Last Updated: 24.01.2020

Welcome to LangRoulette’s privacy policy. We at LangRoulette consider your privacy as a crucial point of our operations. We recommend you to read this privacy policy in full so you have a complete view of how we collect and use your data. 

Some of the highlights are:

  • We don’t transcript nor listen nor interpret your audio/video chat messages: We don’t transcript the content of your audio messages nor listen or interpret them unless there is a content denounce from the user you’re chatting with.
  • We don’t share your audio/video messages with third parties: We don’t share your audio/video messages with any third parties unless required by law.
  • Your audio/video messages are only temporarily stored in our servers: We keep metric information of your messages (size and timestamp) in our databases in order to analyze the general usage of our services and improve them. But the audio/video messages are only kept in our servers for a maximum period of 30 days and are used with the only purpose of being delivered to the person that you had intended to send them and for eventual denounce analyses.
  • You can download or permanently delete your personal data at any time: Under the “My Account” screen you can request all the information that we have about you and request to delete permanently your account and data.
  • We reserve the right to restrict access to LangRoulette in the event of misconduct: We take reports of abuse very seriously. Reports of misconduct on LangRoulette are reviewed by human moderators and can lead to a ban on our app. Please note that the only situation where LangRoulette might analyze your messages is on the eventual denounce of misconduct.

PRIVACY POLICY

This statement details how we handle personal data. We at LangRoulette enormous respect for your privacy. And take protecting it as very seriously.

Even being a super tiny team of two engineers :). We are firmly committed to meeting the European data protection standards for all our members whenever possible.

Please, take your time and read fully our privacy policy to understand how we handle and protect your data.

CONTACT

Tiago Batista Butzke
Rigaer Straße, 18A
10247 Berlin
Germany

You can also reach out to us directly on the email [email protected]

PERSONAL DATA

Personal data refers to any information about personal or factual circumstances of an identified or identifiable person. This includes information and details such as your name, age, gender, mobile device identifiers, telephone number and also your email address.

LEGAL BASIS

Your data is handled according to the following legal provisions:

  • With regard to data communicated in forms, etc. with your consent, Art. 6(1) (a) GDPR;
  • With regard to the services you use for the performance of a contract, Art. 6(1) (b) GDPR;
  • Otherwise, with particular regard to statistical data and online identifiers based on legitimate interests, Art 6(1)(f) GDPR (see below).
  • Legitimate Interests

When handling your data, we pursue the following legitimate interests:

  • Improving our service;
  • Protecting against misuse;
  • Statistics and service analytics.
  • Data Sources

Unless otherwise specified, we obtain the data from you (including via devices used by you).

DATA TRANSFER TO THIRD COUNTRIES

LangRoulette is a worldwide service. Data is transferred to third countries outside your home country and outside the European Union. This is done on the basis of contractual regulations stipulated by law that ensure appropriate protection of your data and that are available for you to view on request.

RETENTION PERIOD

We only retain your data when:

  • In case you consent to this as part of processing, until such time as you withdraw your consent (e.g. by deleting your account);
  • If we need the data to fulfill an agreement, until such time as the contractual relationship with you ceases or legal retention periods expire;
  • If we use the data on the basis of legitimate interest, until such time as your overriding interest obliges us to delete or anonymize them.

PURPOSE OF USE

Your personal data will only be collected by us to the extent and for the purpose for which you provide the data to us, e.g. for registering an account.

We use and store your personal data as part of our services for the following purposes and only if you have provided us with your express consent:

  • To create a public user profile for you at LangRoulette;
  • To provide a curated community just for language learners, where access is restricted to members only. We take best efforts to prevent abuse and ban offenders, as soon as we are made aware;
  • To send information relevant to the service, e.g. via email or push notification (e.g. updates on your membership status, missed calls/messages, new followers);
  • To find partners nearby;
  • To understand how LangRoulette is used and optimize the service

Otherwise, your personal information will not be forwarded to third parties unless you have given your express consent for this or unless we are obliged to disclose it – for example, at the direction of a court or administrative authority.

We forward the following customer data to third parties:

  • To Analyse how LangRoulette is used by our members and optimize the service and design, anonymous usage and personal data are shared with Google Analytics, Firebase Analytics, and New Relic.
  • To communicate information relevant to the service via email or push notification, names, device IDs, email addresses and other personal information may be shared with ElasticEmail (elasticemail.com).
  • We create LangRoulette member profiles based on your login data and also use these profiles and the information they contain, provided by you, for the following purposes:
    • We create a public member profile for you on LangRoulette so that members can find the most relevant language exchange partners to communicate with. While some elements of your profile, including your name, age, profile picture, language settings, profile answers, current country, time zone, and topics are public, only community members can contact you via the LangRoulette app. We never show your email address, exact location or any information you have chosen not to share in your profile settings to other members.
    • We use your language settings for matching your profile with possible language exchange partners that are also registered in the app.
    • In order to keep LangRoulette a safe place for language learners, we take violations of our community rules very seriously. Therefore, we retain anonymous personal identities of banned users for 18 months and might prevent access to the community on this basis during this period.

You can edit, hide and delete personal data in the My Account settings within the LangRoulette app. Also, you can request the deletion of your account or ask for certain profile information to be changed via LangRoulettes’s customer support ([email protected]).

DATA PROTECTION

We have taken extensive technical and organizational measures to secure your data against potential risks, such as unauthorized login or access, unauthorized perusal, amendment or distribution, and against loss, deletion or misuse.

In order to protect your personal data against unauthorized access by third parties when being transmitted, we secure data transmissions, if necessary, using SSL and TLS encryption. This is a standard encryption procedure for online and mobile services, particularly for the Internet. Encryption is not supported in China.

Regarding video and audio chats: we will not monitor, record or broadcast video and audio chat sessions at any time. However, we cannot prevent your chat partners from broadcasting live or recorded chat sessions without your or our permission through third-party websites or services. We recommend that you exercise caution in disclosing any information, personal or otherwise, during a video or chat session.

OUR POLICY ON CHILDREN’S INFORMATION

Children under 14 are not allowed to use LangRoulette. If you are based in the European Economic Area (EEA), you may only use LangRoulette if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of LangRoulette has been provided to us. If you are a parent and you learn that your child is using LangRoulette and you don’t want them to, please contact [email protected]m.

COOKIES

Cookies are small files that your browser stores on your device in a directory designated specifically for this purpose. These cookies can be used for example to find out whether you have already visited a website. Most browsers accept cookies automatically. Nevertheless, you can change the settings in your browser, so that no cookies are stored or so that your explicit agreement is required before any cookies are stored. You can also delete previously set cookies at any time. Please note that disabling cookies may result in your use of our website being restricted.

We need cookies to (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content, and information; (c) to provide and monitor the effectiveness of our Service; (d) to monitor and aggregate metrics such as the total number of visitors, traffic, and demographic patterns; (e) to diagnose or fix technology problems; (f) to help you efficiently access your information after you sign in; (g) to provide advertising, which may be tailored to your interests, and (h) to keep the LangRoulette community safe for members.

REGISTRATION AND AUTHENTICATION

By registering or authenticating, Users allow LangRoulette to identify them securely and give them access to its services. Depending on what is described below, third parties may provide registration and authentication services. In this case, LangRoulette will be able to access some data stored by these third-party services for registration or identification purposes, with the user’s explicit consent:

  • Facebook Authentication (Facebook, Inc.): Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network. The personal data collected are various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.
  • Firebase Authentication (Google Inc.): Firebase Authentication is a registration and authentication service provided by Google Inc. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save information on its platform. Personal Data collected: phone number. Place of processing: United States – Privacy Policy. Privacy Shield participant.
  • Google OAuth (Google Inc.): Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network. Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.

This type of service has the purpose of hosting data and files that enable LangRoulette to run and be distributed, as well as providing a ready-made infrastructure to run specific features or parts of LangRoulette. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where personal data is stored.

  • Digital Ocean (Digital Ocean, LLC.): Digital Ocean is a hosting and backend service provided by Digital Ocean, LLC. Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.
  • Google Cloud Platform (Google Inc.): Google Cloud Platform is a hosting and backend service provided by Google Inc. Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.

INFRASTRUCTURE MONITORING

This type of service allows LangRoulette to monitor the use and behavior of its service components, so its features, performance, operation, maintenance, and troubleshooting can be improved. Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of LangRoulette.

  • Crashlytics (Google Inc.): Crashlytics is a monitoring service provided by Google Inc. to enable LangRoulette to improve the stability of the app and reduce app crashes. Personal Data collected: geographic position, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.
  • Firebase Crash Reporting (Google Inc.): Firebase Crash Reporting is a monitoring service provided by Google, Inc. to improve the stability of the app and reduce app crashes. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.
  • Firebase Performance Monitoring (Google Inc.): Firebase Performance Monitoring is a monitoring service provided by Google, Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.
  • New Relic (New Relic Inc.): New Relic is a monitoring service provided by New Relic Inc. The way New Relic has integrated means that it filters all traffic of LangRoulette, i.e., communication between the Application and the User’s browser or device, while also allowing analytical data on LangRoulette to be collected. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.

MANAGING CONTACT AND SENDING MESSAGES

This type of service makes it possible to communicate with users outside of the app, e.g. via push notifications and email. They may manage a database of email contacts, phone contacts or any other contact information to communicate with the user. These services may also collect data concerning the date and time when the message was viewed by the user, as well as when the user interacted with it, such as by clicking on links included in the message.

  • Firebase Cloud Messaging (Google Inc.): Firebase Cloud Messaging is a message sending service provided by Google, Inc. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.
  • ElasticEmail (Elastic Email, Inc.): ElasticEmail is an email message sending service provided by Elastic Email, Inc. ElasticEmail allows LangRoulette to send email messages to Users. The data collected may be used by the service provider for interest-based advertising, analytics, and market research. In order to understand LangRoulette’s use of data, consult LangRoulette’s privacy policy. Personal Data collected: Cookies, email address, geographic position, language, usage data and various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy – opt out.

WEB AND MOBILE ANALYTICS

The services contained in this section enable us to monitor and analyze web and mobile traffic and can be used to keep track of how LangRoulette is used by users.

  • Analytics collected directly (LangRoulette): LangRoulette uses an internal analytics system that does not involve third parties. Personal Data collected: Cookies and usage data.
  • Google Analytics (Google Inc.): Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of LangRoulette, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage data. Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.
  • Google Analytics for Firebase (Google Inc.): Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Inc. In order to understand Google’s use of data, consult Google’s partner policy. Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The user may check this privacy policy to find a detailed explanation about the other tools used by the owner. LangRoulette uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Firebase Analytics service. Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and usage data. Place of processing: United States – Privacy Policy. Privacy Shield participant.
  • Facebook Ads conversion tracking (Facebook, Inc.): Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on LangRoulette. Personal Data collected: Cookies and Usage data. Place of processing: United States – Privacy Policy. Privacy Shield participant.

DATE OF ISSUE OF THIS DATA PRIVACY STATEMENT

24.01.2020

We reserve the right to make amendments at any time to this data privacy statement for future effects.