manually.

We do not intend to make solely automated decisions that produce legal or similarly significant effects without appropriate safeguards. If you believe an automated decision has significantly affected you, you may contact us at [email protected] and request review.

We may share personal data where necessary to operate Langu, provide our services, comply with law, protect users, enforce our terms or support our legitimate business operations.

Other Langu users

We may share relevant student data with teachers to allow them to provide lessons. This may include name, time zone, booking details, lesson history, trial and paid lesson counts, messages, classroom content and information shared by the student.

We may display teacher profile information publicly or to logged-in users. This may include name, profile photo, video introduction, biography, qualifications, experience, prices, availability, languages/subjects taught, reviews, ratings and teaching record.

Company clients and sponsoring organisations

Where lessons are sponsored by an employer, school, organisation or other company client, we may share relevant attendance, usage, booking, progress, administrative, account and billing information with the sponsoring organisation.

This may include lesson dates, lesson counts, attendance, cancellations, teacher name, progress notes or reports, language level information, usage data and spend/billing information.

We do not normally share message contents with sponsoring organisations, except where necessary for serious investigations, safeguarding, legal compliance, misuse, disputes or similar exceptional circumstances.

Service providers and subprocessors

We use third-party providers to help operate Langu. These may include providers for:

• payments and card processing, such as Stripe;
• teacher payouts, such as Revolut and Wise;
• email, transactional email and marketing communications, such as Mailchimp and Mandrill;
• customer support and live chat, such as Tidio;
• video/classroom infrastructure, such as Twilio Video and Whereby;
• analytics and tag management, such as Google Analytics and Google Tag Manager;
• advertising and retargeting, such as Google Ads and Meta Ads;
• product analytics and behaviour analytics, such as Microsoft Clarity;
• error monitoring and diagnostics, such as Sentry;
• security, DNS, caching and traffic management, such as Cloudflare;
• hosting and infrastructure providers, including providers with servers in Germany or elsewhere in Europe;
• accounting, finance, compliance, legal, business operations and administration tools.

We share only the personal data reasonably necessary for these providers to perform their services.

Legal, regulatory and safety disclosures

We may disclose personal data where we reasonably believe it is necessary to:

• comply with law, regulation, court orders or legal processes;
• respond to lawful requests from authorities;
• enforce our terms;
• investigate fraud, abuse, security issues, off-platform circumvention or payment disputes;
• protect the rights, property or safety of Langu, users or others;
• prevent harm or safeguarding risks;
• support legal claims or professional advice.

Business transfers

If Langu is involved in a merger, acquisition, restructuring, sale of assets, investment, financing, insolvency or similar transaction, personal data may be shared with relevant parties and advisers as part of that process, subject to appropriate safeguards.

We are based in the UK and may use service providers located in the UK, EEA, United States and other countries.

Where personal data is transferred outside the UK or EEA, we will use appropriate safeguards where required, such as adequacy decisions, UK or EU standard contractual clauses, data processing agreements or other lawful transfer mechanisms.

You may contact us if you would like more information about the safeguards used for international transfers.

We may send marketing communications about Langu services, offers, updates, surveys, promotions and relevant content.

We may rely on the “soft opt-in” where permitted, for example where you have registered with us or used our services and we are marketing similar Langu services to you.

Marketing emails will include an unsubscribe link, except for transactional or service emails that are necessary for your account, bookings, payments, safety, legal notices or platform operation.

Transactional emails may include booking confirmations, payment receipts, password resets, lesson reminders, account notices, support messages, dispute messages, policy updates and similar service communications. You cannot opt out of necessary transactional emails while continuing to use Langu.

We may use email and digital advertising channels, including retargeting, to promote Langu. We currently use email for direct communications and do not currently send SMS or WhatsApp marketing.

Cookies are small files placed on your device when you visit a website. Similar technologies include pixels, tags, scripts, local storage and tracking identifiers.

We use cookies and similar technologies for purposes including:

• keeping users logged in;
• remembering preferences;
• operating secure areas of the platform;
• understanding how users use Langu;
• improving website performance and product design;
• detecting errors and technical issues;
• measuring marketing performance;
• delivering and measuring advertising;
• retargeting users with relevant ads.

Types of cookies we use

Strictly necessary cookies: Required for login, security, account access, booking flows and platform operation
Functional cookies: Remember preferences and improve user experience
Analytics cookies: Help us understand site usage, behaviour, performance and errors
Marketing and advertising cookies: Help us measure campaigns, show relevant ads and retarget users

Examples of cookie and tracking providers

We may use cookies, tags, pixels or similar technologies from providers such as:

• Google Analytics;
• Google Tag Manager;
• Google Ads;
• Meta Ads;
• Microsoft Clarity;
• Tidio;
• Cloudflare;
• other analytics, advertising, support, performance or security tools.

We do not currently use Google AdSense.

Cookie consent and control

We use a cookie banner, but we are continuing to improve our cookie controls.

You can also control or delete cookies through your browser settings. Blocking some cookies may affect how Langu works, especially login, booking and account features.

Where legally required, we will seek consent before using non-essential cookies and similar technologies.

We keep personal data for as long as reasonably necessary for the purposes described in this policy.

For general inactive account data, our default retention period is 3 years after your last activity on Langu, unless we need to keep the data for longer.

We may retain certain records for longer where necessary for legal, tax, accounting, audit, payment, fraud prevention, safeguarding, dispute resolution, platform integrity, business record, contractual or legitimate interest purposes.

Examples include:

• payment and transaction records;
• payout records;
• commission and tax-related records;
• booking and lesson records;
• messages and classroom records relevant to disputes, safeguarding, fraud prevention or platform integrity;
• teacher application records;
• support records;
• complaint and investigation records;
• reviews, ratings and public or semi-public content;
• anonymised, aggregated or de-identified records.

Where practical, we may anonymise or de-identify records so they are no longer linked to you.

Public or shared content, such as reviews, teacher profile content, messages sent to another user or materials shared with another user, may remain visible or retained after account deletion, but we may remove or reduce identifying information where appropriate.

We use technical and organisational measures designed to protect personal data.

These may include:

• SSL/TLS encryption for data transmitted through the platform;
• access controls and role-based permissions;
• limiting staff access to personal data where appropriate;
• secure server access controls;
• use of SSH keys, VPN or IP restrictions where appropriate;
• backups and recovery processes;
• logging and monitoring;
• security reviews and technical safeguards;
• contractual protections with service providers.

No online service is completely secure. You are responsible for keeping your login details secure and for using a secure device and connection when accessing Langu.

If you believe your account or personal data has been compromised, please contact us promptly at [email protected].

Depending on where you live and the circumstances, you may have rights under data protection law, including the right to:

• access the personal data we hold about you;
• correct inaccurate or incomplete personal data;
• request deletion of your personal data;
• restrict our use of your personal data;
• object to certain processing, including direct marketing;
• request portability of personal data you provided to us;
• withdraw consent where processing is based on consent;
• complain to a data protection authority.

To exercise your rights, contact us at [email protected].

We may need to verify your identity before responding. Some rights are subject to legal limits, and we may not always be able to comply with a request, for example where we need to retain data for legal, accounting, fraud prevention, safeguarding, dispute or legitimate business reasons.

You may request deletion of your account by contacting us or using any account deletion tools made available within Langu.

Deleting your account does not automatically require us to delete all records immediately. We may retain information where necessary for legal, tax, accounting, payment, fraud prevention, safeguarding, dispute, platform integrity, business record or legitimate interest purposes.

Where appropriate, we may delete, anonymise or de-identify personal data rather than remove all related records.

Langu may contain links to third-party websites, tools or services.

We are not responsible for the privacy practices, cookie practices, content or security of third-party websites or services. You should review their privacy and cookie policies before using them.

We may update this Privacy & Cookie Policy from time to time.

The updated version will apply from the date it is published or otherwise notified to you.

If we make significant changes, we may notify you by email, dashboard notice or another reasonable method.

Your continued use of Langu after an updated policy takes effect means you acknowledge the updated policy.

For privacy questions, requests or concerns, contact:

E-Polyglot Ltd trading as Langu
124 City Road
London EC1V 2NX
UK

Email: [email protected]