Effective Date: June 30, 2026. Previous versions available upon request.

Preamble

This Privacy Policy (“Policy”) describes how inlingua International Ltd. (“inlingua”, “we”, “us”, or “our”), a company registered at Belpstrasse 11, CH-3007 Bern, Switzerland, collects, uses, stores, and protects personal data. It applies to all individuals who interact with inlingua in any capacity, including but not limited to: visitors to the inlingua website (www.inlingua.com), users of the inlingua online learning platform (my.inlingua.com), prospective and current licensees, license applicants, and business partners. This Policy also applies to personal data processed through API or LTI integrations with my.inlingua.com as used by local inlingua Centers or their B2B clients.

inlingua International Ltd. is the data controller within the meaning of the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and the Swiss Federal Act on Data Protection (“revFADP”). inlingua is committed to protecting personal data and processes it in accordance with applicable data protection law.

This Policy is to be read in conjunction with inlingua’s Terms of Use (governing use of the inlingua website). Where a User accesses Services through a local inlingua Center, the terms and conditions of that Center may also apply. Local Center terms are issued independently by each Center and are not controlled by inlingua International Ltd. Users should contact their local Center directly to obtain the applicable terms.

This Policy takes precedence over the Terms of Use with respect to data protection matters. Where a local Center’s terms address data protection, users are advised to review those terms alongside this Policy. inlingua International Ltd. does not assume responsibility for the data protection compliance of independently operated local Centers.

Where inlingua provides Online Learning Services through a local Center or directly, the provisions of this Policy apply to all personal data processed in connection with those services. Specific service terms are set out in the applicable service agreement or the terms and conditions of the local Center.

For non-data-protection matters (e.g., intellectual property, acceptable use), see our Terms of Use at www.inlingua.com/terms-of-use.

Data Protection Officer (DPO)

For matters related to data protection, you may contact our Data Protection Officer at:

  • Email: dpo@inlingua.com
  • Postal Address: Data Protection Officer, inlingua International Ltd., Belpstrasse 11, CH-3007 Bern, Switzerland

The DPO is responsible for monitoring compliance with this Policy and applicable data protection laws.

1. Confidentiality – Protection of Personal Privacy

inlingua complies with the General Data Protection Regulation (Regulation (EU) 2016/679) and the Swiss Federal Act on Data Protection (revFADP), which regulate the processing of personal data within the European Union and Switzerland respectively.

inlingua will make all reasonable efforts to ensure that the Services meet technical standards and security norms. To safeguard the confidentiality of the User’s personal data, inlingua and its partners utilize security techniques and procedures including: daily security and vulnerability scans, software audits, firewalls, and data encryption (TLS/SSL). inlingua makes every effort to protect data against loss and unauthorized access.

In the event of a personal data breach or unauthorized access to personal data, inlingua will notify affected individuals and relevant supervisory authorities in accordance with applicable data protection law (GDPR Art. 33–34). For Swiss users, notifications will be made to the Federal Data Protection and Information Commissioner (FDPIC) where required under revFADP.

Despite these security measures, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, inlingua cannot guarantee absolute security of personal data transmitted over the Internet.

2. Protection of Children’s Information

inlingua is committed to protecting the privacy of children. The inlingua website and services are general audience platforms and are not designed or intended to attract children. inlingua applies the following age-based rules in accordance with GDPR Article 8:

  • Users under the age of 16 may not use the Services without verifiable parental or legal guardian consent.
  • Users aged 16 to 17 must obtain parental or legal guardian consent before using the Services.
  • inlingua does not knowingly collect personal information from children without such consent.

Where parental consent is required, the applicable consent procedure is provided by the local inlingua Center or via the registration process. The lawful basis for processing children’s data with parental consent is GDPR Article 6(1)(a) (consent) in conjunction with Article 8.

Note: Under GDPR, ‘children’ refers to individuals under 16. Users aged 16–17 are not classified as children but still require parental consent to use our Services.

3. Registration and Personal Profile

When the User registers for inlingua’s online learning services, personal data is collected as necessary to provide those services. The User is responsible for ensuring that the personal data they provide is accurate and up to date.

inlingua respects the User’s privacy and does not sell, rent, or trade the User’s name or personal details to other organizations or use them for marketing purposes without the User’s consent. Where personal data is collected for further purposes, inlingua will inform the User of the lawful basis for that processing.

Lawful Bases for Processing

We process personal data based on the following lawful bases under GDPR Article 6:

  • Contract Performance (Art. 6(1)(b)): To provide the Services and fulfill our contractual obligations.
  • Legal Obligation (Art. 6(1)(c)): To comply with applicable laws (e.g., tax, employment).
  • Legitimate Interests (Art. 6(1)(f)): For improving our Services, ensuring security, and preventing fraud, where our interests are not overridden by your rights.
  • Consent (Art. 6(1)(a)): For marketing communications and non-essential cookies, where we obtain your explicit consent.

Data Minimization

We collect only the personal data that is adequate, relevant, and limited to what is necessary for the intended purposes (GDPR Article 5(1)(c)).

Profile data collected may include: name, username, email address, phone number, date of birth, country, city, address, timezone, and interface language (where provided by the User). This data is available only to authorized administrators or company supervisors.

inlingua uses collected information to:

  • Deliver the Services and products that the User has requested (billing, identification, authentication);
  • Manage the User’s account and provide customer support;
  • Contact the User about their use of the Services;
  • Conduct research and aggregate analytics;
  • Improve the content and functionality of the Services and Website;
  • Enforce inlingua’s terms and conditions;
  • Manage inlingua’s business operations;
  • Comply with legal obligations and respond to lawful requests from authorities.

4. Data Subject Rights

Under GDPR and revFADP, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at dpo@inlingua.com or using the contact details in Section 13. We will respond to your request within 30 days as required by law. For Swiss users, requests will be processed in accordance with revFADP.

If the User’s personal data changes, or if the User no longer desires the Services, they may correct or update their personal information via the account settings page. Account deletion requests must be submitted to inlingua Customer Support or the local Center. Upon deletion, no refunds are due for unconsumed services and no user data can be retrieved thereafter.

inlingua retains personal data for as long as the account is active or as needed to provide Services, comply with legal obligations, resolve disputes, and enforce agreements. Note that account metadata and learning records are subject to different retention periods — see Section 16 (Data Retention Policy) for details. An account remains active even after a paid subscription has expired.

To exercise any of these rights, contact our Data Protection Officer at dpo@inlingua.com or by post at: DPO, inlingua International Ltd., Belpstrasse 11, CH-3007 Bern, Switzerland. You also have the right to lodge a complaint with your local supervisory authority at any time without prejudice to any other administrative or judicial remedy.

5. Who We Share Your Information With

inlingua may provide the User’s personal data to companies that provide services necessary for our business activities, such as processing payments, providing customer service, or maintaining IT infrastructure. These companies are authorized to use the User’s personal data only as necessary to provide these services to inlingua.

inlingua may provide the User’s personal data to the local Center operating in or close to the User’s location area.

To ensure the quality of inlingua’s Services, inlingua may provide the results of the User’s placement, progress, and achievement tests, as well as activity results, to create pedagogical reports for the inlingua trainer assigned to the User.

Where local inlingua Centers or their B2B clients connect to my.inlingua.com via API or LTI integration, personal data (including learning progress and activity results) may be transmitted to and processed within those integrations. Such integrations are subject to a separate data processing agreement between inlingua and the respective Center. inlingua acts as data controller for personal data processed through these integrations.

inlingua may also disclose the User’s personal data as required by law, such as to comply with a subpoena or similar legal process, and/or when inlingua believes in good faith that disclosure is necessary to protect inlingua’s rights, protect the User’s safety or the safety of others, investigate fraud, or respond to a government request.

inlingua may also disclose the User’s personal data to any other third party with the prior consent of the User.

Data Processing Agreements

Where we share personal data with third-party processors, we ensure that appropriate Data Processing Agreements (DPAs) are in place in accordance with GDPR Article 28. These agreements require processors to implement appropriate technical and organizational measures to protect personal data.

6. Use of Cookies and Similar Technologies

This Website uses cookies and similar technologies (e.g., pixels, tags) to support website functionality and analytics. We use Google Analytics, a web analytics service provided by Google LLC, to analyze how Users use the site. Google Analytics collects information about your use of the Website (including IP address, which is anonymized before transmission) and transmits it to Google servers.

For Users in the EEA, UK, and Switzerland, non-essential cookies (including Analytics cookies) are only set after you have given your explicit, informed consent via our Cookie Consent Banner. Consent is not implied by continued browsing of the Website. You may withdraw your consent at any time via the cookie preferences center or by adjusting your browser settings.

Cookie Categories

  • Strictly Necessary Cookies: Essential for the Website to function. No consent required.
  • Performance Cookies: Help us improve the Website. Consent required under GDPR/ePrivacy.
  • Functional Cookies: Remember your preferences. Consent required under GDPR/ePrivacy.
  • Marketing Cookies: Deliver targeted advertising. Consent required under GDPR/ePrivacy.

You can deactivate Google Analytics at any time by downloading and installing the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout). For more details, see our Cookies Policy at www.inlingua.com/cookie-policy.

7. Log Files and Automated Data Collection

As is standard with most websites, inlingua gathers certain information automatically and stores it in log files. This information includes IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. Log files are retained for 90 days and are primarily used for security monitoring and aggregate trend analysis.

Occasionally, inlingua may connect personal data to information gathered in log files as necessary to improve the Service to individual Users. Otherwise, this information is used without connection to individual Users.

Automated Decision-Making and Profiling

inlingua does not use automated decision-making (including profiling) that produces legal effects or similarly significant effects on Users (GDPR Article 22). Any automated processing is limited to non-consequential purposes such as:

  • Personalizing learning recommendations based on User progress.
  • Improving the Website and Services through aggregate analytics.

If we introduce automated decision-making with significant effects in the future, we will update this Policy and provide information about the logic involved and the envisaged consequences for the User. Users will have the right to object to such processing and request human intervention.

8. Links to Other Websites

The inlingua Website contains links to other sites. inlingua is not responsible for the privacy practices of such other sites. inlingua encourages Users to be aware when leaving the inlingua Website and to read the privacy statements of any website that collects personally identifiable information. This Privacy Policy applies only to information collected by inlingua.

9. Testimonials

inlingua may post User testimonials on its Website which may contain personally identifiable information. Publication of testimonials is subject to the User’s prior written consent. If the User wishes to have their testimonial removed, they should contact inlingua Customer Service (see contact details in Section 13 below).

10. Communications from the Website

inlingua will send to the User strictly service-related announcements (e.g., maintenance notifications, security alerts) when necessary. These communications are not promotional and cannot be opted out of unless the User deactivates their account, as they are necessary for the performance of the contract.

The User may at any time unsubscribe from promotional emails by clicking the unsubscribe link at the bottom of each email. For Users in the EEA/UK, we will honor opt-out requests within 10 business days, as required by the ePrivacy Directive. Marketing communications are only sent where we have obtained your prior consent or where we have a legitimate interest permitted under applicable law.

11. Enforcement and Compliance

inlingua will continuously monitor its privacy practices and continued compliance with the GDPR, revFADP, and the Terms of Use.

Records of Processing Activities

In accordance with GDPR Article 30 and revFADP, inlingua maintains records of its processing activities, including:

  • The purposes of processing.
  • Categories of personal data and data subjects.
  • Recipients of personal data.
  • Retention periods.
  • Technical and organizational security measures.

These records are available to supervisory authorities upon request.

12. Changes to the Privacy Policy

inlingua may update this Policy from time to time. For material changes, inlingua will post a prominent notice on the Website at least 30 days before the change takes effect. For non-material changes, the Policy may be updated without prior notification. inlingua encourages the User to periodically review this page for the latest information on our privacy practices.

13. Contact Us

For questions regarding this Policy or about inlingua’s privacy practices, please contact:

Data Controller:

inlingua International Ltd.

Belpstrasse 11, CH-3007 Bern, Switzerland

Email: service@inlingua.com

Phone: +41 (0)31 388 77 00

Data Protection Officer (DPO):

Email: dpo@inlingua.com

Postal Address: DPO, inlingua International Ltd., Belpstrasse 11, CH-3007 Bern, Switzerland

Local Centers:

Contact your local inlingua Center for region-specific inquiries. A list of Centers is available at www.inlingua.com.

Supervisory Authorities:

EEA/UK Users: You have the right to lodge a complaint with your national data protection supervisory authority under GDPR Article 77.

Swiss Users: You have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch.

14. Third-Party Tools and Data Processors

This Privacy Policy applies not only to information collected through the inlingua Website (www.inlingua.com) but also to personal data collected through third-party tools and platforms used by inlingua International Ltd. in the course of its business activities. This includes tools used for license applications, partner onboarding, appointment scheduling, and business development inquiries. inlingua may update its use of third-party tools from time to time; this clause applies to all such tools irrespective of whether they are individually named herein.

Where inlingua uses third-party platforms to collect or manage personal data, inlingua acts as the data controller. The third-party platform provider acts as a data processor on inlingua’s behalf, subject to a Data Processing Agreement (DPA) in accordance with GDPR Article 28. inlingua ensures that all third-party processors provide sufficient guarantees of GDPR-compliant data processing.

Currently Used Third-Party Processors

  • Microsoft 365 (Forms, Lists, and related services): Provided by Microsoft Corporation and its affiliates. Data is processed and stored on Microsoft’s servers within the EEA or in third countries subject to Standard Contractual Clauses (SCCs), governed by the Microsoft Products and Services Data Protection Addendum. Privacy Statement: https://privacy.microsoft.com
  • Amelia Booking Plugin: Provided by TMS Plugins. Hosted on inlingua’s own infrastructure in Switzerland. Personal data entered through Amelia (name, email address, appointment details) is stored in inlingua’s own database and is subject to the same security and data protection standards as all other data collected by inlingua. Privacy information: https://wpamelia.com/privacy-policy/

inlingua does not share personal data with any third party beyond those named above, except as described in Section 5 of this Privacy Policy or as required by applicable law. For further details, see the contact information in Section 13.

15. Data Processing in the License Application Process

Prospective inlingua licensees (“Applicants”) may be asked to submit personal and business-related information as part of the inlingua license application process. This data is collected for the following purposes:

  • Evaluating the suitability of the Applicant and the proposed license territory;
  • Conducting due diligence in accordance with inlingua’s licensing standards;
  • Communicating with the Applicant throughout the application and onboarding process;
  • Complying with inlingua’s legal and contractual obligations.

The legal basis for this processing is GDPR Article 6(1)(b) (processing necessary for the performance of pre-contractual measures taken at the request of the data subject) and, where applicable, GDPR Article 6(1)(f) (legitimate interests of inlingua International Ltd. in evaluating and managing its licensee network).

Application data will be retained for the duration of the application process and, in the event of a successful application, for the duration of the license agreement and any applicable statutory retention periods thereafter. In the event of an unsuccessful application, data will be deleted within 12 months of the final decision, unless the Applicant has consented to longer retention for future consideration.

Special Category Data

In rare cases, license applications may require processing of special category data (e.g., financial information, criminal records for background checks). Such processing is carried out only where:

  • Explicit consent is obtained from the Applicant (GDPR Article 9(2)(a)); or
  • Processing is necessary for compliance with legal obligations (GDPR Article 9(2)(g)); or
  • Processing is necessary for the establishment, exercise, or defense of legal claims (GDPR Article 9(2)(f)).

We will inform Applicants in advance if special category data is required and provide details of the lawful basis for processing.

16. Law, Jurisdiction, Severability, and Data Retention

This Privacy Policy is governed by Swiss law and, where applicable, the GDPR and UK GDPR.

Any disputes relating to data protection matters under this Privacy Policy will be subject to the jurisdiction of the courts of Berne, Switzerland. Individuals within the EU/EEA have the right to lodge a complaint with their local data protection supervisory authority (GDPR Article 77). Swiss users may lodge a complaint with the FDPIC (www.edoeb.admin.ch).

Severability

If any provision of this Policy is found to be unlawful, void, or unenforceable, the other provisions will remain in full force and effect. If any provision is partially invalid, the invalid part will be deemed severed, and the remaining part will continue in effect.

Assignment

inlingua International Ltd. may transfer its rights and obligations under this Policy to a successor entity within the same corporate group in the event of an internal restructuring. In such cases, the successor entity will be bound by this Policy and personal data will continue to be processed in accordance with its terms. Notice of any such transfer will be posted on the Website. The processing of personal data will not be affected by such a transfer.

Entire Agreement

This Policy, together with the Terms of Use and any applicable local Center terms, constitutes the entire agreement between you and inlingua regarding the processing of personal data and supersedes all prior or contemporaneous agreements, representations, or understandings.

Data Retention Policy

We retain personal data for the following periods. After the applicable retention period, personal data will be securely deleted or anonymized, except where retention is required by law (e.g., for tax or legal purposes).

inlingua International Ltd. · Belpstrasse 11, CH-3007 Bern, Switzerland · service@inlingua.com · www.inlingua.com

Data Type Retention Period Legal Basis
Account Metadata 2 years after account closure GDPR Art. 5(1)(e), revFADP
Learning Records Duration of Services + 5 years Contractual obligation
Payment Data 7 years Tax / legal requirements
Marketing Data Until withdrawal of consent GDPR Art. 6(1)(a)
License Application Data Duration of application + 12 months (or per Section 15) GDPR Art. 6(1)(b), (f)
Log Files 90 days Legitimate interest (security)