Privacy Policy

The information FiliLearn collects depends on how a person uses the platform.

We may use personal information to:

• Provide FiliLearn services
• Create and maintain accounts
• Authenticate users
• Deliver lessons and learning activities
• Personalize learning experiences
• Track learning progress
• Provide pronunciation feedback
• Process subscriptions and payments
• Schedule Live Classes
• Enable Teacher and Learner communications
• Operate classroom functionality
• Maintain classroom recordings where applicable
• Maintain classroom chat and session records
• Verify attendance
• Investigate technical issues
• Prevent fraud and abuse
• Protect Learners and Teachers
• Maintain platform security
• Provide customer support
• Administer Teacher applications
• Verify Teacher identity
• Manage Teacher payments
• Perform quality assurance
• Investigate complaints
• Resolve disputes
• Maintain audit logs
• Comply with legal obligations
• Enforce FiliLearn policies and agreements
• Improve our products and educational content
• Develop new FiliLearn features
• Send service related communications
• Send marketing communications where the recipient has provided appropriate consent or where otherwise legally permitted

FiliLearn does not sell personal information in exchange for money.

We do not sell classroom recordings.

We do not sell classroom chats.

We do not sell pronunciation recordings.

We do not sell Teacher identification documents.

We do not sell children's personal information.

We do not use classroom recordings for behavioral advertising.

If FiliLearn's practices change in a way that constitutes a sale or sharing of personal information under applicable privacy law, we will update our disclosures and provide any legally required choices before implementing those practices.

FiliLearn may send information about:

• New lessons
• New FiliLearn Original stories
• Platform features
• Educational content
• Promotions
• Special offers
• Product announcements
• Learning tips

Users may control marketing preferences through available account settings or unsubscribe mechanisms.

Marketing consent is separate from communications necessary to operate a FiliLearn account.

For example, unsubscribing from promotional email may not prevent communications concerning:

• Account security
• Password resets
• Payment receipts
• Subscription status
• Class bookings
• Class changes
• Class cancellations
• Safety issues
• Legal notices
• Other essential service communications

We do not knowingly use personal information of children under 13 for targeted behavioral advertising.

Protecting younger Learners is particularly important to FiliLearn.

The Children's Online Privacy Protection Act applies to covered online services involving children under 13 in the United States.

Where FiliLearn knowingly permits a child under 13 to create or use an account that involves collection of personal information, FiliLearn will implement parental or guardian consent procedures as required by applicable law.

Depending on the account and jurisdiction, FiliLearn may require a parent or guardian to:

• Create or authorize the child's account
• Provide consent
• Review privacy disclosures
• Approve applicable data collection
• Review information associated with the child
• Request deletion where legally available
• Manage certain privacy preferences

Children should not provide more personal information than reasonably necessary to participate in FiliLearn.

Where parental consent is required, FiliLearn may limit access to affected features until appropriate consent has been obtained.

The FTC's updated COPPA framework also places heightened restrictions on disclosures and advertising uses involving children's information.

FiliLearn does not condition a child's participation in an educational activity on providing more personal information than is reasonably necessary for that activity.

Parents or guardians with questions about a child's FiliLearn information may contact us at legal@heybuddysolutions.com.

If a minor participates in a Live Class, additional protections may apply.

FiliLearn may provide notice that the session is recorded.

Where consent is required, FiliLearn will seek the appropriate consent before recording or processing information.

Recordings involving minors will not be made publicly accessible by FiliLearn.

Access will be restricted according to FiliLearn authorization controls.

FiliLearn may preserve recordings where reasonably necessary to investigate safety incidents, legal claims, abuse reports, disputes, or policy violations.

FiliLearn may monitor or review activity when reasonably necessary to:

• Protect Learners
• Protect Teachers
• Investigate complaints
• Detect inappropriate conduct
• Investigate unauthorized contact
• Review reported classroom behavior
• Investigate account abuse
• Verify compliance with platform rules
• Maintain educational quality

Such review does not mean FiliLearn continuously watches every user or every class in real time.

FiliLearn may disclose information to service providers that perform services on our behalf.

These providers may support:

• Cloud infrastructure
• Database hosting
• Authentication
• Video communications
• Classroom recording
• Payment processing
• Email
• Push notifications
• Audio generation
• Pronunciation technology
• Analytics
• Security
• Customer support
• Error monitoring
• Data storage

Service providers are permitted to process information for authorized business purposes and are expected to protect information consistent with applicable requirements.

We may also disclose information when reasonably necessary to:

• Comply with law
• Respond to lawful requests
• Protect the rights and safety of FiliLearn
• Protect Learners or Teachers
• Investigate suspected fraud
• Investigate abuse
• Enforce our agreements
• Respond to emergencies
• Establish or defend legal claims
• Complete a corporate transaction such as a merger, acquisition, financing, restructuring, or sale of assets, subject to applicable law

FiliLearn may integrate with third party services.

Depending on the features you use, these may include providers for:

• Payments
• Video conferencing
• Cloud services
• Authentication
• Artificial intelligence enabled voice technology
• Email communications
• Mobile platforms
• Analytics

These companies may process information according to their own privacy policies and contractual obligations.

FiliLearn seeks to provide third parties only the information reasonably necessary for the service they provide.

Certain FiliLearn functionality may use automated technology or artificial intelligence to support educational experiences.

Examples may include:

• Audio generation
• Pronunciation assessment
• Learning recommendations
• Content assistance
• Automated quality checks

Automated systems should not be treated as infallible.

Where automated technology affects educational feedback, FiliLearn may review and improve those systems over time.

We do not permit third party artificial intelligence providers to independently use FiliLearn user information for unrelated purposes where FiliLearn has contractually restricted such use.

FiliLearn retains personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

• Providing services
• Maintaining account history
• Security
• Fraud prevention
• Legal compliance
• Dispute resolution
• Financial record keeping
• Quality assurance
• Safety investigations
• Contractual requirements

Different categories of information may have different retention periods.

Classroom recordings may be subject to a separate retention period established by FiliLearn.

Classroom chat, session logs, administrative records, and recordings may be retained longer if a session has been placed on administrative or legal hold.

When information is no longer reasonably required, FiliLearn may delete, deidentify, aggregate, or securely dispose of it, subject to applicable legal requirements.

Users may request account deletion using available account functionality or by contacting FiliLearn.

Deleting an account does not necessarily require immediate deletion of every record associated with the account.

Certain information may be retained where reasonably necessary for:

• Legal obligations
• Financial records
• Fraud prevention
• Security
• Dispute resolution
• Contract enforcement
• Safety investigations
• Protection of other users
• Establishment or defense of legal claims

Where information must be retained, access may be restricted and the information will not be used for unrelated purposes.

FiliLearn uses reasonable administrative, technical, and organizational safeguards designed to protect personal information.

These measures may include:

• Access controls
• Role based permissions
• Authentication controls
• Encryption where appropriate
• Secure communications
• Audit logging
• Database security controls
• Restricted administrative access
• Secure credential handling
• Monitoring for unauthorized activity

No online service can guarantee absolute security.

Users are responsible for maintaining the confidentiality of their account credentials and should notify FiliLearn promptly if they suspect unauthorized access.

Classroom recordings are treated as restricted information.

FiliLearn intends to limit recording access to authorized Admin and Super Admin personnel with a legitimate operational reason.

Recording access may be logged.

Teachers and Learners should not be able to obtain internal recording files by manipulating URLs, APIs, Session IDs, or application interfaces.

Knowing a Session ID does not provide authorization to access a recording.

Teacher identity and verification documents require heightened protection.

FiliLearn restricts access to personnel who reasonably need access for verification, compliance, safety, or administration.

Teacher identification documents are not available to Learners.

They are not used for general advertising.

They are not sold.

FiliLearn's website may use cookies, local storage, SDKs, or similar technologies for purposes such as:

• Authentication
• Session management
• Security
• Remembering preferences
• Platform functionality
• Analytics
• Performance
• Fraud prevention

Where required by applicable law, FiliLearn may provide additional consent controls for nonessential technologies.

FiliLearn mobile applications may send push notifications relating to:

• Classes
• Messages
• Learning reminders
• Account activity
• Announcements
• Progress
• Bookings
• Schedule changes
• Other FiliLearn activity

Users can generally control push notification permissions through device settings and available FiliLearn preferences.

Marketing related notification practices may be subject to additional consent requirements.

California residents may have privacy rights under the California Consumer Privacy Act and related California law where those laws apply to FiliLearn.

Depending on eligibility and applicable law, those rights may include the right to request:

• Information about personal information collected
• Access to personal information
• Correction of inaccurate information
• Deletion of personal information
• Information about categories of information disclosed
• Opt out of qualifying sale or sharing
• Limit certain uses of sensitive personal information where applicable
• Non discrimination for exercising privacy rights

The California Privacy Protection Agency provides additional information concerning these rights.

FiliLearn will verify privacy requests as reasonably necessary to protect account information from unauthorized disclosure or deletion.

Authorized agents may submit requests where permitted by applicable law and subject to verification requirements.

Certain information FiliLearn processes may qualify as sensitive personal information under applicable law.

Examples may include:

• Account credentials
• Precise identification information
• Government identification documents provided by Teachers
• Certain financial information
• Communications
• Information concerning minors

FiliLearn uses sensitive information only for reasonably necessary and disclosed purposes.

Users located outside the United States may have additional rights under applicable privacy law.

Where the General Data Protection Regulation applies, processing may rely on legal grounds including:

• Performance of a contract
• Consent
• Compliance with legal obligations
• Legitimate interests
• Protection of vital interests where appropriate

Users may have rights relating to access, correction, deletion, restriction, portability, objection, and withdrawal of consent, subject to applicable conditions.

Under European rules, parental authorization requirements for children's online consent can vary by country, generally within the age range established under GDPR.

Personal information may be processed in countries other than the country where a user resides.

Where legally required, FiliLearn will use appropriate mechanisms for international transfers of personal information.

Depending on your account and jurisdiction, you may be able to:

• Update profile information
• Update communication preferences
• Disable marketing email
• Disable certain notifications
• Request access to information
• Request correction
• Request deletion
• Request information regarding privacy practices
• Withdraw consent where processing relies on consent

Parents or guardians may have additional choices regarding information associated with younger Learners.

Browser based privacy preference technologies continue to evolve.

Where applicable law requires FiliLearn to recognize a legally valid browser or device based opt out preference signal, FiliLearn will process the signal as required.

FiliLearn may create aggregated or deidentified information that does not reasonably identify an individual.

We may use such information for:

• Educational research
• Product improvement
• Analytics
• Performance measurement
• Curriculum development
• Business planning

Where information is maintained as deidentified information, FiliLearn will not intentionally attempt to reidentify it except as permitted by law.

FiliLearn may preserve or disclose information when we reasonably believe doing so is necessary to:

• Comply with legal process
• Respond to lawful government requests
• Investigate abuse
• Protect a child
• Protect a Teacher
• Prevent serious harm
• Protect FiliLearn systems
• Investigate fraud
• Enforce agreements
• Protect legal rights

Nothing in this Privacy Policy is intended to prevent FiliLearn from taking reasonable measures to protect users or comply with law.

If FiliLearn or HeyBuddy Enterprises LLC participates in a merger, acquisition, financing, restructuring, bankruptcy, asset sale, or similar transaction, information may be transferred as part of that transaction.

Any recipient will remain subject to applicable privacy obligations concerning transferred personal information.

FiliLearn may update this Privacy Policy as the service evolves.

When material changes occur, we may provide notice through:

• The FiliLearn platform
• Email
• App notification
• Website notice
• Another legally appropriate method

The Effective Date at the top of this policy will indicate when the latest version became effective.

Where applicable law requires consent to a material change, FiliLearn will request that consent.