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Privacy Policy

Last Updated: November 30, 2021
Innovative Language Learning USA, LLC (“us”, “we”, or “our”) operates https://www.dngtour.com and related sites (the “Sites”). This Privacy Policy explains how we collect, use, and disclose the information we collect on our Site and through our mobile applications (the “Apps”), and through the services offered via the Sites and Apps (collectively the “Services”). We will not use or share your information with anyone except as described in this Privacy Policy. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use. The use of information collected through our Sites shall be limited to the purposes under this Privacy Policy and our Terms of Service. By visiting our Site or using any of our Apps or Services, you agree that any information that we collect from or about you through our Services may be handled as described in this Privacy Policy.
1. Information We Collect
We may collect personally identifiable information about you that you provide to us when you use our Services such as your name, age, and email address (“Personal Information”). We may collect Personal Information directly from you, from third parties, and automatically through your use of our Services. We may combine information collected from or about you from these various sources.

When you create an account with us, a verification email will be sent to the e-mail address you used for registration to prove that you are the owner of the email address. You can also create an account with us by logging in through certain third-party accounts, such as Facebook. By logging in through a third-party account, you grant us permission to access certain information from that third-party account as explained on the permissions page when you log in.

We may also automatically collect information about users of our Services through cookies (see Section 2 for more information), web beacons, and other technologies. Some or all of this information may be collected by third-party software providers (as listed in Section 3) and some or all of this information may be collected by us and transferred to such third-party providers for further analysis. The collected information may include, but is not limited to, IP address and domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on our Services; and the referring URL, or the webpage that led a user to our Services. In addition, we may collect information about user activities within our Services, such as a user's learning progress, lessons accessed and completed, and download history.

If you choose to purchase a product from us, you agree that our third-party payment processors (PayPal and Authorize.Net) will collect your payment information. If you pay with a credit card on our site, your payment data, full name, email, country, postal code, IP address, and other information as required for processing your payment by Authorize.net, our third-party credit card payment processor, will be securely transmitted to Authorize.Net upon checkout. The transmission of the data to Authroize.Net is aimed at payment processing and fraud prevention in order for the third-party payment processor to conduct identity and creditworthiness checks. The third-party payment processors will, if necessary, pass on your submitted information to their affiliates and service providers to the extent necessary to fulfill their contractual obligations or for data to be processed in the order. We do not store or process your credit card number on our servers. The applicable data protection provisions of each of these third-party processors may be found on their websites (https://www.authorize.net/about-us/privacy/ and https://www.paypal.com/us/webapps/mpp/ua/privacy-full).

We also may ask you to provide additional information about yourself, including your age, hobbies, and interests in learning languages. You can choose not to provide this additional information to us. We also reserve the right to record, read, copy, disclose, and use (but not transmit to any third party) any text, speech, data, images, and other materials you transmit to us via non-public means for improving our Services. When you provide Personal Information through our Site, the information will be sent securely to servers located in the United States.

As a service to our users, we feature Blogs and Lesson Comments as well as Forum Posts for users to interact with each other and with us. Information shared in Blogs and Lesson Comment and through Forum Posts is accessible to the general public and may be viewed, disclosed to, or collected by third parties that do not adhere to our Terms or this Privacy Policy or that may use the information to send you unsolicited communications. In addition, we may retain this information as necessary to resolve disputes, provide customer support, and troubleshoot problems as permitted by law. You should think carefully before disclosing any personal information in any public forum.

Please note: our Services do not respond to Do Not Track signals. For more information about Do Not Track signals, please click here.

2. Cookies
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can take the form of session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our website. A persistent cookie remains on your hard drive for a specified period of time.

We use cookies on our Sites to provide you with a better user experience by tracking your use of our Site, the links you click, and the searches you conduct on our Site. You may, at any time, delete or decline cookies by changing your browser settings but keep in mind that some of our Services may not function properly with such settings.

3. Third Party Tracking
We use third-party online business optimization software (including Google Analytics, Google AdWords, Google Tag Manager, Google Optimize, Bing AdWords, FullStory, Lucky Orange, and Facebook Pixel) to assist us in the capture and analysis of customer usage information (the collection of which is listed in Section 1). We may also use third-party marketing software (including Campaigner) to send out email communications and promotional newsletters and further assist us in the capture and analysis of our marketing efforts. These service providers act as limited agents to us, for the purpose of providing their services. Any information obtained by such third parties from our users or us is and will remain our property, and will be subject to this Privacy Policy. To learn more about the privacy practices of such service providers, we encourage you to review the privacy policy of these third-party providers as listed on their websites.

4. Use of Your Information
We use your information, including Personal Information, as follows:

Deliver the services and products that you have requested;
Processing orders and payments;
Communicate with you about your use of our Services, including to send you Service/product updates;
Manage your account and provide you with customer support;
Enforce our terms and conditions;
Comply with applicable legal or regulatory obligations;
Analyze how users interact with our Services;
Detect security incidents and protect against malicious or illegal activities;
Debug to identify and repair errors that impair existing functionality;
Manage our business; and
Perform functions as otherwise described to you at the time of collection.


5. Disclosure of Your Information
As a matter of policy, we do not sell or disclose any Personal Information about you to any third party except to provide you with products or services you have requested, when we have your permission, or under the circumstances listed below:

With other users of our Services in order to provide our Services (but not your email address or password);
To our teachers in order to provide Services you have requested;
To nonaffiliated companies that we engage as contractors or agents to perform services for us, such as administering our Site, systems, and software; sending direct mail communications; or administering events, in which case we will disclose your information with such contractors only to the extent reasonably necessary for them to perform services on our behalf, consistent with this Privacy Policy;
In response to subpoenas, court orders, or legal process, from law enforcement agencies or state and federal regulators, or as otherwise required by law;
To assert or defend our legal rights, including fraud prevention and enforcing this Privacy Policy and our Terms of Use;
To protect the rights, property, or safety of us or other persons, including to detect, prevent, or otherwise address fraud, security, or technical issues, or anything else that we may consider to be, or pose a risk of being, an illegal, unethical, or legally actionable activity;
As we deem appropriate to attempt to prevent physical or emotional harm to other persons and/or to their property based on overt or implied threat; and
In connection with an actual or proposed corporate merger, acquisition, asset purchase, or other transaction or proceeding involving all or part of the business or assets to which the information pertains.
We may also disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

6. Period of Retention of Personal Information
We shall process and store your Personal Data only for the period necessary to achieve the purpose of storage, or as far as permitted by the applicable law.

7. Accessing, Reviewing and Changing Your Profile
You can access, review, and change any of your personal profile information at any time from the Account Info section of the My Account page.

8. User’s Rights to Personal Information
You have the following rights to your Personal Information:

Right to be informed of how we are using your Personal Information;
Right of access to know which of your Personal Information is held and processed by us;
Right of having any of your inaccurate or incomplete Personal Information rectified;
Right to erasure at any time for any reason (or for no reason);
Right to restrict a certain type of processing of your Personal Information;
Right to retain and reuse your Personal Information for other purposes;
Right to object to how your Personal Information is used; and
Right to limit the use of your Personal Information by automated decision making and profiling.


Upon your notification, we will comply with your request as reasonably possible in accordance with our policy and applicable law. However, in some incidents, we may only comply by terminating your membership or otherwise restricting your access to our Site. Please note that we can only honor requests to opt out of disclosures on a going-forward basis and opt-out requests do not affect information that we have previously disclosed. We may also retain certain information about you as required by law or as permitted by law for legitimate business purposes.

9. Your Use of other Members’ Information
Through regular use of our Site, as a member you may have access to another member’s contact or Personal Information. By registering for our Site and accepting this Privacy Policy, you agree that you shall not disclose another member’s Personal Information to any third party in any situation unless: 1) the terms of this Privacy Policy permit disclosure; 2) you have obtained permission from the other member; 3) you have obtained our permission; or 4) such disclosure is required by law; and in each case only to the extent permitted and/or as necessary.

10. Security
To safeguard the confidentiality of your Personal Information, we utilize sophisticated security techniques and procedures, including: daily security and vulnerability scans, software audits, firewalls, and data encryption (Secure Socket Layers). We make every effort to protect that data against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by others. We strive to comply with the GDPR as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. We certify that we adhere to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement. Despite our efforts, no data security measures can guarantee 100% security. In the event that Personal Information is compromised as breach of security, we will promptly notify you in compliance with applicable law.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a strong password that cannot be easily guessed, and keeping your login name and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

11. Note about Children

12. Modifications to Privacy Policy
The Privacy Policy is subject to change by us at any time based on changes in the law or our need to accurately reflect our data collection and disclosure practices. Changes are effective upon posting on the website.

13. Contact Us
Innovative Language Learning USA, LLC operates the Site and Services.

14. Notice to California Consumers
If you reside in California, we are required to provide additional information to you about how we use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this California-specific information below.

CA Personal Information. Consistent with Section 1 of this Privacy Policy, we collect certain categories and specific pieces of information about individuals that are considered "Personal Information" in California ("CA Personal Information"), specifically:

Personal and Other Identifiers or Characteristics: such as first name and last name, personal or professional contact information, mailing address, telephone number, e-mail address, unique personal identifier, IP, device, and online activity information, age, date of birth, gender, demographics, username and password to our Websites or services.
Commercial Information: such as payment details, credit card information and purchase or transaction history.
Sources. We may collect certain categories of CA Personal Information from you and other third parties as described in Sections 1, 2 and 3 of this Privacy Policy.
Use or Disclosure of CA Personal Information. Consistent with Sections 3, 4 and 5 of this Privacy Policy, we may use and/or disclose CA Personal Information for business or commercial purposes.
California Consumer Rights. Subject to certain exceptions, as a California resident, you may have the following rights to your CA Personal Information:

Access. Request access to your CA Personal Information that we collect, use, disclose, or sell;
Deletion. Request deletion of your CA Personal Information; and
CA Personal Information Sold or Disclosed For Business Purposes. Request information about the CA Personal Information we have disclosed for business purposes within the preceding 12 months. To the extent permitted by applicable law, we may be required to retain some of your CA Personal Information and certain CA Personal Information is strictly necessary in order for us to fulfill the purposes described in this Privacy Policy.
Exercising California Consumer Rights. If you are a California resident and wish to exercise any of these rights, you may make a request about your CA Personal Information twice per 12-month period and we shall respond within forty (45) days:
(q) log into your account to make any updates or submit a request;
(c) contact us as described in the Privacy Policy Section 13 above, or


When submitting your request, you may be asked to provide certain information, which may include additional proof of identification, so that we can verify your identity and validate the request. We are not responsible for requests that are not sent or submitted properly, or that do not have complete information. Please note that you are limited by law in the number of requests you may submit per year. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon you exercising your rights to your CA Personal Information.
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Privacy Policy Guide

개인정보처리방침안내
purpose	item	Retention period
User identification and identity verification	ID, name, password	Until membership withdrawal
Notice regarding the use of customer service; User identification for CS response	Contact (e-mail, mobile phone number)	Until membership withdrawal
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