Privacy Policy

Last Revised: August 2021

1              Who we are

1.1          Voxy, Inc. (Voxywe, or us) welcomes you to www.Voxy.com and any and all platforms, applications or mobile applications offered by Voxy, Inc (the Site). This Privacy Policy describes how Voxy collects and receives information about you through the Site and when contracting with corporate customers or providing our English language training and teaching services to end users (the Services) and through Voxy’s businesses, including offline and how we use and share your personal data.

1.2          Voxy is committed to protecting your privacy. We want to maintain a transparent relationship with you, and let you know how we collect and securely process any personal data we collect or that you may provide us with. We will process your personal data in accordance with applicable personal data protection laws.

1.3          In this Privacy Policy we refer to employees of corporate customers who we liaise with in relation to the corporate contract as B2B Contacts and individuals who utilise the Services or access the Site as Users. Unless otherwise stated, all sections of this Privacy Policy are applicable to B2B Contacts and Users.

1.4          This Privacy Policy exists in English and other translations. In the event of inconsistencies between versions, the English version will prevail.

1.5          This Privacy Policy covers our use of your personal data when:

1.5.1      you enquire about and/or you (or your employer) enters into a corporate contract with us for the Services if you are a B2B Contact;

1.5.2      you register for an account with us and use our Site and Services if you are a User;

1.5.3      when you get in touch with us including via our Site contact form, by email, social media or by phone (if you are a B2B Contact or User);

1.5.4      you provide your personal data to Voxy offline. Voxy also may provide paper copies of the Privacy Policy when it collects information from you offline; and

1.5.5      we collect personal data through cookies and similar technologies when you browse the Site.

1.6          Please also see:

1.6.1      Your Terms of Use (if you are a User) for information relating to the contractual relationship between you and us in respect of your use of the Services and/or Site;

1.6.2      Your corporate agreement (if you are a B2B Contact) for information relating to the contractual relationship between our corporate customer and Voxy in respect of the Services; and

1.6.3      Our Cookie Policy for information relating to our use of cookies and similar technologies on this Site.

2              What We Collect and How We Use Personal Data

2.1          We will collect and use your personal data when you enquire about and/or enter into a corporate contract with us, register for an account with us and use our Site and Services, and when you get in touch with us including via our Site contact form, by email, social media or by phone and from cookies as described in the Cookie Policy.

2.2          If you are a User, Voxy may also be provided with your personal data by our corporate customers when they sign up to our Services (or personal data may be provided by our channel partners) in order to enable you to register an account and use our Services. Our corporate customers and channel partners will only share your personal data with us if they have previously informed you about this data sharing (e.g. your employer will inform you they will share certain personal data with us (such as name, email address, role) to enable you to register and sign up to use the Services).

2.3          The table below sets out how we collect your personal data, the types of personal data and how this personal data is used.

 What personal data we collectHow we use your personal data

1.

If you are a B2B Contact, we will process personal data you provide when enquiring about or registering an interest in becoming a corporate customer including:

●        Name;

●        Contact details (including email address and phone number);

●        Job role; and

●        Name of your employer.

Voxy will use this personal data to:

●        Respond to queries and other requests;

●        Negotiate the contract;

●        Manage and administer the contract including for payment, invoicing and refund purposes;

●        Manage any customer service issues that arise during the course of the contract;

●        Communicate with you regarding the management and administration of our contact with our corporate customer;

●        Help us ensure that our corporate customers are genuine and to prevent fraud; and

●        Send you direct marketing.

2.

If you are a User, we will process personal data that you provide to us when registering for an account on our Site and during onboarding as a User. This includes:

●        Name;

●        Email address;

●        telephone number;

●        account password;

●        Age;

●        your country of residence;

●        English language education experience and current knowledge/level;

●        Personal goals (e.g. use of English for work, daily life, preparing for exams) in order to personalise lesson content;

●        Preferences and Interests (in order to suggest lesson content) (e.g. art, entertainment, food, lifestyle, sports).

 

Voxy will use this information to:

●        Provide you with, manage and administer, our Site and Services;

●        Verify that you are authorised to access our Services under a corporate customer agreement;

●        To analyze our Users’ demographics and interests;

●        Meet our contractual commitments to you;

●        Help us ensure that our Users are genuine and to prevent fraud;

●        Allow Users to engage with each other through the Site;

●        Send you direct marketing (but only where you consent to this);

●        Notify you about any changes to our Site, such as improvements or Service changes, that may affect our Services;

●        To alert you to new features, lessons, terms, Services, content, or activities

●        To monitor and analyze information regarding your browsing and viewing preferences; and

●        Make the Site and Service more relevant and personal to you including by making content and lessons on the Site more relevant to you and your interests and encourage activity, session attendance and use of the Services.

 

3.

If you are a User, personal data we collect when you use the Services including:

●        Course and training progress, test scores and results;

●        The dates and times you, book, attend and access training and sessions and which sessions you have booked and attended; and

●        Photos and videos of your attendance at the session including your name and username if visible when attending the session.

 

Voxy use this personal data to:

●        Provide our Services including access to sessions, testing, results and certifications;

●        Allow Users to engage with each other through the Site;

●        Provide reports about employee or student attendance (including name of employee or student) and usage of Services to our corporate customers by reference to corporate customer accounts and associated access codes;

●        Manage and develop our Site and Services;

●        Monitor compliance with and to enforce the Terms of Use; and

●        Use photos and videos for internal and external promotional purposes (e.g. on our website or on social media).We will request consent to such use photos and/ or videos where required by applicable law.

 

4.

Information when you communicate with us whether through our Site (including the contact us form or when you request a demo), by email, by phone, by social media or by any other means including:

●        Your contact details (name, email address, address, phone number and social media handle or user name); and

●        The details of your communications with us; The details of our messages to you.

 

Voxy use this personal data in order to:

●        Respond to requests for information about our Services;

●        Answer any questions, issues or concerns;

●        Monitor communications for quality and training purposes;

●        Develop new Services; and

●        Improve our Services.

 

5.

When you sign up to receive our marketing emails and updates whether online or offline, including:

·         Your contact details (name, email address, address).

Voxy use this personal data in order to:

·         To send marketing emails about our products and services and to provide you with personalized content in the marketing emails.

6.

Personal data that we collect through your use of our Site including:

●        usage statistics;

●        browsing history;

●        domain name of your internet service provider;

●        Device information such as operating system, browser and version, country/region/city of device, unique device identifiers, the mobile network system;

●        traffic data;

●        weblog statistics ;

●        Hardware and browser settings;

●        Page requests;

●        The requests you make;

●        The pages you visit and sessions you attend; and

●        IP address.

For further information on our use of cookies see our Cookie Policy.

Voxy use this personal data in order to:

●        analyse use of the website such as pages visited and number of visitors;

●        monitor and analyse attendance at sessions through our Site;

●        Operate our Site;

●        Improve our Site, content, products and Services;

●        Provide and adapt our Site to the technical capabilities of User devices;

●        Identify issues with the Site and the user’s experience of it; and

●        Monitor and analyse the way our Site is used.

 

If personal data is required to enter into a contract with you or otherwise provide Services to you we may be unable to enter the contract or provide Services if you fail to provide the requested personal data. We will inform you if this is the case.

Voxy may automatically receive and record non-personal information on our server logs from your browser as well as through other analysis of the Site.

3              Our legal basis for using your personal data

3.1          We rely on the following lawful bases under data protection law (where applicable) for our use of your personal data:

3.1.1      Consent: you have given your consent to the processing;

3.1.2      Performance of a contract: it is necessary for the performance of and compliance with your contract with us or in order to take steps prior to entering into that contract;

3.1.3      Legal or Regulatory Obligation: we need to process your personal data in order to comply with a legal or regulatory obligation; or

3.1.4      Legitimate Interests: it is necessary for our legitimate interests (or those of a third party). Please see section When do we have legitimate interests? below for more information.

3.2          Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4              When do we have legitimate interests?

4.1          We use your personal data where this is necessary for our legitimate interests (or those of a third party). This includes where use of your personal data is necessary to:

4.1.1      Ensure effective administration and management of our Site;

4.1.2      Administer our operations and business in an efficient and effective way;

4.1.3      Manage and administer our Services, Site, content, activities and corporate customer arrangements;

4.1.4      Provide and administer accounts on our Site for Users;

4.1.5      Understand how individuals use our Site and Services;

4.1.6      Understand and respond to queries, complaints and feedback;

4.1.7      Research and analyse the Services our Users and corporate customers want;

4.1.8      Send direct marketing to B2B Contacts and Users;

4.1.9      Improve and develop our Services;

4.1.10    Maintain a public profile;

4.1.11    Transfer personal data in relation to an actual or proposed sale, transfer or re-organisation of all or part of our business and the acquisition of the business;

4.1.12    Ensure network and information security; and

4.1.13    Enforce our legal rights and manage any dispute and legal claims and take legal or other professional advice.

5              Legal requirements

5.1          Your personal data may be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim.  We will not delete personal data if relevant to an investigation or a dispute.  It will continue to be stored until those issues are fully resolved.

6              Where your information will be held

6.1          Personal data collected by Voxy will be stored and processed in the United States in accordance with the laws of the United States. If you submit your personal data directly to Voxy online or offline (e.g. when signing up for an account if you are a User), you acknowledge that you are providing your personal data to Voxy in the United States.

6.2          Depending on a B2B Contact or User’s location, data transfers may involve transferring personal data outside of that B2B Contact or User’s location.

6.3          If you are located in the UK or European Economic Area, we may transfer your personal data to locations outside of the UK and European Economic area. However, to ensure your personal data is protected in accordance with EU and UK data protection law we will only transfer data outside the UK and European Economic Area where appropriate safeguards as required by applicable data protection law are in place. This includes where a jurisdiction has been deemed adequate by the EU Commission or, where there is no adequacy decision, by putting in place Standard Contractual Clauses. Please contact us at datacontroller@voxy.com if you would like further information on the specific safeguards used by us when transferring your personal data.

7              The Rights of Users

7.1          Users may exercise certain rights regarding their personal data under applicable data protection law. In particular, Users may have the following rights:

7.1.1      Withdraw consent at any time.  The right to withdraw consent where you have previously given their consent to the processing of personal data.

7.1.2      Object to processing of persona data.  The right to object to the processing of personal data if the processing is carried out on a legal basis other than consent.

7.1.3      Access Personal Data.  The right to learn if personal data is being processed, obtain disclosure regarding certain aspects of the processing and obtain a copy of the personal data undergoing processing.

7.1.4      Verify and seek rectification.  The right to verify the accuracy of personal data and ask for it to be updated or corrected.

7.1.5      Restrict the processing of personal data.  The right, under certain circumstances, to restrict the processing of personal data.

7.1.6      Have Personal Data deleted or otherwise removed.  The right, under certain circumstances, to obtain the erasure of their personal data.

7.1.7      Portability. The right to receive personal data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the personal data is processed by automated means and that the processing is based on consent, on a contract which the User is part of or on pre-contractual obligations thereof.

7.1.8      Lodge a complaint.  You may also have a right to lodge a complaint with a supervisory or regulatory authority. In particular if you are an EEA or UK resident you may lodge a complaint with the supervisory authority in the UK or Member State in the European Union where you are habitually resident, where you work or where an alleged infringement of data protection legislation has taken place.

7.2          Please contact us at datacontroller@voxy.com if you would like to exercise any of the above rights.

8              Retention of personal data

8.1          Personal data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

8.1.1      Personal data collected for purposes related to the performance of a contract shall be retained until such contract has been fully performed and for the relevant statutory limitation period following the end of that contract.

8.1.2      Personal data collected for the purposes of legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this Privacy Policy.

8.2          The criteria we use to determine the retention period is as follows:

8.2.1      the length of time that you are a User of the Site and Services;

8.2.2      the duration of your contract with us;

8.2.3      whether there are contractual or legal obligations that exist that require us to retain the data for a period of time;

8.2.4      whether there is an ongoing legal claim that relates to your relationship with us; and

8.2.5      whether any applicable law, statute, or regulation allows for a specific retention period.

8.3          We may use personal data to generate aggregated and anonymised information to assist in our planning, development and improvement of products and Services. This information will cease to be personal data once it is made anonymous and aggregated and may be retained for longer than the retention periods set out above.

9              Direct Marketing

9.1          If you are a B2B Contact, Voxy may send direct marketing to you (in relation to marketing aimed at your employer) by email. B2B Contacts can opt-out of receiving these communications at any time.

9.2          If you are a User, Voxy may send direct marketing, if you have given your consent:

9.2.1      to marketing relating to Voxy products and services; and/or

9.2.2      to marketing relating to identified third party products or services that may be of interest.

9.3          If you do not want us to use your personal data for the purposes of direct marketing you can withdraw your consent at any time by contacting support@voxy.com. Please note that such requests may take up to ten (10) days to become effective.

9.4          Please note that if you choose not to consent to direct marketing or withdraw your consent to direct marketing we will still communicate with you in relation to any contract you have with us and other Service related messages. For example, messages relating to Service downtime or confirmation of training bookings and communications relating to your contract with us, or messages regarding activation, reset password and login access. You may not opt out of receiving communications regarding your dealings with Voxy or the Site, content, Services or technical information about the Site.

10           Information Sharing with Third Parties

10.1        Your personal data will be processed by our employees and contractors.

10.2        There are also certain circumstances where we will transfer your personal data to third parties. These include:

10.2.1    Group companies – so we can provide the best service across our group. We also share your personal data within our group for management forecasting and financial planning purposes – although this would generally be aggregated data where no individual is identifiable.

10.2.2    Corporate customers – Voxy will share your personal data including name and details of training attended and certifications completed with the corporate customer that enabled your account. This is the corporate customer whose activation code you used when signing up for an account on our Site to use our Services and would generally be your employer or the university or other educational institution you attend. The information shared with corporate customers includes information about how many Users have signed up for our Services on the corporate account and usage/activity of those Users. Corporate customers (e.g. your employer or your university) will act as an independent data controller – please see the relevant corporate customer’s privacy policy for details on how they will use and process your personal data;

10.2.3    Channel Partners – Voxy will share your personal data with the relevant Channel Partner. Our Channel Partners act as an intermediary with some of our corporate customers. We will share personal data with the relevant Channel Partners to enable that Channel Partner to administer the arrangement with a specific corporate customer. This includes your personal data collected through use of the Site and Services.

10.2.4    Service providers – Third parties may process your personal data on our instructions. These include IT suppliers (including website hosting, software and app providers), cloud hosting providers, order fulfilment, payment processing, customer service, data analytics providers, debt agencies, professional advisors, marketing agencies, database providers, backup and disaster recovery specialists and email providers.

Our suppliers and service providers will be required to meet appropriate standards on processing information and security when processing your personal data.  The information we provide them, including your information, will only be processed in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this Privacy Policy.

Please see the table below for details of some of our key service providers.

Voxy SubProcessors
Third Party/Service VendorPurposeCountry
AWS AmazonHosting, Content Delivery Network servicesUSA
LogglyCentralized loggingUSA
MarketoEmail service providerUSA
BluejeansVideo conferencingUSA
Pendo.ioThird-party analytics providerUSA
GoogleThird-party analytics provider, email providerUSA
DatadogCentralized logging, monitoringUSA
OktaAuthenticationUSA
SpeechAceSpeech recognitionUSA
WistiaContent Delivery Network servicesUSA
ZendeskChat and service for customer supportUSA
JobHomeCustomer supportBrazil
SupportYourAppCustomer supportUkraine

10.3        Your personal data may be transferred to other third party organisations in certain scenarios, such as:

10.3.1    If we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;

10.3.2    If we are reorganised or sold, or in the event of a merger, joint venture, assignment, transfer or disposition of all or any portion of Voxy’s business or operations (including without limitation in connection with bankruptcy or any similar proceedings) information may be transferred to a buyer who can continue to provide services to you;

10.3.3    If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police e.g. in order to assist fraud protection and minimise credit risk;

10.3.4    In response to a subpoena, legal order or official request, when we believe you have acted in violation of our contract with you, to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats, or when we believe that doing so may protect your safety or the safety of Voxy or others, or as otherwise permitted or required by law; or

10.3.5    If we are exercising or defending a legal claim your information may be transferred as required in connection with defending such claim.

10.4        Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data. For example, we may take personally identifiable information and de-identify it and share it in a de-identified or aggregated form with advertisers, business partners, and/or third parties in order to analyse Site usage, perform services on our Site or others’ Site, improve our services, improve our user experience, or for similar purposes. We will not re-identify such data and we will ask our contracting parties to agree to keep the data in its de-identified form.

11           Children

11.1        The Site is not directed toward children under 15 years of age nor does Voxy knowingly collect information from children under age 15 on the Site or offline. If you are under 15, you are not permitted to use our Services, register for emails or direct marketing or to otherwise submit any personally identifiable information to Voxy. If you provide information to Voxy through the Site, you represent that you are 15 years of age or older.

11.2        If you are between 15 and 17 years of age, when you visit, browse, use, or submit personal information to the Site, you represent that you have the permission of a parent or guardian to do so and who agrees to these Terms on your behalf. If you are a parent or guardian and believe Voxy may have inadvertently collected personal information from your child, please notify Voxy immediately by sending a message detailing the basis of your belief and your request to: Voxy, Inc. 64 Bleecker St. #241, New York, NY 10012-2410 or support@voxy.com.

12           Protection of Personal Information

12.1        Voxy uses reasonable administrative, physical and electronic security measures to protect against the loss, misuse and alteration of personal information. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Voxy to intercept or access transmissions or private communications unlawfully. While we strive to protect personal information, neither Voxy nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk.

13           Updating your Information

13.1        You are responsible for keeping your information current. You may update your information by contacting us at support@voxy.com or editing your account information. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to Voxy’s internal reporting, processing and retention policies and all applicable legal obligations.

14           Links

14.1        You may have the opportunity to follow links on the Site to other sites that may be of interest to you. Voxy endeavors to only link to reputable organizations. Because other sites may not be hosted or controlled by Voxy, we are not responsible for the privacy practices of those sites or the content provided thereon. Therefore, the privacy policies with respect to other sites may differ from those applicable to the Site. We encourage you to review the privacy policies of each other site. This Privacy Policy only applies to information collected and maintained by Voxy.

15           Changes to the Privacy Policy

15.1        Should the Privacy Policy be revised, Voxy will post the changes on the Site which will be effective immediately upon posting. You can determine when the Privacy Policy was last revised by referring to the “Last Revised” legend at the top of this page.

15.2        If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why we use personal data, we will notify you by way of a prominent notice on our website or, if we have your email address, by email. Where required by applicable law, any material changes to the terms of the Privacy Policy will apply only to information collected thereafter, unless you provide consent.

16           Questions?

16.1        If you have any questions or concerns regarding this Privacy Policy, please contact us at:

16.1.1    Voxy, Inc. 64 Bleecker St. #241, New York, NY 10012-2410

16.1.2    datacontroller@voxy.com; or

16.1.3    support@voxy.com

17           Notice of Privacy Rights of California Residents

17.1        We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. Due to Voxy’s size/data collection, Voxy is not currently required to comply with the CCPA, but we do make an effort to do so.

17.2        If you are a California resident and have provided personal information to Voxy, you are entitled by law to request certain information regarding any disclosure that may have been made by Voxy to third parties of personal information for their direct marketing purposes. To make such a request, send a message to support@voxy.com.

17.3        The message should specify that you seek your “California Customer Choice Privacy Notice.” Please allow thirty (30) days for a response. Voxy is required to respond to only one request per customer each year, and is not required to respond to requests made by means other than through the above e-mail address.

17.4        We will not share your personal information with third parties for their direct marketing purposes if you request that we do not do so. You may make such a request by sending us a message at support@voxy.com.

17.5        When contacting us, please indicate your name, address, email address, and what personal information you do not want us to share with third parties for their direct marketing purposes. Please note that there is no charge for controlling the sharing of your personal information or for processing this request.

17.6        Non-discrimination

17.6.1    We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

(a)           Deny you goods or services.

(b)           Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

(c)           Provide you a different level or quality of goods or services.

(d)           Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

17.6.2    However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. Voxy does not currently offer any incentive programs related to personal information.

18           Information for Users residing in Brazil

18.1        This part of the Privacy Policy integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

18.2        The provisions contained in this section apply to all Users who reside in Brazil, according to the “Lei Geral de Proteção de Dados” (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

18.3        This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).

18.4        Voxy Brasil Serviços Educacionais Ltda. (“Voxy,” “we,” or “us”) welcomes you to www.voxy.com and any and all applications or mobile applications offered by Voxy (the “Site”). This Privacy Policy describes how Voxy collects and receives information about you through the Site, Services and Content and through Voxy’s businesses, including offline.

The Privacy Policy together with the Terms of Use govern your use of the Site and Voxy’s collection and use of your information.

Voxy is committed to protecting your privacy. We want to maintain a transparent relationship with you, and let you know how we collect and securely process any data you may provide us with. To this end, we have developed the current Privacy Policy, where you can gather all the relevant information and resolve any doubts that you may have in connection with the referred subject matters.

In the same way, we inform you that your data will be processed in accordance with the personal data protection laws currently in force; specifically, the “Lei Geral de Proteção de Dados” (“LGPD”).

18.5        Acceptance of Privacy Policy

Each time you access, use, or browse any Site or provide personal information to Voxy offline, you signify your acceptance of the then-current Privacy Policy.

If you do not accept this Privacy Policy, you are not authorized to provide information to Voxy or use the Site and must discontinue use of the Site immediately.

Should the Privacy Policy be revised, Voxy will post the changes on the Site which will be effective immediately upon posting. Any material changes to the terms of the Privacy Policy will apply only to information collected thereafter, unless you provide consent. You can determine when the Privacy Policy was last revised by referring to the “Last Revised” legend at the top of this page.

If you provide your personal information to Voxy offline, the Privacy Policy applies to Voxy’s collection and use of your information. Voxy also may provide paper copies of the Privacy Policy when it collects information from you offline. In addition to this Privacy Policy, you agree that the provisions in the Terms of Use also govern Voxy’s collection and use of your information collected offline.

18.6        Types of Information We Collect and Process

We may collect personal information from you including, without limitation, non-public information about you that helps Voxy identify you, such as first and last name, birth date, email address, home address, telephone number, password, preferences and interests, education level, ethnicity, marital status, shopping habits, Site usage, age, gender (collectively, “Personal Information”).

We can process your personal information solely if we have a legal basis for such processing, which includes:

i.           your consent to the relevant processing activities;

ii.          compliance with a legal or regulatory obligation that lies with us;

iii.         the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;

iv.         studies conducted by research entities, preferably carried out on anonymized personal information;

v.          the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;

vi.         the exercising of our rights in judicial, administrative or arbitration procedures;

vii.        our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and

viii.       credit protection.

Unless specified otherwise, all Data requested by the Site is mandatory and failure to provide this Data may make it impossible for the Site to provide its services.

We also may collect non-personal information about your use of the Site such as your IP address, usage statistics, browsing history, types of computers and/or mobile devices accessing the Site, Content or Services, type of computer operating system you use (e.g., Microsoft Windows or Mac OS), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer), and the domain name of your internet service provider (collectively, “Traffic Data”).

18.7        How We Collect and Transfer your Information

We may collect personal information from you when you use the Site or register an account to access Content, Services or Activities provided on the Site or to request to receive emails or newsletters that may be offered on the Site or offline.

Personal Information collected by Voxy may be stored and processed outside the Brazilian Territory, at the United States of America. By using the Site and submitting your personal information to Voxy online or offline, you expressly consent to the storage and processing of your personal information outside the Brazilian Territory.

We may combine Personal Information we collect through our Site or offline with information that we obtain from our affiliates, suppliers, vendors, merchants, licensors, partners or sponsors, and other sources (e.g., offline records or publicly available information). We will treat the combined information as personal information.

Voxy may automatically receive and record non-personal information on our server logs from your browser as well as through other analysis of the Site. We also may collect information using cookies, web beacons or similar technologies, or through third parties using similar technologies.

18.7.1    Cookies

We use “cookies” to customize your experience with the Site, Content and Services and to store your information, so you do not have to re-enter them each time you visit the Site or access the Content or Services. Cookies are small computer files that are transferred to your hard drive and contain information such as your username, user preferences, the web pages you’ve visited and the activities you’ve performed while using the Site, Content or Services. You may block or delete cookies from your hard drive; however, by disabling cookies, you may not have access to all of the Services or Content. Some of our business partners also use cookies to provide us with anonymous, aggregate data and information regarding our users. We do not have a access or control over these cookies, and our Privacy Policy does not cover the use of third party cookies.

In order to opt out of a third-party vendor’s use of cookies, visit the Network Advertising Initiative opt-out page.

18.7.2    Web Beacons

We or our third-party tracking utility company also use “web beacons” to collect information about your use of our Site, the websites of selected sponsors and advertisers, and our Content and Services. Web beacons are tiny graphic image files embedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user’s browser. The information collected by web beacons allows us to statistically monitor how many people are using our Site and Services, selected sponsors’ and advertisers’ websites and using our Services and for what purposes.

18.8        How We Use Your Information

We may use the information we collect:

i.          To alert you to new features, terms, Content, Services, Activities;

ii.         To send emails or newsletters, and to provide you with personalized content in the newsletters;

iii.         To analyze information regarding your browsing and viewing preferences;

iv.         To analyze our users’ demographics and interests;

v.          To administer Content, Services or Activities;

vi.         To process and respond to your inquiries;

vii.        To improve the Site;

viii.       For the purposes for which you provided the information; and

  1. To enforce the Terms of Use.

18.8.1    Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  1. Personal Data collected for purposes related to the performance of a contract shall be retained until such contract has been fully performed.
  2. Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes.

Voxy may be allowed to retain Personal Information for a longer period whenever you give consent to such processing, as long as such consent is not withdrawn. Furthermore, Voxy may be obliged to retain Personal Information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

All users of the Site’s teaching functionalities will have their personal information anonymized at the end of the contracts with Voxy, and their Personal Information will be erased in up to six (6) months, keeping solely the usage and navigation histories of the Voxy platform.

18.8.2    Information Sharing with Third Parties

Voxy may disclose the information it collects about you:

(i) to third parties to provide analytics for advertising purposes or to confirm or update information provided by you;

(ii) to suppliers, vendors and others who help Voxy provide services to you, such as outsourcing one or more of the functions described in this Privacy Policy;

(iii) to third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of Voxy’s business or operations (including without limitation in connection with bankruptcy or any similar proceedings); or

(iv) as otherwise authorized by you.

Voxy can also share Personal Information specifically with corporate clients that hired its services to be employed to employees, contractors or partners of a corporate client. In such cases the Personal Information can include your complete name, email address, phone number, study notes, grades, classes frequency and other information regarding the progress of the courses. When such corporate clients are the contractors of the students in any manner, the dispositions, agreements and terms amongst the students and the corporate clients will be applicable as well.

We also may share your information in response to a subpoena, legal order or official request, when we believe you have acted in violation of the Terms, to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats, or exercise legal rights or defend against claims, when we believe that doing so may protect your safety or the safety of Voxy or others, or as otherwise permitted or required by law.

We also may use and share non-personally identifiable information with third parties. Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified or aggregated form with advertisers, business partners, and/or third parties in order to analyze Site usage, perform services on our Site or others’ Site, improve our services, improve our user experience, or for similar purposes. We will not re-identify such data and we will ask our contracting parties to agree to keep the data in its de-identified form.

We sometimes contract with other companies and individuals to perform functions or services on our behalf such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services. They may have access to Personal Information needed to perform their functions but are restricted from using the Personal Information for purposes other than providing services for us or to us. Voxy requires that its agents and service providers that have access to Personal Information provide the same level of protection as required by the LGPD.

18.9        User Privacy Rights

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

i. Obtain confirmation of the existence of processing activities for your personal information;

ii. Withdraw their consent at any time;

iii.          Object to processing of their Data.;

iv.          Access their Data;

v.           Verify and seek rectification;

vi.         obtain anonymity, block or delete your unnecessary or excess personal information, or information that is not being processed in accordance with the LGPD;

vii.        Have their Personal Data deleted or otherwise removed;

viii.       Lodge a complaint to the Competent Authorities.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights, but you must bear in mind that, in some cases, limiting access to your personal information may prevent Voxy from providing some of its services to you.

18.9.1    How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

18.9.2    How and when we will respond to your request

We will strive to promptly respond to your requests.

In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

18.10     Communications with You

You authorize Voxy to transmit email to you to respond to your communications and administer Services, Content or Activities. If you participate in any Services, Content or Activities, you agree that Voxy is authorized to contact you by to send information and documents to you by email or postal mail. Unsubscribe instructions are included in each promotional email from Voxy or you may sent an email requesting to opt-out of communications to support@voxy.com .

Please note that such requests may take up to ten (10) days to become effective. You may not opt out of receiving communications regarding your dealings with Voxy or the Site, Content, Services or technical information about the Site.

18.11     Protection of Personal Information

Voxy uses reasonable administrative, physical and electronic security measures to protect against the loss, misuse and alteration of personal information. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Voxy to intercept or access transmissions or private communications unlawfully. While we strive to protect personal information, neither Voxy nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk.

18.12     Updating your Information

You are responsible for keeping your information current. You may update your information by contacting us at support@voxy.com or editing your account information. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to Voxy’s internal reporting, processing and retention policies and all applicable legal obligations.

18.13     Links

You may have the opportunity to follow links on the Site to other site that may be of interest to you. Voxy endeavors to only link to reputable organizations. Because other site may not be hosted or controlled by Voxy, we are not responsible for the privacy practices of those sites or the content provided thereon. Therefore, the privacy policies with respect to other site may differ from those applicable to the Site. We encourage you to review the privacy policies of each other site. This Privacy Policy only applies to information collected and maintained by Voxy.

18.14     Questions? Contact the Owner and Data Controller

If you have any questions or concerns regarding this Privacy Policy, please contact us at: datacontroller@voxy.com or support@voxy.com .

The requests must be addressed to the Brazilian Data Privacy Dept.

COOKIE POLICY

Voxy, Inc. (Voxywe, or us) welcomes you to www.Voxy.com and any and all platforms, applications or mobile applications offered by Voxy, Inc (the Site). Voxy uses cookies on our Site as described in this cookie policy.

We use “cookies” to customize your experience with the Site, content and Services and to store your information so you do not have to re-enter them each time you visit the Site or access the Content or Services. Please review this cookie policy carefully.

This cookie policy was last updated on [August] 2021.

Some cookies collect personal data. For details on how we collect and use personal data, please see our Privacy Policy.

What are cookies?

A cookie is a small text file that is stored by your browser, and allows it to remember information between web pages and browser sessions.

There are two main types of cookies:

  • Session cookies: specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don’t have to re-enter information when you navigate to a new page.  Session cookies are not permanently stored on your device and are deleted when the browser closes.
  • Persistent cookies: record information about your preferences and are stored in your browser cache or mobile device.

Turning off and deleting cookies

You can amend your cookie settings by selecting ACCEPT or DECLINE on the cookie consent pop-up on our Site. If you select DECLINE then non-essential cookies will not be deployed on your device.

In addition, all web browsers allow you to limit cookie behaviour or turn off cookies within the settings or options of the browser. The steps to do this are different for each browser, you can find instructions under the Help menu of your browser. Through your browser you can also view the cookies that are on your computer, and delete individual ones, or purge them all.

Please note that you may not be able to take advantage of all the features of our Site and Services and there may be issues with Site and Service functionality if you delete or refuse certain essential cookies.

What do those cookies do?

We have categorised the cookies on our Site as set out below:

Type of CookiePurpose of Cookie
EssentialThese cookies are essential for you to browse our Site and use its features.  The information collected relates to the operation of the Site and enables us to provide the Site to you.
Functionality/optimisationThese cookies remember the choices you have made, for example the country you visit our Site from, your language and any changes you have made to text size and other parts of the web pages that you can customise to improve your user experience and to make your visits more tailored and enjoyable.
AnalyticsThese cookies collect information on how users use our Site, for example which pages you visit most often, which sessions you attend, whether you receive any error messages and how you arrived at our Site.  Information collected by these cookies is used to analyse and improve your use of our Site.

 

In addition, we have set out below more detailed information regarding the cookies placed when you visit the Site. We have tried to be as comprehensive as possible in providing this list. However, the cookies and similar technologies on the Site will change from time to time.

Cookies used on the Voxy.com web site

CategoryCookieCookie DurationPurpose
Analytics_ga_BYBG9N694K2 yearsGoogle Analytics: tracks aggregate platform usage for purposes of improving marketing initiatives and improving the platform. See more information at  https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Analytics_ga2 yearsGoogle Analytics: tracks aggregate platform usage for purposes of improving marketing initiatives and improving the platform

Cookies used in the Voxy platform

CategoryCookieCookie DurationPurpose
Essentialsessionid1 monthidentifies user session for authentication and authorization purposes, assigned by voxy application
Essentialmy_languagesessionapplication uses to identify users language
Essentialcsrftoken1 yeardjango cooke to prevent cross site forgery
Essentiallogglytrackingsessionsessionusage to correlate debugging and troubleshooting logs
Analytics_mkto_trk2 yearsused by our operational email tool, Marketo, as an identifier to send out operational emails and user usage on our platform
Analytics_ga2 yearsGoogle Analytics: tracks platform usage for purposes of improving the platform. See more information at  https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
AnalyticsPendo (local storage) Pendo_* Pendo: tracks platform usage for purposes of improving the platform; also allows Voxy to message users on the platform for support and informational purposes
EssentialZendesk (local storage) ZD_* Zendesk: allows support team to troubleshoot and interact with users and customers

 

Other technologies

In addition to cookies, we use some other similar technologies as follows:

  • Web Beacons: We or our third party tracking utility company also use “web beacons” to collect information about your use of our Site, the websites of selected sponsors and advertisers, and our content and Services. Web beacons are tiny graphic image files embedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user’s browser. The information collected by web beacons allows us to statistically monitor how many people are using our Site and Services.
  • SDKs: these are mobile application third party software development kits used in our apps.  They enable us to collect information about app activity and the device it runs on, in order to troubleshoot and improve our platform.]

Changes to our Cookie Policy

This cookie policy may be updated from time to time.

If we change anything important about this cookie policy we will notify you through a pop-up on the Site for a reasonable length of time prior to and following the change. You may review the cookie policy by visiting our Site and clicking on the Privacy Policy link.