Culangex Privacy Policy

The Services are used by several types of people, and different rules may apply to each:

• Individual consumers who download or play our game (for example, via Steam).
• Children under 13 and their parents or guardians (see Section 9).
• Schools, districts, and institutional partners and their enrolled students (see Section 10 and our Institutional Data Protection Addendum).
• Visitors to our website, including prospective investors, partners, and grant reviewers.

Where there is any conflict between this Policy and a separately signed agreement (such as an Institutional Data Protection Addendum or a written contract with a school), the separately signed agreement controls for that relationship.

We use information to:

• Provide, operate, and maintain the Services, including pronunciation feedback and adaptive learning features.
• Create and manage accounts and authenticate users.
• Process transactions and deliver purchased content.
• Measure learning progress and improve curriculum and game design.
• Provide customer support and respond to inquiries.
• Monitor for security, fraud, abuse, and Terms of Service violations.
• Improve, test, and develop new features (using de-identified or aggregated data wherever feasible).
• Comply with legal obligations and enforce our agreements.

We do not sell personal information, and we do not use children's personal information for targeted or behavioral advertising.

For users we know to be children under 13, we use personal information only for the internal operation of the Services and only as permitted by COPPA and with the consent described in Section 9.

If you are in the European Economic Area or the United Kingdom, we process personal data under one or more of these legal bases: your consent (which you may withdraw at any time, including for Voice Data and biometric processing); performance of a contract with you; compliance with a legal obligation; and our legitimate interests in operating and improving the Services, where not overridden by your rights.

We share information only as described here:

• Service providers / processors who perform services for us (hosting, analytics, speech and AI processing, payment processing, customer support) under contracts that limit their use of the information to providing services to us.
• Distribution platforms (for example, Steam) as needed to deliver and operate the game.
• Schools and institutional partners, where a student uses the Services through that institution (see Section 10).
• Legal and safety disclosures, when required by law, subpoena, or legal process, or to protect the rights, safety, and property of Culangex, our users, or others.
• Business transfers, in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy and applicable law.
• With your direction or consent, including any sharing you choose to enable.

We do not sell or rent personal information, and we do not share children's personal information except as necessary to provide the Services or as required by law.

We keep personal information only as long as needed for the purposes described in this Policy, then delete or de-identify it.

• Voice Data: We retain raw voice recordings for no more than 30 days, the period necessary to generate feedback and perform quality assurance, after which we delete the raw recordings and retain only derived, non-identifying pronunciation metrics, unless a longer period is required by law or you have consented to longer retention.
• Account data: Retained while your account is active and for a reasonable period afterward, then deleted or de-identified.
• Children's data: Retained only as long as reasonably necessary to fulfill the purpose collected, then deleted (see Section 9).

Depending on where you live, you may have the right to:

• Access the personal information we hold about you.
• Correct inaccurate information.
• Delete your information.
• Port your information to another service.
• Opt out of certain processing.
• Withdraw consent at any time, including consent to process Voice Data or biometric information.

To exercise these rights, contact us at privacy@culangex.com. We will verify your request before acting on it. We will not discriminate against you for exercising your rights.

Some jurisdictions regulate biometric identifiers and information, including voiceprints. Where our processing of Voice Data constitutes the collection of a biometric identifier:

• We collect and process Voice Data to provide pronunciation feedback and progress measurement, and for no other purpose.
• We obtain consent before collecting biometric information where required, and for children under 13 we obtain verifiable parental consent (Section 9).
• We do not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information.
• We retain biometric information only as described in Section 6 and destroy it when the initial purpose is satisfied or within the period required by applicable law, whichever is sooner.
• We protect biometric information using the security measures described in Section 13.

Illinois residents: This section, together with our retention schedule, is intended to serve as our publicly available biometric data retention and destruction policy.

We knowingly permit children under 13 to use the Services, and we comply with the U.S. Children's Online Privacy Protection Act (“COPPA”). Our practices for children are described in detail in our separate Children's Privacy & Parental Consent Notice, which is incorporated into this Policy. In summary:

• We provide direct notice to parents and obtain verifiable parental consent before collecting personal information (including Voice Data) from a child under 13, except where COPPA provides a limited exception.
• We collect only the information reasonably necessary for a child to participate.
• We do not condition a child's participation on disclosing more information than is reasonably necessary.
• We do not use children's information for targeted advertising or to build profiles for advertising.
• Parents may review, delete, or refuse further collection of their child's information by contacting privacy@culangex.com.

If you believe we have collected information from a child without the required consent, contact us immediately at privacy@culangex.com and we will delete it.

When a school, district, or other educational institution provides the Services to its students:

• We act as a school official / service provider with a legitimate educational interest under the Family Educational Rights and Privacy Act (“FERPA”), processing student data on behalf of and under the direction of the institution.
• The institution may provide consent on behalf of parents for the collection of student information in the educational context, as permitted by COPPA's “school consent” framework, provided the data is used only for the educational purpose authorized by the school.
• We use student personal information only to provide the Services to the institution and do not use it for our own commercial purposes, advertising, or to build non-educational profiles.
• Our handling of student data is further governed by our Institutional Data Protection Addendum and any signed agreement with the institution.

On our website we use cookies and similar technologies for essential functionality, preferences, security, and aggregate analytics. Full details are in our Cookie Policy. You can control cookies through your browser settings; disabling some cookies may affect site functionality. We honor recognized opt-out signals (such as Global Privacy Control) where required by law. We do not use advertising cookies in connection with children.

We are based in the United States and process information there and in other countries where our service providers operate. Where required, we use appropriate safeguards (such as Standard Contractual Clauses) for cross-border transfers of personal data.

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls, and a heightened standard of protection for Voice Data and children's data. No system is perfectly secure, and we cannot guarantee absolute security.

California residents have the rights described in Section 7, plus the right to know the categories of personal information collected and disclosed, the right to limit use of sensitive personal information, and the right to non-discrimination. We do not sell or share personal information as those terms are defined under California law. Voice Data and biometric information are treated as sensitive personal information, and we limit its use to providing the Services. To exercise rights, contact privacy@culangex.com.

We may update this Policy from time to time. We will post the updated version with a new “Last Updated” date and, for material changes affecting children's data or biometric data, we will obtain renewed consent where required by law.