NEELE APP – Privacy Notice
Thank you for using NEELE App, a UABIT App! This Service is a mobile application brought to you by N SOLUCOES TECNOLOGICAS LTDA, a limited liability company incorporated in Brazil.
We wrote this Privacy Notice to help you understand what information we collect, how we use it, and what choices you have. We’ve tried our best to explain things in a simple and clear way. For capitalized terms not defined in this Policy, please refer to our Terms of Service for their respective definitions.
We welcome your questions and comments on this policy.
1. Identity and the contact details of the controller
NEELE APP is a language-learning platform designed to provide fluency through practical activities and everyday situations.
When we say “NEELE,” “our,” “we,” or “us,” we’re talking about UABIT. This Privacy Notice (“Privacy Notice”) applies specifically to NEELE APP.
The personal data related to the use of NEELE mobile application are controlled by UABIT (N SOLUCOES TECNOLOGICAS.). If you have questions about our Privacy Policy, please contact us:
N SOLUCOES TECNOLOGICAS LTDA
AV JACARANDA LOTE 18
AGUAS CLARAS, BRASILIA, DF BRAZIL 71936-250
Email: [email protected]
2. Personal Data Processing
2.1. Information we collect about you
NEELE APP does not collect personal information indirectly from you, and the only information it collects is that which is required in the process of enabling use, as well as that is related to the usage of NEELE APP, as they are indispensable for the performance of the contract held between us, as detailed below:
To access and use the application’s features, you do not need to provide any personal data to us. There is no registration required to use the platform and all of its features are available as soon as the user downloads the app.
When you use the application’s features, your text and audio files are not transmitted to us or our servers, they are stored in your own device or are immediately discarded. Your progress data is stored in your own device’s cloud storage, if applicable. In this case, we may just collect information about your performance on NEELE APP activities, as correct and wrong answers, to better understand how the spelling is being corrected by our systems. However, we can’t relate this information to you in any way and they are used just to provide more accurate services, for example to make changes in our system settings to better understand our users' accent.
When you subscribe to become a Premium member, we still don’t collect your personal data. The subscription process is held by third parties, especially your own device’s application store, who just send us a token to confirm the validity of the financial transaction.
However, we may collect and process your personal data when you contact us through our e-mail addresses. These activities are carried out to answer your requests and provide the information required by you, and this data may be used to get in touch with you later, for example to communicate with you, send you updates, newsletters, marketing materials and other information that may be of your interest. You can decide to stop getting these updates by contacting us. Despite that, when you use our form to provide improvement suggestions, we do not collect any personal data.
NEELE APP may also store some information locally on your device. For example, we may store information as local cache so that you can open the app and view the content faster. However, we can’t access this information, so it can't be processed by us.
2.2. Information third parties may collect about you
To use our voice application features, you have to give us access to your microphone. As stated before, we don’t collect any data nor receive the audio files.
However, to be able to correct your speech pronunciation, you have to authorize the use of your device’s speech recognition technology, which may involve the collection of personal data by your device’s manufacturer, as Apple or Google, for example. In this case, we recommend you to consult your device’s manufacturer about their privacy and data protection policies and practices, as this data may be used by the third parties for its own purposes.
Besides that, NEELE APP has some connections with other services, our partners, specially related to analytics and advertising, like Facebook (Ads, Analytics, Lookalike, Retarget), Google (Firebase, Ad Mob, Ads), Flurry (Analytics) and AppsFlyer (Ads). These activities are based on our legitimate interest and in our partners legitimate interest, as this data is important to support and enhance the services provided to you. To better understand how third parties process personal data, we recommend you to visit their privacy policies, as shown below:
NEELE APP may present to you links to access websites and / or other third party applications, with their own content and privacy policy. It is highly recommended that you check the rules of such policies.
It is important to notice that your mobile device may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID), which may help you to control the processing of your information.
2.3. Other information collected by NEELE
NEELE APP can collect information about your device, including the hardware model, operating system and version of the device, as well as unique device identifiers (including MAC and IMEI address), browser type, language, operator and Internet Protocol identification address (IP Address) or any other means of identifying the connection with the ISP.
In case of problematic usability events, we also collect some information from the devices in order to help diagnose any problems during the usability of the services and resources of the application. So, for example, for troubleshooting purposes, if a problematic event is detected, the list of applications on your device and other information about the device's performance at the time of the event will be collected.
This information is collected, based on our legitimate interest, to always provide a better service to you, using this information to promote technical improvements in our application, as well to guarantee that the contract between us is executed properly, for example when this data is processed to troubleshoot purposes.
3. How we share your information
NEELE shares your personal data only when it is necessary to offer the Service, legally required, or permitted by you, as better explained below:
If you want to, you may share information with third party social media:
In some cases, we may share your information with third parties:
In some cases, we may share your data with third parties for legal reasons:
4. How long we keep your content:
We will retain your data and information as long as needed to provide you the Service as well until needed to the performance of the contract held between us.
Please be aware that we will not be able to delete any content you have shared with others or with social media sites, which only you can do directly in your social media provider. You should understand that users who see the content you provide can always save it using any number of techniques: screenshots, in-app functionality, or any other image-capture or audio recording technology. It’s also possible, as with any digital information, that someone might be able to access messages forensically or find them in a device’s temporary storage.
5. Your rights as a personal data subject
Our goal is to give you simple and meaningful choices over your information. You have the rights to:
6. Security
We take reasonable precaution to protect personal information from misuse, loss and unauthorized access. Although we cannot guarantee that personal data will not be subject to unauthorized access, we have physical, electronic and procedural safeguards in place to protect personal information, as well as our partners and service providers. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. If UABIT identifies a security breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. UABIT may also post a notice on the UABIT website or through a NEELE APP message if a security breach occurs.
7. Children
Our Service is not intended for – and we do not direct them to – anyone under 13 years old, so we do not knowingly collect personal information from anyone under 13. If you find that your minor child has provided us with personal information without your consent, please contact us at [email protected].
8. Changes to this Privacy Policy
We will occasionally update this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our Service, or advances in technology. When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy, which will be posted on the Services under Settings and you should regularly check for the most recent version, which is the version that applies. Please review the changes carefully. Your continued use of the Services following the posting of changes to this policy will mean you accept those changes. If you do not agree to such changes, you may stop using NEELE APP.
Last Update: January 1st, 2021