PRIVACY POLICY

We're updating our Privacy Policy to make it easier to read, be more transparent, and to reflect improvements we are making at Busuu. These changes will come into effect on November 17, 2024, and your continued use of the Busuu service after this date will be subject to our updated Privacy Policy.

These changes include:

• The data controller for the Busuu service will change to our parent company, Chegg, Inc. This means that Chegg will process your personal data in accordance with the updated Privacy Policy.
  
• We have consolidated two separate policies into one. You will now see a Supplemental Privacy Policy for Busuu along with a single Privacy Policy for all Chegg services.
  
• The Supplemental Privacy Policy for Busuu provides information about some of the features that Busuu offers to help improve your pronunciation and conversation skills, including our use of artificial intelligence (AI) and machine learning (ML).
  

Supplemental Privacy Policy for Busuu

The purpose of this Supplemental Privacy Policy for Busuu ("Supplemental Privacy Policy") is to describe how we at Busuu Limited, including our parent company Chegg, Inc., together with other affiliates and subsidiary companies (collectively, "Chegg") use the personal information that we collect when you use Busuu.

The main Chegg Privacy Policy provides information on how and why your personal information is processed or used to support Chegg services (including Busuu), the legal grounds for the processing, the privacy choices you may exercise under applicable data protection laws, and the contact details for the exercise of such choices. This Supplemental Privacy Policy supplements (but does not replace) the Chegg Privacy Policy by providing additional details on the personal information that we collect, use, and share when you use Busuu.

Where there is an inconsistency or contradiction between this Supplemental Privacy Notice and the Chegg Privacy Notice, this Supplemental Privacy Notice shall prevail in relation to your use of Busuu. Capitalized terms used but not defined in this Supplemental Privacy Policy shall have the meanings given to them in the Chegg Privacy Policy.

This Supplemental Privacy Policy consists of two parts:

• Part One sets out the privacy practices that apply across our Services.<
  
• Part Two sets out the privacy practices specific to Busuu.
  

PART ONE: OUR PRIVACY PRACTICES ACROSS OUR SERVICES

The main Chegg Privacy Policy is available here.

PART TWO: SUPPLEMENTAL INFORMATION SPECIFIC TO BUSUU

1. Who We Are

Chegg, Inc. is the data controller (i.e., the entity that determines the means and purposes of collecting, using, and disclosing personal information) of the personal information that we collect about you when you use Busuu.

2. Personal, Sensitive, and Non-Personal Information We Collect and How We Use and Disclose It

In addition to the information described in the Chegg Privacy Policy under section 1 "Personal, Sensitive, and Non-Personal Information We Collect and How We Use and Disclose It" (available here), we collect the additional following categories of information when you use Busuu:

A. Online usage information, which includes content consumed and, where applicable, your answers, course progression, proficiency, and other usage information, such as lesson consumption (e.g., lessons, checkpoints, and certificates), Smart Review consumption, fluency score, Smart Review percentage and strength, number of words learned, and certificates achieved.

a. Purposes for Collection: (1) Provide You with Services (provide you with content or other services and allow you to participate in features we offer; send you transactional messages regarding your use of our Services, purchases, and other account-related communications; respond to your inquiries; provide customer support; provide you with your performance evaluations or other results); (2) Advertising Activities and Marketing Messages (to send you offers, promotions, invitations, and similar information from us, our advertisers, or third parties); (3) Personalization (to identify your preferences; tailor content, including advertising and recommendations, to you on the Services and on other websites and services); (4) Internal Business Purposes (to operate and improve our products and services; detect and troubleshoot problems; market research); (5) Security (to investigate, prevent, detect, and protect against misuse of our systems, fraud or other crime, or activities that violate our policies); (6) Legal (to comply with the law; resolve disputes; enforce our agreements and policies; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights or assets); (7) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, including during due diligence); (8) Other Purposes as Disclosed at the time of collection/with your consent

b. Categories of Third Parties the Data May Be Disclosed To: (1) Other Users (including instructors and students, depending on the Services you interact with); (2) Affiliated Companies; (3) Technology Systems Service Providers (including webhosts, database hosts, software-as-a-service or other cloud computing providers, and technology maintenance and repair vendors); (4) Security Vendors; (5) Customer Service Providers (including call centers and live chat vendors); (6) Financial Assistance Partners; (7) Third-Party Business Partners (unaffiliated parties that are joint marketing partners or whose products or services are bundled with our Services); (8) Government Agencies and Law Enforcement or Where Required By Law; (9) Third Parties in connection with court or other legal actions; (10) Third Parties who acquire the information in connection with a business transition; (11) Third Parties to whom you agree or direct us to share your information; (12) Other service providers who use your data solely to provide services to us or to you

c. Third Parties to whom the Data May Be Sold/Shared for Targeted Advertising: This category of data is not sold or shared for targeted advertising.

3. Non-Personal Information

We collect, use, and share aggregated data, such as statistical or demographic data, for our lawful business purposes, including to analyze, build, and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you for any purpose. Aggregated data may be derived from personal information, but is not considered personal information as this data does not directly or indirectly reveal your identity. For example, research and survey results will be aggregated and may be used for marketing purposes. We also aggregate usage data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect aggregated data with your personal information such that it can directly or indirectly identify you, we will treat the combined data as personal information which will be used in accordance with this Supplemental Privacy Policy.

4. Disclosure of Personal Information

When you use the Busuu service, you may set up your personal profile, connect with other learners, send and receive messages, perform searches and queries, enroll in events and courses, and transmit information through various channels. We display your profile information (except for your email address and password) to other users browsing for friends and to support other site functions.

Per the Chegg Privacy Policy, we do not allow service providers to use your personal data for their own purposes, and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Further details on our disclosure of data to third parties are provided in the Chegg Privacy Policy under section 2 "Additional Information Regarding Certain Information and Uses" (in particular under sub-section D "Data We Disclose to Third Parties") and section 3 "Third-Party Advertising and Analytics/Privacy Controls/Do-Not-Track" (available here).

We also engage in online advertising practices (and certain analytics or similar activities) that may be considered "targeted advertising" under certain laws. Details on how to opt out of the processing of your personal information for the purposes of targeted advertising and how to exercise your privacy choices are available in the Chegg Privacy Policy under section 4 "Your Choices and Opt-Out Rights" (available here)

We may also disclose your personal information to companies within our family of companies, including but not limited to Busuu Online S.L.

5. Information Regarding Certain Information and Uses

In addition to the uses of information described in the Chegg Privacy Policy under section 2 "Additional Information Regarding Certain Information and Uses" (available here), we use information we collect when you use Busuu in the following ways:

A. Audio-Only AI Pronunciation Assistance Recordings ("Speaking Practice")

The Speaking Practice feature allows you to practice speaking and receive AI-generated feedback on how to improve your pronunciation.

If you choose to use this feature (which is an AI-powered service), your voice will be recorded, retained, and used to provide you with the service you requested (to provide you with feedback on your pronunciation) and to improve our services. Some portions of this feature are powered by service providers, such as Azure AI Speech services. We may also process such audio information to troubleshoot and improve the service by training our machine-learning models with support from expert human reviewers. Such audio information will not be used to uniquely identify you.

B. Audio-Only Community Recordings ("Community Corrections")

The Community Corrections feature allows you to either write or record your voice to submit to other Busuu users for feedback. A proficient speaker of the language you are learning will provide feedback, and in turn, you will also have the opportunity to provide feedback to learners of your own language.

If you choose to participate in the audio component of the Community Corrections feature, your voice will be recorded, retained, and used to provide you with the service you requested and to keep our services safe for all language learners. Such audio information will not be used to uniquely identify you. Additionally, some portions of this feature are supported by service providers for their content moderation services.

C. Audio-Only AI Conversations Recordings ("Conversations")

The Conversations feature allows you to have a conversational, spoken interaction with an AI-powered language partner specific to topics you are learning.

If you choose to use this feature (which is an AI-powered service), your voice will be recorded, retained, and used to provide you with the service you requested (to facilitate interactive conversational scenarios for your language learning) and to improve our services. Some portions of this feature are powered by OpenAI and other service providers. We may also process such audio information to troubleshoot and improve the service by training our machine-learning models with support from expert human reviewers. Such audio information will not be used to uniquely identify you.

6. Information for European Union/European Economic Area and United Kingdom Residents

You can find out about the legal bases we rely upon and how they relate to the ways in which we process your information in the Chegg Privacy Policy under section 11 "Information for European Union/European Economic Area and United Kingdom Residents" (available here).

In relation to video or audio recording when using certain community or AI-powered features, we rely on our legitimate interests to improve our services in accordance with your choices.

7. Data Privacy Choices

You can learn more about the consumer privacy choices that may be available to you by reviewing section 4 of the Chegg Privacy Policy available here.

In particular, you may, for example, request a copy of the personal information held about you, or request changes or the deletion of your personal information, by sending an email to privacy@busuu.com.

8. Contact Us

If you would like to exercise a privacy choice, or if you have any questions or suggestions regarding our privacy practices, you can contact us by email at privacy@busuu.com, or by writing to us at Broadwalk House, 5 Appold Street, London, EC2A 2AG, United Kingdom.