Privacy Policy

Effective Date: 11 March 2025
Last Updated: 11 March 2025

August Interactive, Inc. ("Company," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, store, and protect your personal data when you use Trumersion ("Application"), our AI-powered language learning platform. By using Trumersion, you agree to the terms of this Privacy Policy.

1. Information We Collect

We collect only the necessary data to improve your language learning experience and ensure the functionality of the Application. The data we collect includes:

a. Personal Information

• Name, email address, and account credentials (if applicable) when you register.
• Contact information for customer support inquiries.

b. Usage Data

• Interaction with the app, learning progress, and engagement metrics to enhance the user experience.
• Measure language proficiency.
• Preferences and feedback on AI-generated language responses.
• Provide  aggregate statistics to users and instructors/teachers.
• Publish anonymized summary statistics to the public at large

c. Device and Technical Data

• IP address, device type, operating system, and app performance analytics.
• Crash reports and diagnostics for improving app stability.

d. AI Training Data

• User inputs may be analyzed to enhance AI-driven language learning models but are never sold or shared with third parties for commercial purposes.

2. How We Use Your Information

We use collected data to:

• Provide, personalize, and improve Trumersion's features and learning tools.
• Monitor app performance, troubleshoot issues, and enhance security.
• Analyze user interactions to refine AI responses and optimize the learning process.
• Communicate important updates, security alerts, and customer support responses.
• Anonymized or aggregated wherever possible unless otherwise required by legal statue
• Generated language transcripts or (anonymized) audio recordings, behavioral, gameplay, or demographic data used solely to improve  user experience or adaptive model capabilities only

We do not sell, rent, or trade your personal information to third parties for marketing or advertising purposes.

Legal Basis for Processing

For users in the European Economic Area (EEA) and UK, we process your personal data based on the following legal grounds:

• Consent: When you explicitly agree to the processing of your data for specific purposes.
• Contractual Necessity: When processing is necessary to provide you with our services.
• Legitimate Interest: When processing is necessary for our legitimate business interests, such as improving our services or preventing fraud.
• Legal Obligation: When we need to process data to comply with legal requirements.

3. Data Security and Protection

We prioritize your security with robust measures:

• Encryption: All sensitive data is encrypted both in transit and at rest.
• Access Controls: Restricted access to personal data, ensuring only authorized personnel can view it.
• Regular Audits: Routine security reviews to identify and mitigate risks.
• Compliance: Adherence to data protection regulations such as GDPR, CCPA, and other applicable laws.

Data Breach Notification Procedures

In the event of a data breach that affects your personal information, we will:

• Notify affected users without undue delay, typically within 72 hours of becoming aware of the breach.
• Provide details about the nature of the breach, potential consequences, and measures taken to address it.
• Work with relevant authorities as required by applicable laws.

4. Third-Party Services and Data Sharing

We may share necessary data only with trusted service providers that help us operate the Application, such as:

• Cloud storage providers for secure data management.
• AI processing services for language model improvements.
• Analytics tools for understanding app performance and user engagement.

All third parties are contractually obligated to uphold stringent security and privacy standards. No third party may sell or exploit your data for independent use.

International Data Transfers

Your personal data may be transferred to, stored, and processed in countries outside your country of residence or the European Economic Area. When we transfer data internationally, we implement appropriate safeguards to ensure your data remains protected in accordance with this Privacy Policy and applicable laws. These safeguards may include Standard Contractual Clauses approved by the European Commission, the UK government, or other legally acceptable mechanisms.

5. Your Data Rights and Choices

You have the following rights regarding your data:

• Access & Correction: Request access to or correction of your personal data.
• Data Deletion: Request deletion of your data, subject to necessary legal obligations.
• Opt-Out of Communications: Unsubscribe from promotional emails or adjust notification settings.
• Restrict Processing: Limit how your data is used for AI model improvements.
• Data Portability: Receive your data in a structured, commonly used format.
• Object to Processing: Object to certain types of processing, including automated decision-making.

To exercise any of these rights, please contact us at support@augustinteractive.gg.

Automated Decision Making and Profiling

Our Application uses AI algorithms to personalize your language learning experience based on your interactions and progress. You have the right to:

• Request human intervention in any automated decision-making process.
• Express your point of view regarding automated decisions.
• Contest automated decisions that significantly affect you.

Right to Lodge Complaints

If you are located in the EEA, UK, or another jurisdiction with similar laws, you have the right to lodge a complaint with your local data protection authority if you believe our processing of your personal data violates applicable laws.

6. Data Retention

We retain user data only as long as necessary for:

• Delivering Trumersion's services.
• Compliance with legal and regulatory obligations.
• Improving our AI models and platform features (with anonymized data when possible).

Once data is no longer needed, we securely delete or anonymize it.

7. Children's Privacy

Trumersion is not intended for children under the age of 13 without parental consent. If we become aware of data collected from a child under 13 without proper consent, we will take immediate steps to delete it.

8. Cookies and Tracking Technologies

Our Application may use cookies and similar tracking technologies to enhance user experience and collect information about how you use our services:

• Essential Cookies: Necessary for the Application to function properly.
• Analytics Cookies: Help us understand how users interact with our Application.
• Preference Cookies: Remember your settings and preferences.

You can manage cookie preferences through your device or browser settings. Note that disabling certain cookies may affect the functionality of our Application.

9. California Privacy Rights

California residents have specific rights under the California Consumer Privacy Act (CCPA) and "Shine the Light" law:

• Right to know what personal information is collected, used, shared, or sold.
• Right to delete personal information held by businesses.
• Right to opt-out of the sale of personal information.
• Right to non-discrimination for exercising CCPA rights.

California residents can request information about our disclosure of personal information to third parties for direct marketing purposes by contacting us at the information provided below.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify users of significant changes through in-app notifications or emails. Continued use of Trumersion after such changes constitutes acceptance of the updated policy.

Change Log

• 11 March 2025: Initial Privacy Policy published.

11. Data Processing Addendum

For business or enterprise customers processing personal data subject to GDPR, CCPA, or similar regulations, we offer a Data Processing Addendum (DPA). To request our DPA, please contact us at legal@augustinteractive.gg.

12. Dispute Resolution

Any privacy-related disputes will be resolved through:

1. Direct communication with our support team.
2. If unresolved, through a formal complaint process managed by our legal team.
3. If still unresolved, through applicable regulatory authorities or arbitration as required by law.

13. Contact Us

For any questions or concerns about this Privacy Policy, please contact us at:

August Interactive, Inc.
PO Box 2488

Reston VA, 20190

Email: support@augustinteractive.gg
Privacy Officer: privacy@augustinteractive.gg