Privacy Policy

Introduction: Who We Are and What This Policy Covers
Key Terms and Our Role
Legal Basis for Processing Your Data
What Personal Data We Collect and for What Purposes
Who We May Share Your Data With
International Data Transfers
How Long We Store Your Data (Data Retention)
Your Rights Under the GDPR
Cookies and Tracking Technologies
Security of Your Data
Children’s Privacy
Social Logins
How to Contact Us & Your Right to Lodge a Complaint

1. Introduction: Who We Are and What This Policy Covers

This „Langly Apps” branded mobile application and any related services (the „Application” or „Services”) are provided to you by LANGLY INC., a US registered company with company number 6769874, with its registered office at 16192 Coastal Highway, Lewes, Delaware (referred to as „LANGLY„, „we”, „us” or „our”).

This Privacy Policy (the „Policy”) explains how we collect, use, store, and protect your personal data when you use our Applications within Romania and the European Economic Area (EEA).

This Policy should be read together with our End User License Agreement (EULA).

2. Key Terms and Our Role

- Personal Data: Any information relating to an identified or identifiable natural person („data subject”). This includes your name, email address, IP address, device advertising identifiers, location data, etc.

- Processing: Any operation performed on personal data, such as collection, recording, storage, use, transfer, or deletion.

- Data Controller: For the purposes of our Services, LANGLY INC. is the controller of your personal data. This means we determine the purposes and means of the processing of your data.

3. Legal Basis for Processing Your Data

We only process your personal data when we have a lawful basis to do so under Article 6 of the GDPR. Depending on the purpose, we rely on the following legal bases:

- Performance of a Contract (Art.6(1)(b) GDPR): When processing is necessary to provide you with the Services you have requested (e.g., to create and maintain your account).

- Your Consent (Art.6(1)(a) GDPR): For specific purposes, such as marketing communications or the use of non-essential cookies for advertising and analytics. You have the right to withdraw your consent at any time.

- Our Legitimate Interest (Art.6(1)(f) GDPR): When we have a legitimate business interest that does not override your fundamental rights and freedoms (e.g., to improve our Services or prevent fraud).

- Legal Obligation (Art.6(1)(c) GDPR): When we are required to process data to comply with the law.

4. What Personal Data We Collect and for What Purposes

We only collect data that is necessary to achieve the stated purposes.

Data Category	Purpose of Processing	Legal Basis
Registration Data (name, email, password)	To create and manage your account, provide access to the Services.	Performance of a Contract
Social Media Data (profile, friends list when using social logins)	To simplify registration and login, and to enable social sharing features.	Performance of a Contract
Usage Data (features you use, session times, interactions)	To analyze and improve the Application’s performance, stability, and security.	Our Legitimate Interest
Technical Data (IP address, device type, OS, advertising IDs like IDFA/GAID)	To ensure compatibility, diagnose problems, and perform basic analytics.	Our Legitimate Interest
Precise Geolocation Data (GPS data)	To provide location-based features (e.g., weather) and to serve relevant ads.	Your Explicit Consent
Communications Data (content of your support requests)	To respond to your inquiries, resolve issues, and improve our support quality.	Performance of a Contract

5. Who We May Share Your Data With

We do not sell your personal data. We may share it with a limited number of parties:

- Service Providers (Data Processors): We engage trusted partners to perform technical functions (e.g., hosting, analytics, customer support). They act only on our instructions and are obligated to protect your data under Data Processing Agreements (DPAs) we have with them.

- Advertising Partners: With your explicit consent, we may share advertising identifiers and related data with ad networks to display personalized advertising.

- Public Authorities: Upon a lawful and verified request (e.g., a court order) as part of our legal obligations.

- In Case of a Corporate Transaction: In connection with a merger, asset sale, or bankruptcy, with users being notified accordingly.

6. International Data Transfers

As LANGLY INC. is based in the United States, your personal data is transferred to and processed outside of the European Economic Area.

We ensure that such transfers are conducted with an adequate level of data protection in compliance with Chapter V of the GDPR. To do this, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, which legally require the data recipient in the US to provide a level of protection equivalent to that in the EU.

7. How Long We Store Your Data (Data Retention)

We retain your personal data for no longer than is necessary for the purposes for which it was collected. The main criteria used to determine retention periods are:

- Active Users: We store your profile data as long as you use our Services (i.e., you have an active account).

- After Account Deletion: We may retain some data in an anonymized form for analytics. Personal data related to legal obligations (e.g., financial records) is kept for the period required by law.

- Consent-Based Data: We store this data until you withdraw your consent.

8. Your Rights Under the GDPR

As a data subject in the EU, you have the following rights:

- The right to access (Art.15 GDPR): You can request a copy of the personal data we hold about you.

- The right to rectification (Art.16 GDPR): You can ask us to correct inaccurate or incomplete data.

- The right to erasure (‘right to be forgotten’) (Art.17 GDPR): You can request the deletion of your data if it is no longer needed for its original purpose or if you withdraw consent.

- The right to restrict processing (Art.18 GDPR): You can request that we temporarily halt the processing of your data in certain situations.

- The right to data portability (Art.20 GDPR): You can request and receive your data in a structured, machine-readable format to transfer it to another controller.

- The right to object (Art.21 GDPR): You can object to the processing of your data based on our legitimate interests.

- The right to withdraw consent: Where processing is based on consent, you can withdraw it at any time. This will not affect the lawfulness of processing before its withdrawal.

To exercise these rights, please contact us at support@langly.ai. We will respond to your request without undue delay, and at the latest within one month.

9. Cookies and Tracking Technologies

We use cookies and similar technologies (e.g., advertising identifiers). They are divided into two categories:

Strictly Necessary: Required for the basic functionality of the Application. Your consent is not needed for these.
Analytics and Advertising: Used to analyze user behavior and display personalized advertising. We will only use these technologies after receiving your explicit, prior consent via our consent management banner.

You can manage your choices and withdraw your consent at any time in the Application’s settings.

10. Security of Your Data

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet is 100% secure.

11. Children's Privacy

Our Services are not directed to children. We do not knowingly collect personal data from individuals under the age of 16 (the age of digital consent in Romania). If you become aware that a child has provided us with personal data without parental consent, please contact us, and we will promptly delete that information.

12. Social Logins

Some of the Langly Apps may offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. We will use the information we receive only for the purposes that are described in this Privacy Policy. Please note that we do not control, and are not responsible for, other uses of your personal data by your third-party social media provider.

13. How to Contact Us & Your Right to Lodge a Complaint

If you have any questions about this Policy or our data processing practices, please contact us:

LANGLY INC.

16192 Coastal Highway, Lewes, Delaware, USA

Email: support@langly.ai