Privacy Policy

Last modified 12.07.2021

1. The Basics

About this Privacy Policy

Sponge Labs LLC (Konju) is committed to protecting the privacy and security of our users, and to be transparent about how we process information about you. This Privacy Policy describes how we process your Personal Information and how you can exercise your privacy rights.

About us

Konju is an educational technology and software-as-a-service company providing a language learning platform for the global educational technology market. Our focus is on being the absolute best place to learn and practice Korean verb conjugations. We focus on combining beautifully designed quizzes to provide short, engaging learning sessions which make language learning a fun part of your daily routine and not a chore.

More information about our services and how you can use them can be found in our T&Cs and on our webpage.

2. Personal Information we process

When you interact with our Apps, we collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”).

The Personal Information we process depends on the context of your interactions with Konju, the products and features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:

Information you provide to us: You may provide certain Personal Information to us when you sign up to a Konju account and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your Google account with Konju), or communicate with us in any other way. This information may include:

Contact details such as your name, e-mail address, mailing address, phone number, profile image.
Account log-in credentials such as your email address or username when you sign up for an account with us;
Account holder information such as your location, interest in learning the language and skill level.
‍Troubleshooting and support data, which is data you provide, or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry.

Information we collect automatically: In some (but not all) countries, including countries within the EEA, this information is considered Personal Information under applicable data protection laws. Service Usage Data may include:

Browser or device information which is collected through your device, such as e-mail address and IP address for debugging purposes.
Usage data which is collected whenever you interact with our Service. This may include the dates and times you access the Services and your browsing activities (such as what portions of the Service you used). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other communications you send through the Service. If you are using our App, we may collect information about how often you use the App and other performance data. This information allows us to improve the content and operation of the Service and facilitate research and analysis of the Service.
Log data whereby our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP-addresses and your activity in the Services (such as the date/time stamps associated with your usage, results, pages and files viewed, searches and other actions you take (for example, which features you used)).
Cookies which allow us to collect information such as browser type and other anonymous traffic data. Please see our cookie policy for more information on our use of cookies.
Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of our Users, measure the success of marketing campaigns and compile statistics about usage of the Services and response rates.
Analytics, meaning the use of third-party analytic services, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.

Information we collect from other sources: From time to time, we may collect Personal Information about you from other sources, such as our Partners, integrations or other third parties, for example where you have given permission to the third party to share your information with us.

3. Use of Personal Information

We may use your Personal Information which we collect for the purposes and on the legal bases identified below:

Provide the Services. This means using your Personal Information in order to provide the Services’ functionality to you, such as arranging access to an account, responding to your inquiries. We engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Communicate with you. We may need to communicate with you about your account and provide you with customer support to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Services. For example, if you use our App, we may ask you if you want to receive push notifications about activity in your account. If you have opted in on these push notifications and no longer want to receive them, you may turn them off through your operating system. We may also send you system alert messages in reliance on our legitimate interests in administering the Services and providing certain features. For example, we may inform you about temporary or permanent changes to our Service, such as planned outages, security or compliance notifications, information about new features, version updates, releases, abuse warnings, and changes to this Privacy Policy.
Support and improve the Service. Your Personal Information may be used to provide, support and improve the Services in order to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Service and providing certain features. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to you. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws. For further information about how we share your information, refer to the “Personal Information Disclosure” section below.
Comply with legal obligations. We may use your Personal Information in order to comply with requests by public authorities, court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms. This includes Personal Information necessary to provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests, and Personal Information necessary to prosecute and defend a court, arbitration, or similar legal proceeding.
Data analytics. Your Personal Information may be used to perform data analytics in reliance on our legitimate business interests in improving and enhancing our products and services for our Users. For example, we use analytics data to enable product recommendation, audience segmentation, and predicted demographics features for our Users.
Marketing. We may use your Personal Information to serve you marketing information, product recommendations and non-transactional communications (such as email or push notifications) about us, in accordance with your marketing preferences and this Privacy Policy. We will not send you unsolicited written marketing.
Allowing you to participate in sweepstakes, contests and similar promotions. We may offer you the opportunity to participate in sweepstakes, contests and similar promotions. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information. Participation in these activities is fully optional, and subject to separate `just in-time´ notice as required. We engage in these activities to manage our contractual relationship with you.
Aggregated and anonymized data. User’s Personal Information may be used to combine and anonymize data about our Users and our User’s use of the Service in order to create aggregate, anonymized statistics which we may use to provide certain features within the Service and for promoting and improving the Service in reliance on our legitimate interests.

We do not sell Personal Information, and we do not send third party marketing to our users. For purposes of CCPA, and for the purposes of section 12 below, ´sale´ means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

4. Third-Party Integrations

We may use the Personal Information we collect or receive through the Service, as a processor and as otherwise stated in this Privacy Policy, to enable your use of the integrations and plugins you choose to connect to your Konju account. The Services and Websites include social media features, such as social media plug-ins with Twitter, LinkedIn, Instagram, TikTok and Facebook. These features may collect information about your IP-address and which page you are visiting on our Websites, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website.

We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

5. Third-Party websites

The Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, WhatsApp, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to these or other organizations.

6. Your Data Protection Rights

Depending on the country in which you reside, you may have one or all of the following data protection rights: ----------

Access. You have the right to know which of your Personal Information we process.
Rectification. You may ask us to rectify any error in your personal data.
Erasure (the right to be forgotten). You may ask us to erase your Personal Information, which request we will respect and comply with.
Restriction. You may ask us to restrict the processing of your Personal Information.
Object. You may object to the processing of your Personal Information.
Data portability. You may ask us to provide you or others with your Personal Information in a structured, commonly used and machine-readable format.
Complain to data protection authority. You may lodge a complaint with your applicable data protection authority regarding our collection and use of your Personal Information. Contact details for data protection authorities within the EU and EEA are available here.
Right to withdraw your consent. If Personal Information is collected or processed on the basis of consent, or if you have, for example, consented to receiving marketing emails from Konju, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

Please note that the above rights may be subject to exceptions and limitations. We cannot, for example, provide personal data if it would violate our duty of confidentiality or if we have a legal obligation to retain such data.

Exercise your rights.

If you wish to exercise any of the other privacy rights that apply to you, you can do this by reaching out to us on [email protected]. If we receive an email from you, we may ask you to verify your identity to comply with applicable law, and in order to help us respond efficiently to your request.

7. Personal Information Disclosure

Personal Information disclosure by Konju:

We do not share your Personal Information with third parties outside of Konju except in the following limited circumstances:

Service providers. Sometimes, we share your information with our third-party service providers working on our behalf for the purposes described in this Privacy Policy. For example, companies we’ve hired to help us provide and support our Service or assist in protecting and securing our systems and services and other business-related functions. Other examples include analyzing data, hosting data, engaging technical support for our Service, processing payments, and delivering content.
Advertising partners: Konju may cooperate with third party advertising platforms and social media channels to promote our Services, both on our Websites and third-party websites. To this effect, we may share limited Personal Information of our Users to achieve this purpose. For example, we and our third-party advertising partners may use cookies, pixels and web beacons and similar technologies to gather information about your activities on the Website and other websites to provide you with advertising based on your browser activities and interests. For further information, please see our Cookie Policy.
Public institution(s). Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.
Any other person with your consent.

We may also share anonymized, aggregated information with selected third parties for statistical purposes. Where we use any third parties to provide services on our behalf, and such third parties process your Personal Information, we enter into data processing agreements to ensure that such third parties comply with high levels of confidentiality and best practices with regards to privacy and data security standards. We regularly review these standards and practices and maintain a list of all sub-processors used for the services covered by this Privacy Policy.

Personal Information disclosure by you

Konju contain social features which enable a User to invite his/her friends & family to join the User on Konju. By inviting others to Konju, your User profile becomes visible to those that are invited. This means that some of your Personal Data, such as name and picture (as applicable), becomes visible for the invitees.

In order to invite others to Konju, a unique URL-link is generated for the User. As this link is unique to the User, the link may be shared by the invitee with other individuals. Unsolicited invitations using other Users URL-link may be in breach of our T&Cs and Konju reserves the right to take appropriate action if becoming aware of such unsolicited invitations. We therefore strongly advise you to only forward other User's unique URL-link with the User's prior consent.

8. Children

We only collect limited Personal Information about Children directly from the parent or guardian who has downloaded the Konju app. It automatically collects information about the device and usage while a Child is using the Konju app.

At all times we do not knowingly collect Personal Data from Children other than stated above. If you have reason to believe that a Child has provided Personal Data through the Services please contact us at [email protected] and we will endeavour to delete that information from our databases.

9. Our Security

We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at [email protected].

Konju accounts require an email and password to log in. Users must keep their email and password secure, and never disclose it to a third party. Because the information in a User’s Konju account is private, account passwords are hashed, which means we cannot see a User’s password. We cannot resend forgotten passwords either. We will only provide Users with instructions on how to reset them.

10. International Transfers

We collect information globally and may transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. This may involve countries where the data protection, privacy rights and other laws may not be as comprehensive as in your country. Whenever we transfer your information, we take steps, including preventive measures, to make sure your data is always safe.

For all international transfers, both within Konju or to our sub-processors, we ensure that the recipient of your Personal Information offers an adequate level of protection by entering into appropriate back-to-back agreements with our sub-processors. All international transfers are made on the basis of the EU Commission approved standard contractual clauses (“SCCs”).

Konju maintains strict organizational and technical measures to protect Personal Information stored on our, and our trusted third parties’, servers. Access to any Personal Information we process in order to provision the Services is limited through login credentials, multi-factor authentication, access on a need-to-know basis and restricted access to administrative accounts for the employees who require access in order to perform their duties towards you, such as providing support services.

11. Retention of Data

We never retain Personal Information longer than necessary for the purposes for which Personal Information was collected. We retain Personal Information where we have an ongoing legitimate business or legal obligation to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:--------

Whether we have a legal or contractual need to retain the data;
Whether the data is necessary to provide our Service;
Whether our Users would reasonably expect that we would retain the data until they remove it or until their Konju accounts are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

12. Do not Track

Certain US state laws require us to indicate whether we honor “Do Not Track” settings in your browser. Konju adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.

13. Changes to this Policy

We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Websites. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you.

14. Questions & Concerns

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, you may contact us on [email protected], or by postal mail to:

Sponge Labs LLC

30 N Gould St Ste R

Sheridan, WY 82801

USA

15. Supplementary Privacy Policy Statement for Mainland China

Last modified: 12.07.2022

15.1. Purpose and Scope

The Personal Information we process depends on the context of your interactions with Konju, the products and features you use, your location, and applicable law. Konju only uses your personal data when there is a legitimate legal basis for it. Konju will only process Personal Information based on your clear consent to provide the Services. Depending on the circumstances, Konju may also process your personal data based on where the processing is necessary to perform a contract with you, to protect your vital interests or that of others, or to comply with a legal obligation. This means that we will strive to collect only the personal data we need. For any other Personal Information and their purpose which is not specified in the “Privacy Policy” including the “Supplementary Privacy Policy Statement for Mainland China”, Konju will inform you in a reasonable manner and will obtain your consent. In case of any discrepancy or inconsistency between the “Privacy Policy” and the “Supplementary Privacy Policy Statement for Mainland China”, the “Supplementary Privacy Policy Statement for Mainland China” shall prevail.

15.2. Third-party integrations

Certain components of Konju may be associated with third-party services that Konju does not own or control, such as third-party software development kits (“SDK”) that our Services integrate to provide certain services or implement certain functions or third-party application programming interface (“API”) Your use of such third-party services is subject to their terms of service and their privacy policies will also apply. We encourage you to carefully read the privacy policy of the third party. We are not responsible for how third-parties use the personal information they collect from you and cannot control their use.

The details of our service accessing third-party SDK/API are as follows:

Apple Inc. – iOS payment processing service

Alphabet Inc – authentication, API, and backend

Zendesk, Inc. – SDK support tooling

GitHub, Inc. – development software

15.3. International transfers of Personal Information

We collect information globally and may transfer, process, and store your information outside of your country/region of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Therefore, Konju may process Personal Information related to individuals in mainland China in countries/regions other than mainland China. The relevant Personal Information will only be used for the necessary processing activities described in the “Privacy Policy” including the “Supplementary Privacy Policy Statement for Mainland China”. Whenever we transfer your information, we take steps, including preventive measures, to make sure your data is always safe.

15.4. Children's Personal Information

Konju understands the importance of protecting the Personal Information of children, who are individuals under the age of 14 in China. Konju handles children's Personal Information in accordance with our Privacy Policy. Konju treats children's Personal Information as sensitive personal data and complies with special rules regarding sensitive personal data set by law.

Konju only collects limited Personal Information about Children directly from the parent or guardian who has downloaded the Konju app. It automatically collects information about the device and usage while a Child is using the Konju app. At all times we do not knowingly collect Personal Data from Children other than stated above. If you have reason to believe that a Child has provided Personal Data through the Services please contact us at [email protected] and we will endeavour to delete that information from our databases.

15.5. Questions & Concerns

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, you may contact us on [email protected], or by postal mail to: Sponge Labs LLC, address at 30 N Gould St, Sheridan, WY 82801, USA.

16. Definitions

The following definitions applies to this Privacy Policy:

"Affiliate" means an entity that directly or indirectly Controls, is Controlled by or is under common Control with an entity.

“App” means Konju´s software/mobile applications.

"CCPA" means the California Consumer Privacy Act of 2018.

"Control" means an ownership, voting or similar interest representing fifty percent (50%) or more of the total interests then outstanding of the entity in question. The term "Controlled" shall be construed accordingly.

"EEA" means the European Economic Area.

"EU" means the European Union.

"Konju" means Sponge Labs LLC, organization number 2022-001191009, located at 30 N Gould St, Sheridan, WY 82801, USA.

"Personal Information" means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.

"Privacy Policy" means this Konju privacy policy.

“Services” means the Konju services, including any software, that are available on our platform.

"Service Usage Data" means information we gather automatically through your use of the Services and as further detailed in the "Personal Information we process" section below.

"T&C" means the Konju terms and conditions available here.

“Third Country” means any non-EU/EEA country

"User”, "you" and "your" means any person or entity that uses our Service(s).

"Visitor" means, depending on the context, any person who visits Konju Websites, offices, or otherwise engages with us at our events or in connection with our marketing or recruitment activities.

Language

This agreement was originally written in English. To the extent any translated version of this agreement conflicts with the English version, the English version controls.