The purpose of this Privacy Policy is to describe how Dharma Initiative AG, a company duly incorporated and existing under the laws of Switzerland, with its registered office at Baarerstrasse 10, 6300 Zug, Switzerland, along with our subsidiaries and global affiliates ("us," "we," or "our") collect, use, and share information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to https://franklyspeaking.academy/ ("Services"). Please read this Privacy Policy carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at evgeniy.nazarov.com@gmail.com. Your use of our Services is also governed by our Terms of Service. Terms used but not defined in this Privacy Policy can be found in our Terms of Service. If you reside or are located in the European Economic Area ("EEA") we are the data controller of all Personal Data collected via the Services and of certain Personal Data collected from third parties, as set out in this Privacy Policy.

We do not intend to create account for users who are under the age of 16 or statutory age of majority as required by the laws of the country of your domicile. Please do not use Services if you are under such age requirement.

BY ACCESSING OR USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND THAT YOU UNDERSTAND YOUR RIGHTS IN RELATION TO YOUR INFORMATION AND HOW WE WILL COLLECT, USE AND PROCESS IT. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY IN GENERAL OR ANY PART OF IT, YOU SHOULD NOT USE THE SERVICES.

HOW WE COLLECT YOUR INFORMATION
In order to provide Services, and improve the user experience and security of Services, we will collect, record, store, adapt, use, share or otherwise process your personal information, when you register an account and use Services.

We collect your personal information on the following grounds:
i. We need to process such information to deliver contractual services to you.
ii. You consent to provide us when you create an account and use Services.
iii. We collect when we believe it is for our legitimate interests in order to provide you better experiences with Services.

Information Needed for Contractual Services

We process the following personal information only as necessary to deliver contractual services as illustrated in the Terms to you:

• (when applicable) registration information, such as your name, sex, age, address, email, phone number, password, user identifier.

Information You Consent to Provide

You consent to provide some or all of the following personal information when you create an account on the Services or use Services:

• Your Global Positioning System (GPS) information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device.
• Your opt-in choices and correspondence with us, such as information used to verify your account or to resolve your feedback or complaints.
• Information you provide when participating in in-app surveys and activities.

Information We Collect for Legitimate Interests

We may collect some or all of the following Personal Information about you when you use Services for legitimate interests:

• Network activity information, such as your browsing history, search history, the pages you visited, the date and time of your visits, other users’ accounts that you subscribed, and information regarding your interaction with other users.
• Information about you from third-party service providers, such as advertising partners and data analytics providers.
• Device identifiers, such as your operating system, browser type, brand, model and serial number of your mobile device, Internet Protocol (IP) address.
• Mobile advertising identifiers, which are used by mobile operating systems and made available to advertising providers to gather metrics on mobile apps (Apple’s IDFA or Google’s AAID) to help us and advertisers provide ads that may be more relevant to your interests.
• Cookies, small pieces of data to enable us to provide certain features, which are collected by us or our business partners to measure and understand the web pages you click on and how you use Services, enhance your experience using Services, and provide you with targeted advertising on Services and elsewhere across your different devices.

We may also collect, use and share your information to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity.

HOW WE USE YOUR INFORMATION
We use the information we collect about you for the following purposes:

• to administer Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and to solicit your feedback;
• to personalize the contents that you receive and provide you with tailored content that will be of interest to you;
• to provide you with user support and to improve, develop Services and facilitate product development;
• to measure and understand the effectiveness of the advertising we serve to you and others;
• to enable us and our advertising partners to provide ads that may be more relevant to your interests;
• to help us detect abuse, fraud, and illegal activity on Services;
• to enforce our terms, conditions, and policies; and
• to comply with other applicable laws and regulations.

HOW WE SHARE YOUR INFORMATION
We may share your information with certain authorized third parties to assist in the improvement and optimization of Services, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes, including but not limited to:

• to third-party advertising partners so that they can deliver ads they believe are relevant to you in other third party apps;
• to cloud storage providers to store the information you provide;
• to analytics and search engine providers that assist us in the optimization and improvement of the user experience on Services;
• to any member, subsidiary, parent, or affiliate of our corporate group.

Except for the above, we will not disclose or share with any third party your personal information, unless under the following circumstances:

• if we obtained your consent, either implied or express;
• if we are required to do so in order to comply with the applicable laws and regulations and government requests;
• if we believe in our good faith that this is necessary to protect the public interest;
• if it is necessary to do so to protect the safety and fundamental rights of another person;
• if it is necessary to address fraud, security, or technical issues; and
• if it is necessary to ensure the enforcement of our terms and conditions and the daily operation of Services.

We may share your personal data with the third parties in the following cases:
(i) when personal data is shared with other our clients; You may share your data with other our clients by willingly disclosing information within the service. You by your own discretion choose information which you are willing to share within the service. We shall not be liable for any use of your personal data by any other our clients if such information has been shared by you within the service.
(ii) when personal data is transferred to third-party advertising partners; We utilize the third-party advertising partners (and such third-party partners’ policies on personal data are applicable to you, which please note).
(iii) when personal data is transferred to third-party cloud service providers (when applicable).
(iv) when personal data is shared in accordance with the laws and regulations.

YOUR RIGHTS
Pursuant to the applicable laws and regulations of the jurisdiction where you reside, you may have some or all of the following rights:

• access and update certain personal information that you have provided;
• change the mobile advertising identifiers in your mobile device or limit advertising tracking through your mobile device’s privacy settings; and
• rectify and delete your personal data retained on Services.

HOW WE TRANSFER YOUR INFORMATION
We may maintain servers around the world and your information collected by us will firstly be stored and processed in the country where we maintain data collection facilities. We have complied with relevant applicable data localization rules with respect to our data transfer practices. We take appropriate steps to ensure that the information we collected is processed in accordance with the privacy policy and the relevant applicable laws and regulations. If we provide any information about you to any legal agency, we will take appropriate measures to ensure such receiving institutes protect your information adequately in accordance with this privacy policy and the applicable laws.

SECURITY OF YOUR INFORMATION
We take appropriate administrative, technical and physical security measures to safeguard your personal information from unauthorized access and disclosure. Only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your personal information. You should use caution whenever submitting information through Services and take special care in deciding which information you provide us with. You are responsible for maintaining the secrecy of your password and account information at all times.

CHILDREN PROTECTION
Services are not directed to children, and if you are under the age of 16 or statutory age of majority as required by the laws of the country of your domicile, you may not use Services. We have zero tolerance to any form of child abuse or exploitation. Your data (including private messages) may be shared with legal agencies if we in our good faith believe that you have engaged in child abuse, or if we are requested to do so by relevant legal agencies.

MODIFICATIONS
We may amend any of the terms of the privacy policy by posting the terms. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using Services.

CONTACT INFORMATION
If you have any questions about this privacy policy or our information-handling practices, please contact us at evgeniy.nazarov.com@gmail.com.