Privacy Policy

Last updated: February 11, 2024

1. Introduction

This Privacy Policy (“Policy”) outlines how Gusev-Bildungstechnologie (Oleg Gusev, Kiefholzstraße 25, 12435 Berlin, Germany) (“we,” “us,” “our”) handles data related to our services and users. As we value your privacy, our app is designed to collect minimal data and adhere to the General Data Protection Regulation (GDPR) standards.

We collect and process your Personal Data differently, depending on whether you are a:

- User of our Speak Dummy app;

- Visitor to our gusev-edtech.com website.

For more details regarding the data processed in relation to each category, please see below.

2. Speak Dummy app users

App Functionality and Data Collection:

The Speak Dummy app (“App”) does not collect any personal information such as emails or phone numbers. Users do not create accounts, and progress is tracked solely within the App. We collect anonymous statistics on which language courses are downloaded most frequently, but these are not linked to any personal data.

Third-Party Services:

Our App uses RevenueCat, Inc. (1032 E Brandon Blvd #3003, Brandon, FL 33511, USA) (“RevenueCat”) for payment back-end services. RevenueCat helps us manage the access you have to our app's features, working closely with the Google Play Store and Apple's App Store. In the case of handling data of our end users, RevenueCat is considered a processor, while we are a controller.

No other third-party services are used to process customer data in our App, ensuring both minimal data collection and enhanced privacy.

International Data Transfers and Safeguards:

In providing our Speak Dummy app services, we utilize RevenueCat, a service designed to streamline in-app purchases and subscriptions. RevenueCat, being based in the USA, operates in conjunction with Google Play Store and Apple's App Store to manage entitlements and offer the appropriate subscription options to our users. While this process involves international data transfers, particularly to the United States, we ensure that these transfers are carried out in compliance with the General Data Protection Regulation (GDPR). We rely on established mechanisms such as standard contractual clauses approved by the European Commission, ensuring that your data is protected with adequate safeguards in line with European Union’s data protection standards.

Data Usage and Collection:

Our goal is to collect only the essential data needed to make our services better for you, and we focus on gathering general statistics that do not identify you personally. Specifically, we keep track of wuniohich language courses are popular and where in the world they are being used. This helps us understand what kinds of courses our users are interested in, based on general location trends.

This information is crucial for us to decide which new language courses to develop and how to improve the ones we already offer. We want to make sure our courses meet the diverse needs and interests of our users. It is important to highlight that this data is purely for improving our course offerings and does not change how the app works for you personally, nor is it used to track your individual app usage.

Data Retention Policy:

In our commitment to continuously improve the Speak Dummy app and our website, we collect and retain non-personal statistical data over time as described above. This data is crucial for understanding how our services are used and for making informed decisions on future updates and offerings. It is important to clarify that this data is aggregated and anonymized, ensuring it cannot be linked back to any individual user, thus maintaining your privacy.

For the functionality of in-app purchases and subscriptions, we utilize RevenueCat, which processes certain necessary data to facilitate transactions. This may include technical information about your device and transaction details related to your app usage. RevenueCat is committed to data protection and ensures that any such data is retained only as long as necessary for the completion of those transactions and in compliance with applicable laws.

We are dedicated to not retaining data longer than needed for our operational and improvement purposes. Our data retention practices are designed to respect your privacy while enabling us to deliver and enhance the high-quality language learning experience you expect from us.

Legal Basis for Data Processing:

Our processing of data within the Speak Dummy app is grounded in our legitimate interest to enhance and optimize our service offerings. We ensure that the data collection is strictly limited to non-personal statistics related to course downloads and usage trends to improve our app's content and functionality. This approach aligns with our commitment to prioritize user privacy while delivering a high-quality user experience.

Data Protection Role and Contact:

As a registered sole entrepreneur operating under Gusev-Bildungstechnologie trade name, I, Oleg Gusev, personally oversee all aspects of our data protection practices. While the scale of our operations does not necessitate the formal appointment of a Data Protection Officer (DPO) as defined under GDPR, I am committed to ensuring the highest standards of privacy and data protection. Should you have any questions or concerns regarding your data and privacy, please feel free to reach out directly to me at privacy@speakdummy.com. I am dedicated to addressing any inquiries and ensuring the protection of your rights under data protection laws.

User Rights Under GDPR:

As a Germany-based app, we comply with GDPR. Users have the right to access, rectify, erase, and port their data. To exercise these rights or for any GDPR-related inquiries, please contact us at privacy@speakdummy.com.

Data Security:

Our approach to data security is simple: we protect user data by not collecting it. We are committed to safeguarding any minimal data we collect and ensuring it remains secure.

Contact Information:

For any privacy-related questions or requests, please contact us at:

Oleg Gusev

Gusev-Bildungstechnologie

Kiefholzstraße 25

12435 Berlin, Germany

Email: privacy@speakdummy.com

Age Limitations and Consent:

We are committed to complying with the Children's Online Privacy Protection Act (COPPA) and GDPR regarding children's privacy.

Our Speak Dummy app is designed to be accessible and safe for users of all ages, including children. While the content does not specifically cater to children and they might find many topics there less engaging, we ensure the app's content is appropriate for any age group. We do not knowingly collect personal data from any of our users, including children, and therefore do not require specific consent for children's use of the app. We advise parents and guardians to supervise their children's use of digital services, including our app, and to discuss internet safety and the importance of privacy.

Updates to the Privacy Policy:

We reserve the right to update or change our Privacy Policy at any time to reflect changes in our practices or service offerings. As we do not collect personal contact information from our users, we will not send direct notifications about policy updates. Instead, we encourage our users to review our Privacy Policy periodically for any changes. The latest version of our Privacy Policy will always be accessible on the speakdummy.com website, with the date of the last update clearly indicated. Staying informed about our privacy practices is an important part of safeguarding your personal information and privacy rights.

Consent and Acknowledgment:

By using the Speak Dummy app, you acknowledge that you have read and understood this Privacy Policy.

3. Website visitors

The gusev-edtech.com website (“Site”) is owned by Gusev-Bildungstechnologie, which is a data controller of your personal data.

We have adopted this Privacy Policy, which determines how we are processing the information collected by the Site, which also provides the reasons why we must collect certain personal data about you. Therefore, you must read this Privacy Policy before using the Site.

We take care of your personal data and undertake to guarantee its confidentiality and security.

Personal information we collect:

When you visit the the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the installed cookies on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products you view, what websites or search terms referred you to the Site, and how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

Legal Basis for Data Processing:

The minimal data collection on our gusev-edtech.com website is based on our legitimate interest in maintaining and improving the website's functionality and security. This includes processing basic information such as IP addresses and browser details necessary for the website's operation and protection against abuse. We are committed to ensuring that any data processing is conducted with the utmost respect for user privacy and in compliance with applicable data protection laws.

Why do we process your data?

Our top priority is customer data security, and, as such, we may process only minimal user data, only as much as it is absolutely necessary to maintain the website. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding website usage. This statistical information is not otherwise aggregated in such a way that it would identify any particular user of the system.

You can visit the website without telling us who you are or revealing any information, by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the website’s features, or you wish to receive our newsletter or provide other details by filling a form, you may provide personal data to us, such as your email, first name, last name, city of residence, organization, telephone number. You can choose not to provide us with your personal data, but then you may not be able to take advantage of some of the website’s features. For example, you will not be able to receive our Newsletter or contact us directly from the website. Users who are uncertain about what information is mandatory are welcome to contact us via privacy@gusev-edtech.com.

Your rights:

If you are a European resident, you have the following rights related to your personal data:

- The right to be informed.

- The right of access.

- The right to rectification.

- The right to erasure.

- The right to restrict processing.

- The right to data portability.

- The right to object.

- Rights in relation to automated decision-making and profiling.

If you would like to exercise these rights, please contact us through the contact information below.

Additionally, if you are a European resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example, if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information might be transferred outside of Europe, including Canada and the United States.

Links to other websites:

Our website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for such other websites or third parties' privacy practices. We encourage you to be aware when you leave our website and read the privacy statements of each website that may collect personal information.

Information security:

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We keep reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and personal data disclosure in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Legal disclosure:

We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Data Protection Role and Contact:

As a registered sole entrepreneur operating Gusev-Bildungstechnologie, I, Oleg Gusev, personally oversee all aspects of our data protection practices. While the scale of our operations does not necessitate the formal appointment of a Data Protection Officer (DPO) as defined under GDPR, I am committed to ensuring the highest standards of privacy and data protection. Should you have any questions or concerns regarding your data and privacy, please feel free to reach out directly to me at privacy@gusev-edtech.com. I am dedicated to addressing any inquiries and ensuring the protection of your rights under data protection laws.

Updates to the Privacy Policy:

We reserve the right to update or change our Privacy Policy at any time to reflect changes in our practices or service offerings. As we do not collect personal contact information from our users, we will not send direct notifications about policy updates. Instead, we encourage our users to review our Privacy Policy periodically for any changes. The latest version of our Privacy Policy will always be accessible on the gusev-edtech.com website, with the date of the last update clearly indicated. Staying informed about our privacy practices is an important part of safeguarding your personal information and privacy rights.

Consent and Acknowledgment:

By using the gusev-edtech.com website, you acknowledge that you have read and understood this Privacy Policy.

Consent Withdrawal:

The primary consent we request from our users pertains to the use of cookies on our website, gusev-edtech.com. These cookies are essential for providing an optimal user experience and for basic website functionality. If you wish to withdraw your consent for cookies, you can do so at any time by adjusting your browser settings to refuse cookies. Please be aware that disabling cookies may affect the functionality and features available on our website. For more detailed information on managing cookies, please refer to the help documentation of your web browser.

Contact information:

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may send an email to privacy@gusev-edtech.com.